Changes to Gender Pay Gap Reporting 

Gender pay gap reporting legislation was enacted in 2021 and requires organisations to report on their gender pay gap – ie the difference between the average wages of men and women – across a range of metrics.  This initially applied to employers with 250 or more employees, a threshold that is gradually being reduced. 

Employers are now required to report on:

• the mean and median hourly remuneration gap between men and women
  
  
• the mean and median bonus remuneration gap between men and women;
  
  
• the mean and median remuneration gap between part-time employees;
  
  
• the mean and median remuneration gap between temporary contract employees;
  
  
• the percentage of male and female employees who receive a paid bonus and benefits in kind;
  
  
• the percentage of male and female employees in each quartile when divided into four quartiles from lowest to highest pay.
  

The key changes employers need to be aware of in their reporting obligations for this year are:

1. From 1 June 2025, employers with 50 or more employees will be required to publish a gender pay gap report. This has reduced from 150 employees or more in 2024. This change will mean significantly more employers are required to report on their gender pay gap this year and moving forward. 
   
   
2. The reporting deadline is being brought forward to November, rather than December as in previous years.  The date in November will depend on the ‘snapshot date’ which an employer chooses in June.  Employers must pick any date in June as their snapshot date for collecting the relevant data and report by the corresponding date in November – for example if 1 June is an employer’s snapshot date, the report will be due on 1 November. 
    
   
3. Employers will be required to upload their report to an online portal rather than produce the report on their website or in another way that is accessible to all its employees and to the public.  The portal aims to focus employers’ minds on addressing pay transparency given that it will be readily accessible to all when it goes live, which is currently anticipated to be in the autumn of this year.

Amending regulations are required for these changes to be formally brought into force, which are expected prior to the portal going live, however, it is important that employers act on the basis that this is how gender pay gap reporting will operate moving forward. 

Take-Aways for Employers 

Planning – employers will have one month less to prepare their report compared with previous years.  Organisations will need to ensure that it has enough time to compile the information for the report given the shorter timeframe and should undertake an audit of all payroll data that they currently hold and ensure that it is up-to-date and accurate.  Employers should also review its payroll structure and internal policies in advance of reporting on the gender pay gap.  

Reasons for any Gender Pay Gap – organisations need to provide reasons for any gender pay gap and outline steps which will be taken to remedy any such gap moving forward.  Therefore, organisations will need to consider why any pay gaps exist and take steps to remedy the gap in the future.  It is important for employers to remember that simply having a gender pay gap does not necessarily mean that there is any discrimination within an organisation, but it will be important to explain the reasons clearly to ensure that this is clear to anyone reading the report. 

Uploading to the Portal – while employers have always been required to upload their gender pay gap report to their own website or somewhere it can be viewed by the public, the introduction of this portal will facilitate comparing and contrasting reports between employers in various sectors and industries.  This will not only be important to employees within an organisation – who employers should ideally engage with to ensure transparency on any pay gaps – but also to potential candidates applying for a role within an organisation.  On that basis, it will be essential that employers clearly explain any existing gender pay gaps so as not to dissuade a future candidate from applying for a role.  The online portal also gives employers the opportunity to strengthen their employer brand by showing that it is dealing with gender pay gaps head on. 

The changes to gender pay gap reporting are part of a wider trend in Ireland and the EU towards pay transparency, and employers should keep up to date with the developments in this area as the year progresses.

Byrne Wallace Shields LLP

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Tel: +353 1 637 1567
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