Stay ahead of the curve with our exclusive Q&A series, brought to you by leading law firm, A&L Goodbody, LLP, designed to answer your most pressing legal questions. These expert insights provide clear guidance to ensure your HR practices remain compliant and protect your organisation.  

The gender pay gap (GPG) is the difference in the average hourly wage of men and women across a workforce. Mandatory GPG reporting is now a legal requirement for employers with 50 or more employees, with the deadline for publishing the GPG report on or before November each year.

Separately, the EU Pay Transparency Directive is due to be transposed into Irish law by June 2026. The Pay Transparency Directive will mean an increase in employee and employee representative involvement in pay equity, and it contains potentially onerous requirements to conduct equal pay assessments.  It will also provide for additional GPG reporting requirements.

In this month's Q&A, we look at some of the key questions employers may have in relation to the current GPG reporting obligations and what may apply to their organisation. 

What is GPG reporting?
GPG reporting refers to the obligation on employers to report on the gender pay differentials in their organisation, setting out pay differences between female and male employees. On 13 July 2021, the Gender Pay Gap Information Act 2021 (the Act) was signed into law. On 3 June 2022 the Employment Equality Act 1998 (section 20A) (Gender Pay Gap Information) Regulations 2022 (the Regulations) were published, creating a responsibility for employers to report on:

• The difference between the mean and median hourly pay of male and female employees expressed as a percentage of the mean hourly remuneration of relevant employees of the male gender;
• The difference between the mean and median bonus pay of male and female employees expressed as a percentage of the mean bonus pay of relevant employees of the male gender;
• The difference between the mean and median hourly pay of part-time and temporary male and female employees expressed as a percentage of the median hourly remuneration of relevant employees of the male gender on part-time or temporary contracts;
• The percentage of male and female employees who received bonuses and benefits in kind; and
• The percentage of male and female employees in each of the four quartile pay bands.
   

Who is required to report?
The Regulations, updated on 31 May 2024 and again on 31 May 2025, require employers with 50 or more staff to publish their gender pay gap (GPG). Employers must also provide a statement explaining the reasons for any differences and outlining measures taken or planned to reduce or eliminate them.

What is the deadline to report?
In 2025, the reporting deadline was changed from December to November of each year. In-scope employers must choose any date in June as their “snapshot date” and report by the corresponding date in November of the same year. This means organisations will have five months from their snapshot date to report on their GPG instead of previous six month.

Is there a government portal? 
It was announced earlier this year that a centralised portal would be launched in time for the 2025 reporting cycle. However, the portal has currently launched on a voluntary basis with partner organisations, IBEC and the 30% Club. Employers which are members of these bodies can publish their reports on the portal voluntarily. For all other in-scope employers, the findings must be published on the employer’s website in a manner that is accessible to all employees and the public. If the employer does not have a website, the findings must be available in physical form for inspection during normal business hours by employees and the public at the employer’s registered office or principal place of business.

Legislation is currently being drafted to amend the Gender Pay Gap Information Act 2021 to provide the legislative basis for employers to be required to report their gender pay gap information via the online portal in 2026.

What should employers do next?
As well as complying with GPG reporting requirements, employers will also need to prepare for the implementation of the EU Pay Transparency Directive, by examining their existing pay structures, recruitment, pay transparency and gender pay gap reporting practices and taking steps to address any issues before they are forced to.