1. Meeting our Public Sector Equality Duty: our equality objectives

1.1 Key legislative requirements

The purpose of the Specific Equality Duties (SEDs) is to enable ‘the better performance’ by public authorities of the Public Sector Equality Duty (PSED). The Equality and Human Rights Commission (EHRC) sets out the 3 sets of requirements in the specific duties in its technical guidance:

• the first set requires certain listed authorities to publish gender pay gap information on their employees
• the second set requires certain listed authorities to publish information to demonstrate their compliance with the general equality duty (‘equality information’)
• the third set requires the preparation and publication of one or more equality objectives which each organisation thinks it should achieve to do any of the things mentioned in the general equality duty (‘equality objectives’)

The SEDs allow for the publication of ‘information within another published document’ but the information must be published ‘in a manner that is accessible to the public.’ The EHRC also advises that ‘objectives should focus on the biggest equality challenges that a public authority faces’.

1.2 The purpose of this report

This report explains how NHS England met the requirements of the PSED and the 2 sets of reporting requirements provided by the SEDs (see parts 2, 3 and 4).

As part of the NHS reforms announced in March 2025, over the next 2 years NHS England will be integrated into the Department of Health and Social Care (DHSC) and cease to exist as a separate legal entity. At that time, responsibility for setting equality objectives for transferred functions will become the responsibility of the new DHSC and considered as part of their PSED and SED responsibilities. These changes directly impact NHS England’s equality objectives and targets for 2025/26. In some cases it has been appropriate to revise targets but further changes will need to be considered this year.

2. Pay gap reporting during 2024/25

2.1 Pay gap reporting

This section considers the first set of SED reporting requirements and identifies how NHS England has complied with statutory requirements on pay gap reporting during 2024/25. It includes statutory gender pay gap reporting and identifies steps taken by NHS England, over and above its statutory requirements, to provide 3 further pay gap reports and to develop action plans.

2.2. Gender pay gap reporting

NHS England published our gender pay gap report for 2022/23 in December 2024. The report provided a snapshot of the gender pay gap (GPG) on 31 March 2023.  At that time, NHS England was in the middle of a merger: NHS England and NHS Digital legally merged on 1 February 2023, followed by Health Education England (HEE) on 1 April 2023.

This report combined data from employee staff records across the 3 former organisations. Although HEE did not formally merge into NHS England until the day after the snapshot on 31 March 2023, it was treated in this report as being part of the new organisation. The report included the GPG data for each of the 3 organisations, NHS England, NHS Digital and HEE, for 2017/18 to 2021/22 and the information for NHS England in 2022/23. For the snapshot date of 31 March 2023, the report compares GPG data for different pay bands.

We published our GPG report for 2023/24 on 21 March 2025. It includes the GPG data for each of the 3 organisations for 2017/18 to 2021/22 and the information for NHS England in 2022/23 and 2023/24. For the snapshot date of 31 March 2023 and 31 March 2024, the report also compares mean GPG data. For the snapshot date of 31 March 2024 the report compares GPG data for different pay bands.

2.3 Disability pay gap reporting

Disability pay gap (DPG) reporting is not yet a statutory reporting obligation but the Government has announced plans to make it so. NHS England published a DPG report for 2023/24 on 21 March 2025. The DPG measures the difference between the average hourly rate paid to disabled and non-disabled employees, using both median and mean averages.

The report included the DPG data for each of the 3 organisations for 2017/18 to 2021/22 and compared the DPG data for NHS England in 2022/23 with 2023/24. Using a snapshot date of 31 March 2024 the report compared DPG data for different pay bands.

2.4 Ethnicity pay gap reporting

Ethnicity pay gap (EPG) reporting is not yet a statutory reporting obligation but the Government has announced plans to make it so. NHS England published an EPG report for 2023/24 on 21 March 2025. The ethnicity pay gap measures the difference between the average hourly rate paid to Black and Minority Ethnic (BME) employees and that paid to white employees, using both median and mean averages.

The report included the EPG data for each of the 3 organisations for 2017/18 to 2021/22 and compared the DPG data for NHS England in 2022/23 with 2023/24. Using a snapshot date of 31 March 2024 the report compared DPG data for different pay bands.

2.5 Sexual orientation pay gap reporting

Sexual orientation pay gap (SOPG) reporting is not a statutory reporting obligation. NHS England published a SOPG report for 2023/24 on 21 March 2025. The SOPG gap measures the difference between average hourly rate paid to Lesbian, gay, and bisexual (LGB) employees and heterosexual employees, using both median and mean averages.

The report included the SOPG data for NHS England for 2017/18 to 2021/22 and compared the SOPG data for the new NHS England in 2022/23 with 2023/24. Using a snapshot date of 31 March 2024 the report compared SOPG data for different pay bands.

2.6 Action planning and pay gap reporting

Actions to address the pay gap findings were published on 21 March 2025. These plans were published after the decision to reduce NHS England’s headcount by 50% alongside the integration of NHS England into the DHSC.

3. Progress against the 2024/25 equality objectives and targets

3.1 Context

A summary of progress made during 2024/25 for each of the 8 equality objectives and targets is provided here.

3.2 Equality objective 1 [COVID-19 and recovery]

Equality objective 1: To ensure that the equality and health inequality impacts of COVID-19 and key lessons learnt are fully considered and that clear strategies are developed and implemented for the NHS workforce and patients of all ages as the NHS continues to move beyond the recovery phase. To ensure that patient and workforce focused strategies reflect this and make an effective contribution to advancing equality for people of all ages by reference to protected characteristics and to reducing associated health inequalities. 

Target 1: To ensure that operational, planning and associated guidance to systems considers how to address and reduce the adverse equality impacts of COVID-19 and provides strategic guidance to the NHS.

The 2024/25 priorities and operational planning guidance reconfirmed the ongoing need to recover core services and improve productivity, making progress to deliver our ambitions for the NHS workforce and transform the NHS for the future. The need to address health inequalities as we recover core services was embedded throughout the guidance, maintaining the priority to reduce inequalities in line with the Core20PLUS5 approach. The 2025/26 priorities and operational planning guidance sets out the continuation of our approach to reducing health inequalities.   

