Developments around people reporting obligations has been a popular topic of conversation in recent months. A large number of HR professionals are about to face into their first Gender Pay Gap reporting cycle, while others, who have already run the GPG gauntlet are now turning their minds to the anticipated, and potentially heightened, responsibilities set to flow from the EU Pay Transparency Directive and the (still-evolving) EU Corporate Sustainability Reporting Directive. Keeping up with the various changes and updates at local and European level is no easy feat and it can be overwhelming trying to determine exactly what is required, under which legislation and when. Below the employment team from EY Law Ireland summarise the current position under these 3 regimes, including a short overview of key and anticipated requirements.

(1)    Gender Pay Gap Reporting updates

Gender pay gap (“GPG”) reporting is now mandatory for all public and private organisations in Ireland with 50 employees or more.  This year’s report must be published by November 2025, allowing just five months to report from the snapshot date in June. 

What else has changed?
The GPG reporting portal will launch in the autumn. This is the first time that one single platform in Ireland will publish all GPG reports. 

Updated Regulations are expected to ensure that sufficient information is available to support employers to report. 

What needs to go into my report?
In scope, employers must publish the following information about their employees for a 12-month period prior to snapshot date:

1. The difference between the mean and median hourly and bonus remuneration of male and female employees.
2. The difference between the mean and median hourly remuneration of part-time and temporary male and female   employees.
3. The percentage of male and female employees who received bonuses and benefits in kind.
4. The percentage of male and female employees in each of four quartile pay bands.

Employers must also publish a narrative setting out the reasons for any GPG in their organisation and the measures (if any) being taken, or proposed to be taken, to eliminate or reduce such differences. 

(2)    The EU Pay Transparency Directive (the “Directive”)
The Directive contains significant additional measures linked to GPG, such as:

• reporting on the GPG between ‘categories of worker’ broken down by basic and variable pay, and disclosing the percentage gap in pay between men and women, as well as the ratio between its highest paid individuals and the average;
• requirements to conduct equal pay audits/assessments in certain circumstances; and
• increased employee and representative involvement to address pay equity and joint pay assessments (1);
• making information accessible to employees to help them understand pay, pay levels and pay progression .

Is the Directive law yet?
Not quite. The Directive must be implemented by June 2026. In January 2025, the Irish Government took some initial steps, by publishing a General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 which (although subject to change) included two provisions aimed at enhancing transparency prior to employment by:-
(i)    Requiring employers to provide information about salary levels/ranges in job advertisements; and
(ii)    Prohibiting employers from asking job applicants about their own pay history/current rate of pay.

It remains unclear if the draft Bill in its current form will become a formal Bill and eventually law, but the Government’s Spring 2025 Legislative Programme includes reference to the ‘Pay Transparency Bill’. 

So where exactly do things stand now?
In short, watch this space. In the meantime employers can get ahead of the curve by identifying and addressing any pay gaps before the Directive is implemented.

(3)    The EU Corporate Sustainability Reporting Directive (“CSRD”)
The EU (Corporate Sustainability Reporting) Regulations 2024 (the “Irish Regulations”) transposed the CSRD into Irish law in July 2024 and were originally (2) set to commence on a staggered basis by reference to company size and turnover.
In scope Companies will be required to report (3) on the following:
•    The risks they face from changing climate and other Environmental, Social and Governance matters (financial materiality).
•    The impacts they themselves may have on climate and society (impact materiality).
•    Information on their value chain.

Reporting will be in accordance with 12 detailed ESG reporting standards (ESRS) which were published by the EFRAG ( European Financial Reporting Advisory Group). Of these 12, four ESRS (S1-S4) cover social matters which include a requirement for companies to make disclosures relating to their workforce or corporate social responsibility. Drill further down into these and you will find details of what’s expected.

Given the nature of the contents of ESRS (S1-S4), it is highly likely that HR practitioners will be drawn into collating relevant data for sustainability reporting, making this a topic that warrants ongoing monitoring by readers as the framework and requirements develop. 

Recent changes and what to look out for
In February 2025 the EU Commission announced that it has adopted a new package designed to reduce the complexity of EU requirements for all businesses. The focus of the regulatory framework will be on the largest companies (likely to have a greater impact on the climate and environment). (4)  If approved, original scope and thresholds could change such that the reporting requirements could be deferred by 2 years for companies that, under the current framework, would be required to report in 2026 and 2027.

What next for CSRD?
The proposals will be considered by the European Parliament and the Council . The proposals are at an early stage and remain subject to further amendments (if they are approved at all) before they are transposed into domestic Irish law. (5)

4. With all of the moving parts, what do I actually need to do RIGHT NOW?
There’s a lot of noise around HR reporting and compliance at present. However, in short, the only current reporting obligation in the HR space in Ireland at present is in respect of GPG, and in particular, those organisations with 50+ employees. When it comes to the Directive and CSRD, practitioners should continue to monitor the ongoing developments and changes expected over the course of 2025 and beyond. 

GPG – top tips
For those embarking upon their first GPG outing (or those looking to improve on earlier processes), the following may assist:

1. Fail to prepare, prepare to fail – many people facing into their first GPG report will underestimate the time that it’s going to take, the resources required, and the wiggle room needed to reconfigure projected timelines when something unexpected comes up.
2. Expect the unexpected! Whether it’s data issues, tech issues, people/resourcing issues, disagreements on calculation methods or messaging – assume that problems will arise and allow for this when allocating tasks, resources and timelines.
3. Have a Plan B – many companies have found that they simply do not have either the people or the tech resources to coordinate a GPG reporting project from start to finish. Get support early.  
4. Don’t forget about the messaging! Once a company understands the data, it will need to socialise and communicate it. It is a statutory requirement to publish a narrative explaining the gap. 
    

Notes:

(1) Where an employer’s GPG Report shows:
i.    A 5% or more gender pay gap in any category of workers
ii.    The pay gap cannot be justified by objective and gender-neutral factors, and
iii.    The pay gap has not been remedied within six months of the date of the GPG report,
then a ‘joint pay assessment’ may need to be carried out.

(2) Note: the European Commission has put forward a set of proposals aimed at (amongst other things) amending the relevant criteria with a view to easing the burden for smaller businesses (see more below). 

(3) Readers should note that, while this article focuses on reporting obligations, in addition to reporting requirements, the CSRD Regulations also introduce additional obligations, such as consultation responsibilities pursuant to which, companies will need to provide information to, and consult with, employees’ representatives at the appropriate level in relation to the sustainability information. Any opinion of the employees’ representatives in relation to the sustainability information shall be communicated to the directors of the applicable company.

(4) If implemented, the impact is expected to be significant, with the European Commission estimating that if the number of companies in scope will be reduced by about 80%, and that the combined cost savings from the proposed changes amount to €4.4 billion per year.

(5) If implemented, the first Directive will focus on the timing/deferral of reporting requirements, while the second will include a broad variety of proposed amendments to the CSRD and Corporate Sustainability Due Diligence Directive. The first directive, if adopted, is required to be transposed into national law by 31 December 2025 and Member States will then have a 12-month transposition period for the second directive.