DEI isn’t dead. But the US and UK are telling very different stories.

While in the US companies have pulled DEI off their websites, the UK has largely further entrenched it into law, but with notable setbacks.

The most misread story in our field is the "mass roll back and collapse" of DEI in the US and, some assume, in the UK. But when you look closely, and two countries are heading in almost opposite directions.

In the US, the currently administration declared war on DEI and the retreat has been loud. References to "DEI" fell by around 98% across Fortune 100 communications between 2023 and 2025, and public disclosures to the Corporate Equality Index dropped by roughly two-thirds in a single year. Yet only about 5% of companies actually scrapped their programmes. So, it suggests this isn't abandonment — it's de-risking. American firms pulled inclusion off the website to avoid the ire of their government while quietly keeping it in the building. DEI went undercover.

The UK is a different picture. An Institute of Directors survey of 605 business leaders found 71% had no intention of changing their approach, and only 11% expected to scale back. And where the US has moved to deregulate, the UK has done the reverse. The Employment Rights Act 2025 introduced gender equality action plans for larger employers, and a forthcoming Equality (Race and Disability) Bill is set to make ethnicity and disability pay gap reporting mandatory. Notwithstanding the recent supreme court ruling on gender and the ongoing confusion on the guidance of what the ruling should mean in practice, the Equality Act 2010 has largely meant that in the UK, inclusion sits on a stable legal base, not a fragile pledge.

The diverging picture in the US and UK

But don't mistake stability for depth. CIPD research found almost half of UK employers (47%) have no inclusion strategy, and a quarter describe their approach as reactive. That's the real threat to progress in the UK, quiet complacency, not dramatic rollback – because inclusion that was never truly owned doesn't get cut, it quietly fails to deliver and become dormant.

So, what if you lead across both markets? The trap is choosing between one rigid global policy and total local improvisation. Neither works. Instead, it’s important to set a consistent floor: the principles, behaviours and standards you hold everywhere. Then adapt how you express and badge it in each market. In the US that may mean leading with business outcomes and taking legal advice before setting hard targets. In the UK it means leaning into your reporting obligations and the chance to stand apart by going further. Thus, the core stays fixed while the framing flexes and adapts.

The overall lesson is the same. Inclusion that lives on a banner or in a compliance checklists is fragile. Inclusion embedded in how decisions are made, products are designed, and managers are measured is the kind that lasts.