Guidance for integrated care boards on updating their joint forward plans for 2024/25 set out how key legislative requirements should be addressed, including those which impact on equalities and health inequalities. This included the duty to reduce inequalities, the duty to promote integration, the duty to consider the wider effect of decisions (including the so-called ‘triple aim’), and the quality of service duty. 

Target 2: To work to ensure that key NHS England patient strategies consider the lessons learned from COVID-19 and how to address and reduce the adverse equality impacts of COVID-19.

Progress is set out under the assessment for targets 1 and 3. In addition, NHS England teams were supported to undertake equality and health inequalities impact assessments for major programmes. Other initiatives are set out in part 4.

Target 3: To develop and implement strategies in elective recovery, including for people of all ages, in order to reduce the adverse equality impacts of COVID-19 as the NHS moves further into the recovery phase.  

Throughout 2024/25, systems and providers were encouraged to interpret and address health inequalities within local systems. This has taken the form of numerous local interventions, using data to identify where patients with protected characteristics were at greater risk of experiencing inequality – such as through higher Did Not Attend rates, longer waiting times, or issues with patients navigating the complexity within the system.

Waiting list data was also examined nationally to highlight the waiting list profile in terms of age, gender, ethnicity and deprivation, and to identify areas of inequality. As part of the work to develop a new elective reform plan, a task and finish group was established to:

• conduct an evidence review to identify major clinical risks and inequalities
• assess the quality of health inequalities data
• clarify performance and assurance models for health inequalities

This review considered the available national data, the efficacy of local interventions and the input of a diverse group of stakeholders and patient representatives to identify the most effective national and local actions to address health inequalities across all patient groups, including protected characteristics beyond those recorded in national data. 

Following this work, in January 2025 a new plan, Reforming elective care for patients, was published. This sets out the core deliverables needed to return to the 18 week wait standards. NHS England has committed to: 

• collating and publishing data to help improve the uptake of national health inequalities initiatives throughout 2025/26 ​  
• improving the submission and quality of demographics data to increase understanding and insight into health inequalities ​  
• create communities of practice across organisations with similar patient populations to share learning about how to reform elective care equitably and inclusively  
• review local patient transport services and improve signposting to and accessibility of them for patients ​  
• ensure consistency in the availability of accessible and alternative language communication templates​  
• support the expansion of the Health Equity and Referral to Treatment tool and embedding other waiting list prioritisation tools, including those for children and young people ​  
• work with primary and community care to ensure care coordinators support vulnerable and disadvantaged patients, especially those with multiple long-term conditions​  
• prioritise areas with greater health inequalities for future investment of new capacity, for example, community diagnostic centres​  
• offer tailored communication, especially in areas with significant inequalities, to raise awareness of the choices patients can make​  

Progress was made during 2024/25 against, however the elective reform plan, and the underlying work to develop it, indicate there is more to do to address health inequalities. It is therefore recommended that the targets are adjusted to align with the commitments in the plan (see appendix 1).

3.3 Equality objective 2 [Capability]

Equality objective 2: To improve the capability of NHS England to understand and address the PSED’s legal obligations and the interface with the separate health inequalities duties.  

Progress against target 1: To improve the capability of NHS England’s teams to understand and address the PSED’s legal obligations.

During 2024/25, NHS England reviewed the Equality Act 2010 changes including those which came into force in 2024 (see part 5). Consideration was also given to the ongoing impact of changes to the health inequalities duty (section 13G, National Health Service Act 2006). This work informed guidance provided to NHS England colleagues on producing Equality and Health Inequalities Impact Assessments (EHIA).

NHS England also reviewed its framework for Equality and Health Inequalities Impact Assessments and revised our EHIA templates to prepare for rolling out the revised framework in 2025/26. Additional information was provided on NHS England’s intranet and we continued to make NHS England colleagues aware of the Equality and Health Inequalities Network (EHIN), which enables a wide range of people to interact and explore how to advance equalities and reduce health inequalities (see update on equality objective 7).  

3.4 Equality objective 3 [Information]

Equality objective 3: To improve the mapping, quality and extent of equality information to better facilitate compliance with the PSED in relation to patients and NHS service-users of all ages, NHS service delivery, and the NHS workforce.  

Progress against target 1: To work with the DHSC, Office for National Statistics (ONS), NHS arm’s length bodies, and other government bodies to identify how best to carry forward and oversee the work of the Unified Information Standard for Protected Characteristics (UISPC) Project.

NHS England continued to work in partnership with DHSC and reviewed documents produced for the UISPC programme. This involved research to update the major literature and evidence review and to produce an updated scoping report and recommendations. A raft of legislative changes to the Equality Act 2010 came into force in 2024 as did new EHRC statutory guidance. Following the general election, the government announced there would be significant further legislative changes. In addition, there were a number of key legal cases, including cases considered by the Supreme Court where important decisions were awaited.

During 2024/25, there were detailed discussions on the main issues with partners including colleagues from NHS England’s Transformation Directorate, ONS, the Government Statistical Service (GSS) and DHSC.

The UISPC Publication Steering Group (PSG) was reconvened in February 2025 to discuss next steps and how its members and other relevant colleagues in NHS England and the DHSC would feed into the reports and recommendations. The UISPC PSG included representation from NHS system partners and cross government system partners with responsibilities for the development and management of NHS systems, information governance, surveys and associated matters with respect to workforce and patient systems. From March 2025, the PSG commenced the review of the draft reports ahead of consideration by NHS England and the DHSC.

3.5 Equality objective 4 [Internal workforce]

Equality objective 4: To improve, by reference to protected characteristics, the recruitment, retention, progression, development, and experience of the people employed by NHS England to enable the organisation to become an inclusive employer of choice. 

Progress against target 1: To maintain the 19% aspirational target of BME representation at all levels of our organisation.  

As of 31 December 2024, the target was surpassed at all bands except 8c (17.9%), 8d (14.2%), 9 (12.4%) and Executive Senior Managers (ESM) (18%).

Following this analysis, broader disparities in representation and equality across other protected characteristics were identified, prompting a decision to expand the scope of this target to lesbian, gay, and bisexual and disability representation. 

Progress against target 2 and target 5: Target 2. To continue increasing declaration rates of under-represented groups in our workforce including disabled colleagues; and Target 5. To seek to improve our diversity representation through organisational change.  

