Implementation of the EU Pay Transparency Directive: The latest position in Ireland

Why should I read this?

The EU Pay Transparency Directive (Directive (EU) 2023/970) (the Directive) required Member States to transpose it into national laws by 7 June 2026. Ireland did not meet that deadline. However, gender pay gap reporting was already mandatory in Ireland before the Directive entered into force, and the Irish reporting framework has continued to evolve since its introduction in 2022.

Since 2022, employers in Ireland with 250 or more employees have been required to report on their gender pay gap. The threshold was reduced to 150 or more employees in 2024, and to 50 or more employees in 2025. Further changes apply to the 2026 reporting cycle, including mandatory reporting through a central online Gender Pay Gap Portal (Portal) and a shortened reporting window after the snapshot date.

This briefing summarises the key aspects of the existing requirements in Ireland, including the new obligation to submit reports through the Portal and the outlook for full transposition of the Directive.

A summary of the position in Ireland

Every employer in Ireland with 50 or more employees must prepare and publish prescribed gender pay gap information. This already covers some of the gender pay gap reporting required by the Directive, albeit that the Irish regime applies from a lower employee threshold than the Directive’s minimum threshold of 100 employees. However, the Irish regime does not yet align with the Directive in full. Outstanding elements include reporting by categories of workers performing the same work or work of equal value, pay transparency at the recruitment stage, the right of workers to request pay information and joint pay assessment obligations.

The Portal launched in November 2025, initially on a voluntary basis. For the 2026 reporting cycle, it is now mandatory for employers to submit their gender pay gap information and, where required, their written statement to the Minister through the Portal. When submitting the information, employers must confirm that it is accurate.

Filing on the Portal does not replace an employer’s existing publication obligations. Employers must continue to publish their figures and any statement on their website in a manner accessible to all employees and the public. Employers without a website must make a copy available for inspection during normal business hours at their registered office or principal place of business. Reports must remain available and accessible for at least three years from the date of publication.

“Mandatory reporting through the Gender Pay Gap Portal brings greater visibility and comparability to gender pay gap data in Ireland. For employers, the focus should not simply be on reporting the figures, but on understanding what is driving any gaps and taking meaningful steps to address them.”

Mary Gavin, Partner

Reporting through the Gender Pay Gap Portal

Legislative framework

The reporting obligations are principally set out in section 20A of the Employment Equality Act 1998, which was inserted by the Gender Pay Gap Information Act 2021 and amended by the Employment Equality and Institutional Burials (Amendment) Act 2026. Parts 1 and 2 of the 2026 Act came into operation on 1 November 2026. The amendments provide the statutory basis for requiring employers to report gender pay gap information to the Minister, in addition to publishing it.

The practical detail, including what must be reported and how it must be calculated, is set out in the Employment Equality Act 1998 (Section 20A) (Gender Pay Gap Information) Regulations 2022. The Regulations were amended in 2024 and 2025 and, most recently by the Employment Equality Act 1998 (Section 20A) (Gender Pay Gap Information) (Amendment) Regulations 2026 (S.I. No. 548 of 2026), which came into operation on 1 November 2026, an implement the new Portal reporting requirements.

Key dates

Several key dates provide the framework for reporting:

• snapshot date (the “relevant date”): any date in June, selected by the employer each year
• reporting period: the 12 months ending on, and including, the snapshot date
• deadline: employers must publish their report and submit it through the Portal within five months (previously six months) of the snapshot date. For example, an employer that chooses 26 June 2026 as its snapshot date must publish and submit its report by 26 November 2026

What information must be reported

Employers must report the following information:

• mean and median hourly pay gaps for all employees
• mean and median hourly pay gaps for part-time employees
• mean and median hourly pay gaps for employees on temporary contracts
• mean and median bonus gaps, calculated by reference only to employees who received a bonus
• the percentage of men and women who received a bonus
• the percentage of men and women who received benefits in kind
• the percentage of men and women in each of the four pay quartiles

Explaining your gap

If any of the reported figures show differences in pay referable to gender, the employer must also prepare a written statement, setting out, in the employer's opinion, the reasons for the differences and the measures (if any) being taken, or proposed to be taken, to eliminate or reduce them.

The statement must:

• comply with the legislation
• not contain any personal data; and
• be suitable for publication by the Minister

The Minister may review the statement and, if it does not meet these requirements, return it to the employer, which then has 10 working days to correct and resubmit it through the Portal.

Data protection

Under the amended Regulations, employers must ensure that employees’ personal data is pseudonymised before it is reported to the Minister. Where an employer obtains data from a third party, such as a payroll provider, the applicable pseudonymisation requirements should also be built into the arrangements with that provider.

Employers should also consider the risk of individuals being identifiable indirectly from published gender pay gap information, particularly where figures relate to small employee populations or sub-groups. Pseudonymised data remains personal data where an individual can be re-identified, so employers should consider whether publishing granular information could create a re-identification risk (see our briefing - EU Pay Transparency Directive: Data protection).

Failure to comply

Sections 85B and 85C of the Employment Equality Act 1998 provide for enforcement where an employer fails to comply with its obligations. The legislation provides two principal enforcement routes:

• Court orders: the Irish Human Rights and Equality Commission (IHREC) can apply to the Circuit Court or High Court for an order requiring an employer to comply
• Employee complaints: an employee can refer a complaint to the Workplace Relations Commission (WRC), which can order the employer to take a specified course of action to comply. Either party can appeal to the Labour Court within 42 days

Neither route currently provides for fines or compensation for failure to comply with the reporting obligations. By contrast, the Directive requires Member States to lay down effective, proportionate and dissuasive penalties, including fines, and to ensure that workers can claim full compensation for loss suffered as a result of breaches of their rights under the Directive.

What is likely to happen next? 

On 15 January 2025, the Government published the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024, which included two provisions aimed at partly transposing the Directive in relation to recruitment. These would require employers to provide information about salary levels or ranges either in the job advertisement or before interview, and would prohibit employers from asking applicants about their pay history or current rate of pay. The General Scheme subsequently underwent pre-legislative scrutiny, with the Joint Committee on Children and Equality publishing its report in October 2025. In March 2026, however, the Department of Children, Disability and Equality confirmed that these pre-employment measures will instead be included in a dedicated Pay Transparency Bill.

Separately, the Employment Equality and Institutional Burials (Amendment) Act 2026 was signed into law on 24 October 2026. As mentioned above, it amended section 20A of the Employment Equality Act 1998 to provide the statutory basis for mandatory reporting through the Portal for the 2026 reporting cycle.

Those amendments do not themselves complete Ireland's transposition of the Directive, leaving it exposed to potential infringement action by the European Commission while work continues on the outstanding implementing legislation. The Government has indicated that implementation will take place on a phased basis once the legislation has been passed.

Employers should use this interim period to review job architecture, pay-setting and progression criteria, recruitment practices and the quality of the data needed to meet the Directive's more granular reporting and information requirements. The missed transposition deadline is not a reason to pause preparations.