During the reporting period from 1 January to 31 December 2024, declaration rates increased for several groups. Black and Minority Ethnic (BME) representation rose from 21.7% to 22.5%. Lesbian, gay, and bisexual (LGB) representation saw a slight increase from 4.7% to 4.8%. Disability representation saw the most significant increase from 8.8% to 10.6%. 

To address challenges to self-declaration, initiatives were undertaken to encourage colleagues to update their personal information on the Electronic Staff Record (ESR). This included integrating updates into the 1:1 template, reminders in Management Matters and using other internal communication channels. 

In addition, efforts focused on fostering a psychologically safe environment for colleagues to declare disability data. This included embedding workplace adjustments initiatives, leveraging the Disability Confident Scheme, and aligning actions with the Workforce Disability Equality Standard (WDES) strategy. These combined measures aimed to reduce stigma and build trust, encouraging more accurate reporting of disability status across the organisation. 

Progress against target 3: To undertake a change programme on our recruitment and promotion, further enabling the organisation to become an employer of choice and a workforce that reflects the communities we serve.

During 2024/25, the organisation further developed its inclusive recruitment approach. This meant equipping hiring managers with practical tools and clear guidance on fair shortlisting, inclusive interview techniques, and reducing bias at each stage of the recruitment process. These efforts supported the organisation’s wider priorities around improving workforce representation at all levels and creating a more inclusive/equitable employee experience. Recruitment guidance and training resources were created to support hiring managers to foster diversity and equity. 1,602 colleagues received training. In addition, the end-to-end recruitment journey was mapped to identify further opportunities to enhance inclusivity and efficiency. 

Steps were taken to streamline the recruitment process, with changes implemented in January 2025. These included realigning roles between the Recruitment team and NHS Business Services Authority to improve the transition from vacancy approval to onboarding and reduce delays and inconsistencies that it was considered may have disproportionately affected underrepresented groups. The aim was to support a more equitable recruitment experience. To address the underrepresentation of BME and disabled colleagues in leadership roles (particularly at bands 8c and above) and disparities in outcomes for these and LGBT colleagues, a pilot Accelerated Development Programme (ADP) was launched. The programme provided 12-month development placements in band 8c or 8d roles alongside coaching, tailored learning opportunities and senior leader sponsorship. 

Training placements were advertised in November 2024 and work has been undertaken since that date, with placements due to begin in April 2025. Support has also provided to a wider group who had shown interest in the training programme.

While preparing successful candidates for their placements, support was also developed for the 222 unsuccessful applicants. This included constructive feedback, signposting to leadership development opportunities and invitations to a tailored workshop to enhance communication skills. 

Through these initiatives, NHS England strengthened its commitment to fostering diversity, equity and inclusion in recruitment and promotion, ensuring a positive candidate experience. 

Progress against target 4: To reset our EDI strategy, for the new NHS England, creating opportunities to refresh our targets to ensure they are reflective of our EDI values, local labour markets and accommodating the rapid growth of a merged workforce.  

The work we started during 2023/24 as part of NHS England’s EDI improvement plan provided the foundation for resetting the EDI strategy in 2024/25. The improvement plan was developed to support staff through organisational change while ensuring business continuity within the newly merged NHS England. 

The revised strategy maintained a focus on the 7 priority areas in the improvement plan: inclusive recruitment; talent management; leadership and accountability; accessibility; trade union and staff network engagement; safety to speak up; and employee relations. It was underpinned by enhanced workforce data analysis and the introduction of new diversity representation targets, addressing broader issues such as underrepresentation across certain groups within the workforce. 

Following the endorsement of the draft strategy by the People and Remuneration Committee (PRC) in July 2024, extensive staff engagement was conducted to shape the strategy, including with staff network chairs, trade unions and wider colleagues. The new strategy emphasises leadership accountability and improved staff experiences, in line with the NHS-wide EDI improvement plan. 

An implementation plan was finalised in early 2025 in collaboration with the People and Organisational Development functions. It included clear timeframes and ownership for actions, ensuring a cross-organisational effort beyond the EDI team. Governance mechanisms, such as the PRC, People Board, and EDI Board will play a key role in driving delivery. It is anticipated that the final version of the strategy, and accompanying targets, will be published in 2025/26. 

3.6 Equality objective 5 [Patient access and communication]

Equality objective 5: To improve access and reduce communication barriers experienced by individuals and groups of people of all ages, by reference to protected characteristics, who need NHS services.  

Progress against targets 1 and 2: Target 1. To publish the updated Accessible Information Standard (AIS). Target 2. To publish the updated AIS self-assessment framework, e-learning resources and supporting documentation.

During 2024/25, NHS England has comprehensively reviewed the existing AIS. Alongside, we have developed a suite of documents to support colleagues to implement it. This includes updated implementation guidance, guidance on a new AIS self-assessment and template, and e-learning resources.

Additionally, accessible versions of the documents have been produced to assist people with communication needs to access the standard in appropriate formats.

Given the closer working with DHSC during this transition period referred to above, NHS England is now engaging with DHSC on next steps for finalisation and publication of the documents and resources.

Progress against target 3: Through the evaluation of the Equity and Equality Guidance and implementation of Local Maternity and Neonatal Systems (LMNS) equity & equality action plans, in furtherance of pledge 4, NHS England will measure progress in relation to reducing inequalities in perinatal mortality rates for babies from Black, Asian and mixed ethnic groups and identify how good practice can best be shared and spread.

The most recent data available show that significant inequalities persist:

• Maternal mortality: whilst the rate for Black women continued to decrease in 2021-23, it was double (28.21 per 100,000 maternities) that of White women (12.2).  Asian women (16.74) had a slightly increased risk (MBRRACE-UK 2025).
• Stillbirth & neonatal mortality rate in 2023 for Black babies (11.1 per 1,000 total births) was double that of White babies (5.6), for Asian babies (9.2) the rate was 60% higher (ONS 2025). However ethnic disparities in perinatal outcomes persisted. MBRRACE-UK Perinatal mortality surveillance, data published in May 2025 shows that stillbirth rates declined for Black and White babies but increased by 10% for Asian babies. Black babies remained more than twice as likely to be stillborn as White babies. Neonatal mortality rates decreased across all ethnicities but remained highest for Asian and Black babies.
• Experience: in 2024, women of Black, Asian and Mixed ethnicity backgrounds report significantly better experiences than White women (CQC 2024).
• Ethnicity coding data completeness: continues to show year-on-year improvement, reaching 96% in 2024 (unpublished analysis of the Maternity Services Data Set (MSDS)).

Equity and equality work was driven by a national steering group, established in October 2024, co-chaired by the Chief Midwifery Officer and the national clinical directors for maternity and neonatal. Members include multiple expert stakeholders including service users. The national maternity lead for equality chaired 3 other groups: the Service User Equity and Equality Steering Group promoted equity in maternity care for all women and babies; the Diversity in Midwifery Steering Group engaged underrepresented groups in midwifery training; and the Workforce Steering Group aimed to improve the experience of maternity staff from ethnic minority groups.   

NHS England produced a framework summarising the drivers of higher maternal and perinatal mortality for Black and Asian women and babies in November 2024.The steering group agreed a prioritised list of interventions in March 2025. 

Equity and Equality guidance for Local Maternity and Neonatal Systems (LMNS) aims to help systems to improve equity for mothers and babies and race equality for staff. By May 2024, every LMNS had published an equity and equality action plan to outline how the guidance will be implemented. An evaluation of implementation reported in March 2025.  Key findings include: 

• implementation of action plans increased, from 45% in March 2023 to 83% in December 2024
• at a local level, action plan implementation resulted in equity for mothers and babies becoming higher priority; better understanding of local health needs; and increased service user engagement

In 2024/25, the NHS invested £10 million recurrently to address inequalities including for enhanced midwifery continuity of carer teams, where safe staffing is in place. 37 teams were in operation, providing care to women living in the most deprived 10% of neighbourhoods. The Genetic Risk Equity project continued to be piloted in 10 areas of high need. The project supports equity of access to genetics services for the small proportion of consanguineous couples who have a higher risk of having children affected by certain genetic conditions. The evaluation should report in July 2025.

185 midwives participated in the Changing and Growing Together Maternity Reverse Mentorship Programme. They shared stories of culture change, personal transformation, increased confidence and wellbeing, and a growth in empathy and compassion for each other, with White staff matched with midwives from ethnic minority groups.  

NHS England supported over 90 ethnic minority midwives, neonatal nurses and their White managers through the Elevate leadership development programme and White Allyship at Work Programme. Co-designed with the London South Bank University, the programme won the Exceptional Programme of the Year award at the Ethnic Minorities into Leadership Awards 2024.  

Online cultural competence and safety training continued to be available to all staff. The tool was developed in collaboration with the Royal College of Midwives. 

In May 2024, 140 sites received a set of clinical training aids to support care for women and babies with Black or dark skin, so training is more representative of the communities we serve. 

The Health inequalities duties statement helps NHS bodies understand their duties and powers. It applies from 1 April 2023 to 31 March 2025. It includes 2 indicators relating to maternity services: pre-term births (before 37 weeks) by ethnicity and deprivation; and the proportion of maternity inpatient settings offering smoking cessation services.  

NHS England’s Board, at its meeting of 16 May 2024, received an update on maternity and neonatal services which affirmed the NHS’s commitment to tackle inequalities. 

3.7 Equality objective 6 [System workforce]

Equality objective 6: To improve, by reference to protected characteristics, the recruitment, retention, progression, development and experience of staff in the NHS workforce. 

Progress against target 1: To implement the high impact actions (and their associated success metrics) included in the national NHS Equality, Diversity and Inclusion (EDI) improvement plan seeking by 2024/25 to develop improvement trajectories for this programme.

To support the implementation of the NHS equality, diversity and inclusion improvement plan during 2024/25, the NHS Staff Survey results dashboard was improved with new features including two-factor analysis at a national, regional and ICS level to allow greater understanding of intersectionality. The dashboard contains results at a national, regional, ICS and organisation level, including benchmarking data for individual organisations. It also includes results for NHS Staff Survey indicators used in the Workforce Disability Equality Standard and the Workforce Race Equality Standard. This improved functionality supported the ability of NHS organisations to analyse key equality information contained in the 2024 NHS Staff Survey published in March 2025 augmenting the ability at local and national levels to benchmark and undertake comparative analysis.

This additional functionality improved the ability of organisations to address 4 of the 6 High Impact Actions (HIA) that underpin NHS equality, diversity, and inclusion improvement plan launched in 2023.

The implementation of the NHS equality, diversity and inclusion improvement plan during 2024/25 was also supported by:

• webinars facilitated with regulators on workforce outcomes, partnered with NHS Providers for a National Collaborative of ICBs to understand the implementation of HIAs and established a Regional EDI Leads Forum to track the impact of implementation
• webinar for Board Members on using data from the NHS EDI Dashboard, WRES, and WDES for strategic decision-making. This is to support HIAs 1,3 and 6. To further support implementation of HIA 3, partnered with NHS Providers for a peer learning session on ethnicity pay gap reporting
• developed a bespoke EDI Improvement Plan for the primary care sector with extensive engagement from colleagues between September 2024 and January 2025
• following the culture review of ambulance trusts published in February 2024, NHS England has completed the action to develop a bespoke ambulance sector EDI improvement plan
• commissioned NHS Employers Diversity in Health Care Partners programme to support organisations to deliver on the NHS EDI Improvement Plan and Henley Business School to develop a curriculum for a Future Leadership Apprenticeship Diploma in EDI
• supported Cohort 2 of the NHS People Promise Exemplar programme with targeted EDI interventions via learning events
• partnered with NHS Employers to facilitate Roundtable discussions on implementing the EDI Improvement Plan, utilising data to influence strategic decision making and NHS EDI Repository
• the NHS sexual safety charter was updated in October 2024

Progress against target 2: To implement a framework for monitoring the number of volunteers across the NHS by reference to protected characteristics and any other relevant characteristics.  

The NHS Volunteer Workforce Data Collection was introduced as mandatory for all NHS trusts in April 2024, with returns submitted on a quarterly basis. It is a collection of metrics that aim to understand the number of volunteers, the number of hours volunteers contribute and equalities data about those volunteers that aligns with workforce data. In 2024/25 the number of volunteers was the only mandatory item on the return with trusts working toward full compliance with all metrics by April 2025. Trusts, integrated care boards and national healthcare organisations can use the published data to: 

• establish a standard dataset of information regarding the number, composition and contribution of volunteers  
• monitor and tailor recruitment activities to support resilience and ensure volunteers are representative of communities served
• understand volunteer numbers and flux at the various levels to support decision making and demonstrate meeting equality duties and or targets   

The NHS Volunteer Workforce Dashboard is updated quarterly.  

3.8 Equality objective 7 [integrated care boards]

Equality objective 7: To work with integrated care boards (ICBs) to support their compliance with the Equality Act 2010’s Public Sector Equality Duty (PSED) and the associated Specific Equality Duties (SEDs). 

Progress against targets 1 and 2: Target 1. To work in partnership with Equality and Human Rights Commission (EHRC) to ensure clear guidance is produced for ICBs on the development of equality information and equality objectives. Target 2. To identify the best ways to support ICBs to meet PSED/SED requirements.

Progress against both targets was facilitated by NHS England and the EHRC continuing to work in partnership and providing support through the Equality and Health Inequalities Network (EHIN). During 2024/25, membership of the network –

NHS organisations, local authorities, academics, VCSE organisations – continued to grow from just over 7,000 to 7,700. Hosted by NHS England’s Equalities and Involvement Team, the network continues to bring together materials to improve patient equality and health inequalities. The EHIN draws members from local authorities, academics, and others.

Key resources added during 2024/25 were intended to support various initiatives, including appraisal conversations, AI assurance, knowledge management, survey guidance, and tracking progress against equality objectives. The EHRC delivered webinars including on race equality in maternity care and ending inappropriate detention of people with learning disabilities and autistic people. The EHRC also used EHIN to make the sector aware of EHRC publications. EHIN members used the network to communicate with colleagues and share information, good practice, research and calls for information.

3.9 Equality objective 8 [System landscape]

Equality objective 8: To ensure that the equality objectives for NHS England address the relevant statutory functions, duties, powers and responsibilities of NHS England created by the Health and Care Act 2022.

Progress against targets 1 and 2: Target 1: To harmonise the arrangements for PSED and SED compliance across the new NHS England. Target 2. To review and assess how best to incorporate the Equality Objectives, developed for NHS Digital and Health Education England, into the work to develop revised Equality Objectives for the new NHS England.  

The equality objectives approved in May 2024 were the first steps to achieve harmonised equality objectives for NHS England, including to account of the mergers of NHS Digital and Health Educational England with NHS England in 2023. 

Early discussions were held with colleagues about how to best address equality and health inequalities impact assessments in the digital sphere but these discussions were placed on hold pending decisions about the final shape of the reorganisation first announced in 2022. This equality objective and associated targets have been revised following the Government’s announcement in March 2025 that NHS England will be integrated into DHSC (see part 5 and appendix 1).

4. Meeting our Public Sector Equality Duty (PSED): our wider equality information

This section provides further information on equalities work undertaken by NHS England in 2024/25.

4.1 Patient equalities

Work was undertaken in 2024 to review the NHS Equality and Diversity Council’s (EDC) terms of reference and membership. The first meeting of the new EDC was held on 27 February 2025. This meeting adopted revised terms of reference, including setting out the purpose of the Council: to help to improve the access, experiences and health outcomes for all patients and communities and to support the NHS to become a more inclusive employer by using the talents of its diverse staff and the communities it serves. EDC members are senior leaders from NHS commissioning organisations, professional membership bodies, EDI leads in NHS organisations and key partners.

The first meeting of the EDC looked at the development of the 10 Year Health Plan, the People Plan and the work of the LGBT Health Team from an equality and diversity perspective. 

NHS England’s LGBT Health team continued to develop the NHS Rainbow Badge quality improvement programme, working with 77 NHS trusts across the country to support their work to address LGBT health inequalities and to support organisations to become more inclusive for their LGBT+ workforce. 

NHS England’s LGBT Health team undertook a recruitment process to the LGBTQ+ Sounding Board, which is a diverse group of 27 LGBT+ individuals with lived experience and knowledge of the health inequalities faced by their communities. The group meets virtually to support feedback, engagement, co-production and consultation for policy and programme teams at NHS England on areas of relevance to LGBT+ people. The Sounding Board is a key NHS England mechanism that ensures LGBT+ people are appropriately involved in our work at a national level. It includes influencing policy development, service design, and supporting appropriate and effective communications targeting the LGBT+ community across the country. In the last year the Sounding Board has supported engagement work with a range of NHS England’s policy teams including: the mental health team, the Specialised Commissioning team, the New Hospitals team, the Children’s and Young People’s team and the Primary Care team. 

4.2 Healthcare inequalities improvement programme

4.2.1 Key work by the programme

The national Healthcare Inequalities Improvement Programme undertook a range of work in 2024/25 to reduce health inequalities. In July 2024, we reported to the NHS England Board in our annual report on NHS England’s work on healthcare inequalities and the NHS Race and Health Observatory. This report detailed the work of the NHS Race and Health Observatory to address the health inequalities related to the protected characteristic of race. This includes publishing and overseeing work across the domains of maternity and neonatal health, mental health, sickle cell disease, genomics, the workforce, and COVID-19, making recommendations for policy and practice. In April 2024, NHS England published a review of ICB Joint Forward Plans. The purpose of the review was to ensure each plan contains appropriate action to tackle inequalities, with a focus on equity of access for all population groups.  

Regional teams completed their annual assessment of ICBs for 2023/24, with annual assurance published in January 2025. The assurance report includes an assessment of tackling unequal access, experience and outcomes, based on data published by ICBs for the first time in 2024 in response to NHS England’s statement on information on health inequalities. 

NHS England worked to strengthen its Healthcare Inequalities Measurement Framework, and  developed indicators to support evidence-based quality improvement and routine disaggregation of national performance reporting. These indicators were embedded into national data dashboards in 2024/25 to mitigate against the risk of health inequalities being masked by aggregated data. The indicators are:

• Ratio of rate of preterm births for black and Asian women compared to white women
• Modelled gap in preterm birth rate between the most and least deprived populations
• Gap in emergency admissions for Myocardial Infarction (indirectly age sex standardised rate) between the most deprived quintile and the rest of the population
• Gap in emergency admissions for Stroke (indirectly age sex standardised rate) between the most deprived quintile and the rest of their population.
• Early cancer diagnosis by deprivation
• Percentage of NHS talking therapies patients completing a course of treatment and achieving reliable recovery, by ethnicity, against a 48% target for 24.25.
• The percentage of people on primary care severe mental illness registers who receive a full annual physical health check, against a 75% target (60% minimum by March 2025)
• Pulmonary rehabilitation completion by deprivation
• Flu vaccine uptake – percentage point difference between the most deprived 20% of the eligible population (IMD 1 and 2) and the average of the remaining eligible population (IMD 3 to 10)

Data from these indicators shows improvement in the gap in access and outcomes for the most deprived communities and ethnic minority groups over the last two years across a range of areas, however there remains variation between ICBs.

NHS England has also responded to data quality challenges that affect the quality of insight into healthcare inequalities, and during 24/25 has developed and engaged on an ethnicity recording improvement plan designed to address gaps in the completeness of ethnicity records used to analyse inequalities in access, experience and outcomes.

During the year NHS England worked with the NHS Innovation Accelerator (NIA) programme on a health inequalities callout, of which 2 successful candidates made it onto the full NIA programme (C2-Ai and the Sickle Cell Society). NHS England catalysed health inequalities research investment to the tune of circa £800 million from a range of organisations including NIHR (various health inequalities grants and challenge calls), Prostate Cancer UK (Transform trial), Cancer Research UK (SAMBAI global cancer health inequalities challenge), Academy Health (US based philanthropy funded research call into medical devices inequalities) and several others. 

4.2.2 Community languages 

Healthcare Safety Investigation reports published in 2023, outlined patient safety recommendations for the NHS to provide written communications in community languages, highlighting the significant impact this has on patient safety. Further recommendations also link to monitoring use, at the appropriate time, of interpretation services, including ensuring that time-critical care is not delayed as a result.  Following a detailed strategic review in response to the safety recommendations, during 2024/25 NHS England has engaged on, tested and developed a draft framework for action on community language translation and interpreting.

4.2.3 Digital

A framework for NHS action on digital inclusion, published in September 2023, identified older age as the strongest single predictor of reduced internet access and use among adults and that digital services must be designed to alleviate healthcare inequalities rather than exacerbate them. The report recommended that reducing health inequalities and improving digital inclusion have due focus in wider inclusive user design and delivery for all digital products and services. In line with the government plan for the NHS to ‘shift from analogue to digital,’ planning guidance for 2025/26 continued to outline the requirement for all systems to mitigate against digital exclusion, including by implementing the framework for NHS action on digital inclusion.

4.3 Workforce equalities

4.3.1 The Workforce Disability Equality Standard and the Workforce Race Equality Standard

The Workforce Disability Equality Standard (WDES) and Workforce Race Equality Standards (WRES) are mandated standards that provide a strategic direction for disability and race equality. NHS England published the Workforce Disability Equality Standard: 2023 data analysis report for NHS trusts and the 2023 Workforce Race Equality Standard report in March 2024.  

4.3.2 New legislation introduced in 2024/25

The National EDI team continued to address the gender pay gap in medicine by asking all lead employers of postgraduate doctors in training to report annually on ethnicity and gender pay gaps. To ensure system readiness for forthcoming legislation, the national EDI Team:   

• engaged with systems to understand challenges, identify good practice and shape national direction through regional and national networks   
• facilitated several webinars to prepare organisations to explore their own ethnicity data  
• developed a technical guidance package to support trusts to utilise existing reporting functionalities effectively  
• facilitated a peer learning session in November 2024 on the introduction and implementation of ethnicity pay gap reporting

To prepare employers for the new duties created by the Worker Protection (Amendment of Equality Act 2010) Act 2023 and The Equality Act 2010 (Amendment) Regulations 2023, the national EDI team:   

facilitated a round table with organisations in February 2025 to share good practice and identify mechanisms which deter incidents of sexual harassment, including workplace accountability for the prevention of sexual violence 

• delivered an online learning event in March 2025 to update and consult with providers on the EHRC sexual harassment technical guidance and share resources to support implementation of the new Workers Protection Action (2024) 
• supported the Violence Prevention and Reduction team to promote NHS England’s updated violence prevention and reduction standard in December 2024, including the new red, amber, green rating to assist organisations to identify areas to action and measure improvements to safeguard NHS staff against abuse, aggression and violence.   

4.4 Key considerations from the EHRC

4.4.1 EHRC: detention (inappropriate) of people with a learning disability and autism

As at January 2025, over 62% of people aged 14 and over on a GP learning disability register had received an annual health check with nearly 60% of them with an accompanying health action plan. NHS England is currently piloting a primary care health check for autistic people.

At the end of January 2025, the number of autistic people and people with a learning disability in a mental health inpatient unit was 2,065 (1,845 adults and 220 under 18s). This is a reduction of 29% since March 2015 (the baseline for measuring progress on NHS England’s commitment to reduce reliance on mental health inpatient care for these groups of people).  

In 2024/25, NHS England provided national investment of £124 million to enable local areas to develop community intensive support teams, community forensic teams, and 24/7 crisis response for people with a learning disability and autistic people as alternatives to mental health inpatient care. There are now keyworker services in all integrated care systems for children and young people with a learning disability and autistic children and young people who are at risk of admission, or who have been admitted to, a mental health hospital.  

NHS England‘s housing capital programme made £13 million available in 2024/25 to support local areas to develop housing to reduce the number of autistic people and people with a learning disability in a mental health hospital setting. In January 2025, we published updated housing capital guidance. Throughout 2024/25, NHS England supported a national housing community of practice. 

In the summer of 2024, three reports were published by King’s College London including on bowel cancer, cardiovascular disease and pneumonia. These reports were commissioned to understand the impact specific conditions have on people with a learning disability.

4.4.2 EHRC: detention of ethnic minority people under the Mental Health Act 1983

The 2024/25 priorities and operational planning guidance set out a series of requirements in relation to mental health and associated services. Under part 2H, the guidance required the implementation of the patient and carers race equality framework (PCREF) by the end of 2024/25, and for mental health providers to ‘establish the governance structure and reporting metrics at trust level to monitor the access, experience, and outcomes of ethnic minority groups, and build organisational competencies’. 18 pilot trusts are working alongside NHS England to help strengthen the implementation of the PCREF. This involves putting in place practical and organisational changes in response to the recommendations of the Independent Review of the mental health act reforms on promoting equality by reducing disparities including racial disparities.

A critical part of implementing the PCREF is partnership working with patients, carers and local organisations. All pilot trusts have been co-designing and co-delivering the PCREF, enabling an equal balance of power and accountability. In 2024/25 all pilot trusts established a governance structure where patient, carer and community representatives alongside voluntary sector organisations that represent ethnic minority communities to provide feedback on the implementation of the PCREF. In some of the pilot trusts they set up an independent advisory board and other trusts recruited community representatives to lead the patient and carer voice to ensure improvements are made to the access, experience and outcomes for ethnic minorities. The partnership working supports assurance on monitoring data on race inequalities, and combined with the independent element of the governance is critical to ethnic minorities feeling empowered and has helped remove historical barriers.  

Data has also been critical to shift the dial on racial inequalities and trusts have taken positive steps to improve data collection. This included the development of each trust’s dashboard to help the organisation, its partners and their local communities to understand the data. This helped with transparency and assurances on tracking progress. The dashboard also helped as a learning tool to identify gaps and see where activities were having the most positive impact.  For example, one of the PCREF pilot trusts reported, in 2024/25, a decrease in the average length of detention under the Mental Health Act for patients of mixed ethnicity, showing early signs of a downward trend—from a previous high of 80 days to 67 days per 100,000 population. This is notably below the national rate of 177 (MHA Statistics, 2023/24).

By contrast, all 18 trusts have reported a significant and upward trend in the overrepresentation of Black British patients detained under the Act. On average, one trust reported a peak detention length of 270 per 100,000 population in 2024/25, which exceeds the national rate of 242.

Since 2023/24 and leading up to 2024/25, we have seen a fluctuation in detention rates across all ethnic groups, (the overall average, typically ranging from 69 to 270 per 100,000 population), these trends continue to serve as a reminder that the PCREF is one key intervention in addressing disparities and tackling ethnic inequalities across England.

5. Major legislative and NHS reforms and the impact on NHS England’s equality objectives and targets

5.1 Recent and planned changes to Equality legislation

Following the general election in July 2024, the Government announced a range of planned changes to employment and equality legislation which will not come into force until either later in 2025/26 or 2026/27. The central provisions are: proposals to bring the Equality Act 2010’s Socioeconomic Duty provisions into force; a consultation on mandatory ethnicity and disability pay gap reporting; and the Employment Rights Bill

5.2 Key NHS reforms

In March 2025, the Prime Minister and the Secretary of State for Health and Social Care announced that ‘over the next 2 years, NHS England’ would be ‘brought into the department [the Department of Health and Social Care] entirely’ (NHS England: Health and Social Care Secretary’s statement, DHSC, 13 March 2025). Over the next eighteen months, it is expected that NHS England will work increasingly closely with the DHSC as the new 10 Year Plan is published and implemented and as functions are reviewed ahead of the merger. At this point in time, it is not possible to fully identify the implications for NHS England’s equality objectives and the NHS England Board will keep the situation under review to ensure that the organisation is focusing on the right things at the right time.

The changes described above fundamentally alter the environment within which NHS England will function during 2025/26 and until it ceases to exist and compliance with the Equality Act 2010, the PSED and SEDs, with respect to transferred responsibilities, will then be addressed by the DHSC.

5.3 Recommendations: equality objectives and targets for 2025/26

Given the changes, in some cases, it has not been possible to propose amendments to an equality objective or target. Appendix 1 provides the brief rationale where changes are proposed. Appendix 2 lists those targets that have been dropped for 2025/26 and a brief rationale. Three overarching recommendations are set out below given the importance of equalities.

• Recommendation 1: Equality objective 7 [Integrated Care Boards] and equality objective 8 [system landscape] should be amended to include consideration of the forthcoming major legislative and policy reforms.
• Recommendation 2: The equality objectives and targets should be the subject of a joint review by NHS England working in partnership with the DHSC during 2025/26 to facilitate recommendation 1.
• Recommendation 3: Given the merger programme, the equality objectives and targets in appendix 1 should be regarded as provisional unless reviewed in accordance with recommendation 2. However, the equality objectives and targets must be worked towards unless the review recommends changes at which time the rationale for any changes will be properly documented and a decision made by the appropriate governance body.
• Recommendation 4: NHS England will work towards making our equality objectives and targets more performance and outcome driven in 2025/26.  This will involve the identification of suitable equality focused performance measures, appropriate statistics and data for relevant equality objectives and targets. This work will inform the joint review identified in recommendation 2.

Appendix 1: NHS England’s proposed equality objectives and targets for 2025/26 

Equality objective 1 [COVID-19 and Recovery]  

To ensure that the equality and health inequality impacts of COVID-19 and key lessons learnt are fully considered and clear strategies are developed and implemented for the NHS workforce and patients of all ages as the NHS continues to move beyond the recovery phase. To ensure that patient and workforce focused strategies reflect this and make an effective contribution to advancing equality for people of all ages by reference to protected characteristics and to reducing associated health inequalities.  

Revised target: To advance the actions outlined in the elective reform plan, NHS England will identify and work to address inequalities within elective care through enhancing data collection and utilisation, reviewing patient transport options, and leveraging technology to ensure greater equity in managing patient pathways.   

Rationale

The new target has been proposed to align with the elective reform plan commitments.

Equality objective 2 [Capability]  

To improve the capability of NHS England to understand and address the PSED’s legal obligations and the interface with the separate health inequalities duties.   

Continued target: To improve the capability of NHS England’s teams to understand and address the PSED’s legal obligations. 

Equality objective 3 [Information]  

To improve the mapping, quality and extent of equality information to better facilitate compliance with the PSED in relation to patients and NHS service-users of all ages, NHS service delivery, and the NHS workforce.   

Continued target: To continue to work with the DHSC, ONS, NHS arm’s length bodies, and other government bodies to identify how best to carry forward and oversee the work of the UISPC Project and move to publish the reports. 

Equality objective 4 [Internal workforce] 

To improve, by reference to protected characteristics, the recruitment, retention, progression, development, and experience of the people employed by NHS England to enable the organisation to become an inclusive employer of choice. 

New target: To review this equality objective and develop an equality objective and targets appropriate to the integration of NHS England into the Department of Health and Social Care. 

Rationale for revised target

Given the planned incorporation of NHS England into the DHSC, HR equality commitments will naturally need to be informed by this plan.

Equality objective 5 [Patient access and communication]  

To improve access and reduce communication barriers experienced by individuals and groups of people of all ages, by reference to protected characteristics, who need NHS services.   

Revised target 1: To publish the updated AIS self-assessment framework, e-learning resources and supporting documentation

Rationale for revised target

This merged revised target replaces targets 1 and 2 set for 2024/25 (see appendix 2).

Revised target 2: Through the implementation of further, co-produced equity and equality interventions for maternity and neonatal care, in addition to those in Local Maternity and Neonatal Systems’ equity and equality action plans, NHS England will strengthen and better co-ordinate action to improve equity for mothers and babies from Black and Asian ethnic groups and improve workforce race equality within maternity and neonatal services.  NHS England will measure progress in relation to reducing inequalities in perinatal mortality and preterm birth rates for babies from Black and Asian ethnic groups and identify how good practice can be shared and spread.  

Rationale for revised target

This revision of the 2024/25 target (see appendix 2) reflects developments in this policy area. It will support the DHSC to implement the government’s manifesto commitment to ‘set an explicit target to close the Black and Asian maternal mortality gap.’ 

Equality objective 6 [System workforce]  

To improve, by reference to protected characteristics, the recruitment, retention, progression, development and experience of staff in the NHS workforce.   

Continued target: To continue to implement the high impact actions (and their associated success metrics) included in the national NHS Equality, Diversity and Inclusion (EDI) improvement plan seeking by 2025/26 to develop improvement trajectories for this programme.  

Equality objective 7 [integrated care boards]  

To work with integrated care boards (ICBs) to support their compliance with the Equality Act 2010’s Public Sector Equality Duty (PSED) and the associated Specific Equality Duties (SEDs) taking due account of the NHS reform agenda and significant changes in relevant legislation. 

Continued target 1: To work in partnership with Equality and Human Rights Commission (EHRC) to ensure clear guidance is produced for ICBs on the development of equality information and equality objectives. 

Continued target 2: To identify the best ways to support ICBs to meet PSED/SED requirements.

Equality objective 8 [System landscape]  

To ensure that the equality objectives for NHS England address the relevant statutory functions, duties, powers and responsibilities of NHS England and address the NHS reform agenda and significant changes in relevant legislation.  

New target 1: Working in partnership with the DHSC to agree arrangements for reviewing NHS England’s equality objectives and targets and assessing which should be maintained and amended. 

New target 2: Working in partnership with the DHSC, to work towards making NHS England’s equality objectives and targets more performance and outcome driven in accordance with recommendation 4.

Rationale for new equality objective and targets

The 2024/25 equality objective has been amended to take account of major changes in the system landscape. Target 1, has been developed that also takes account of the changes in the system landscape. Target 2 has been added to work towards making NHS England’s equality objectives and targets SMARTER.

Appendix 2: Deleted equality targets for 2025/26

The rationale for the deletion of some equality targets for 2025/26 has been provided in this appendix. Please note that the targets for 2025/26 are set out in appendix 1. We have only included equality objectives where one or more equality target has been deleted for 2025/26.

Equality objective 1 [COVID-19 and Recovery] 

Target 1: To ensure that operational, planning and associated guidance to systems considers how to address and reduce the adverse equality impacts of COVID-19 and provides strategic guidance to the NHS. [Delete]

Target 2: To work to ensure that key NHS England patient strategies consider the lessons learned from COVID-19 and how to address and reduce the adverse equality impacts of COVID-19. [Delete]

Rationale for deleting these targets

Target 1 was deleted because addressing health inequalities is embedded in the 2025/26 priorities and operational planning guidance and is set out explicitly as a national priority, to be incorporated into multi-year planning enabled by the upcoming publication of the 10 Year Health Plan. Production of an Equality and Health Inequalities Impact Assessment (EHIA) for priorities and planning guidance has been embedded into the planning process. The EHIA will be reviewed biannually and updated in line with future priorities and planning guidance, to appropriately assess the impact that planning guidance for systems has on addressing health inequalities. As a priority area NHS England will monitor the planning and delivery of measures to address health inequalities closely and measure progress against the priority over the course of 2025/26.

Target 2 was deleted because work in relation to patient equalities will be supported under Equality Objective 3 and Equality objective 8.

Equality objective 4 [Internal workforce] 

Target 1: To maintain the 19% aspirational target of BME representation at all levels of our organisation. [Delete]

Target 2: To continue increasing declaration rates of under-represented groups in our workforce including disabled colleagues. [Delete]

Target 3: To undertake a change programme on our recruitment and promotion, further enabling the organisation to become an employer of choice and a workforce that reflects the communities we serve. [Delete]

Target 4: To reset our EDI strategy, for the new NHS England, creating opportunities to refresh our targets to ensure they are reflective of our EDI values, local labour markets and accommodating the rapid growth of a merged workforce. [Delete]

Target 5: To seek to improve our diversity representation through organisational change. [Delete]

Rationale for deleting these targets

Given the integration programme and the transfer of NHS England staff to the DHSC, targets 1 to 5 are deleted.

Equality objective 5 [Patient access and communication] 

Target 1: To publish the updated Accessible Information Standard (AIS). [Delete]

Target 2: To publish the updated AIS self-assessment framework, e-learning resources and supporting documentation. [Delete]

Rationale for deleting these targets

Targets 1 and 2 have been deleted because a revised target for the AIS has been proposed, that incorporates both targets.

Rationale for deleting this target

Target 3 has been deleted because a revised target reflects developments in this policy area and will support the DHSC to implement the government’s manifesto commitment to ‘set an explicit target to close the Black and Asian maternal mortality gap.’ 

Equality objective 6 [System workforce] 

Target 2: To implement a framework for monitoring the number of volunteers across the NHS by reference to protected characteristics and any other relevant characteristics. [Delete]

Rationale for deleting this target

Target 2 has been deleted because it was achieved in 2024/25.

Equality objective 8 [System landscape] 

Target 1: To harmonise the arrangements for PSED and SED compliance across the new NHS England. [Delete]

Target 2: To review and assess how best to incorporate the Equality Objectives, developed for NHS Digital and Health Education England, into the work to develop revised Equality Objectives for the new NHS England. [Delete]

Rationale for deleting these targets

Given the integration programme, targets 1 and 2 are deleted but consideration will be given, as part of the joint review with DHSC, to how to embed a revised wider objective.