How Ireland’s gender pay gap reporting is changing in 2025

Following in the footsteps of our fellow European Union (EU) members and the UK, in 2022 Ireland introduced new gender pay gap reporting legislation.

The Gender Pay Gap Information Act 2021 is a framework designed to illustrate how women and men are paid and represented across Ireland’s workforce.

In 2022, the gender pay gap in Ireland was 9.6%, meaning that the average man earned 9.6% more than the average woman.

The article is aimed at HR and payroll teams and employers at small and medium businesses to help them prepare for gender pay gap reporting changes coming from June 2025.

Here’s what we cover:

What is gender pay gap reporting and what is its purpose?

We hear a lot about the gender pay gap. But what is it?

The gender pay gap refers to the difference between average earnings by women and men across the workforce.

It’s based on gross hourly earnings and is not the same as equal pay for equal work.

Mary Cullen, managing director of Insight HR, one of Ireland’s leading HR consultancies, explains that the gender pay gap refers to “the difference in the average hourly wage between men and women across an entire workforce, rather than an indication of illegal discrimination or unequal pay for the same work”.

She adds, “It’s an assessment of gender representation and workforce participation.”

The purpose of the gender pay gap reporting legislation is to identify and measure gender-based pay disparities within organisations, with the aim of implementing measures to reduce or eliminate any gaps.

Mary says, “Gender pay gap reporting shines a light on pay disparities in the workplace, helping organisations understand where gaps exist and why.

“It’s not just about compliance. It’s about transparency, accountability, and making meaningful progress toward workplace equality.”

How gender pay gap reporting currently works

You need to calculate the data for your employees using a “snapshot date”, which is in effect, an end date for the previous 12 months.

The data must include the differences between the:

• Mean hourly pay and the median hourly pay of male and female employees
• Mean bonus pay and median bonus pay of male and female employees
• Mean part-time pay and median pay of part-time male and female employees
• Mean pay and median pay of male and female employees on temporary contracts.

You should include the percentage of employees who received bonuses and benefits-in-kind compensation such as a company car.

Additionally, male and female employees must be placed in four specified pay bands:

• Lower
• Lower-middle
• Upper-middle
• Upper range.

In addition to the data, you must include a report which explains, in your opinion, the reasons why a gender pay gap exists within your company.

If you identify a gap, you should outline the actions you intend to take to reduce or close the gap.

These measures should be specific and measurable and could include a review of your company’s recruitment processes, bonus schemes, promotion practices and flexible working arrangements.

Mary says, “The reporting process forces businesses to take a hard look at their data, identify underlying issues, and start conversations that lead to real change.”

“Pay gaps don’t always stem from direct pay discrimination; they often highlight broader issues, like barriers to career progression, unequal access to leadership roles, or unconscious bias in hiring and promotions.”

What’s changing with gender pay gap reporting

Ireland’s gender pay gap reporting is in its third year. In 2025, it’s expanding to include companies with 50 or more employees.

The reporting deadline shifts to November, requiring organisations to report within five months of their June ‘snapshot’ date.

What is the threshold for gender pay gap reporting?

The first threshold for gender pay gap reporting was for companies with more than 250 employees.

Currently, the threshold is for organisations with 150 or more employees.

This is set to change in June 2025 when businesses with 50 or more employees will be required to report their gender pay gap.

The government’s guidance on calculating the number of employees for the purposes of reporting is to “carry out a headcount” of all employees on the snapshot date including workers who are not rostered, those on leave, as well as temporary and part-time employees.

What are the reporting timelines, deadlines and the snapshot date?

Employers are required to choose a snapshot date in June each year and to base their reporting on the hourly pay rates of employees they have on that date.

The reporting period is 12 months prior to the chosen date.

So, for example, if you choose 20 June 2025 as the snapshot date, the reporting period will be 21 June 2024 to 20 June 2025.

Previously, publication of the report was to be no later than six months following the snapshot date: 20 December.

However, in 2025, employers will be required to publish their report in November.

What happens if businesses fail to comply?

While currently there are no financial penalties in place for non-compliance, organisations that fail to comply with the gender pay gap regulations can face legal consequences.

An employee can submit a claim against their employer with the Workplace Relations Commission (WRC) for failure to comply with the reporting requirements.

And the WRC can order an employer to take action to comply with the Act.

Decisions made by the court will be published with the result that companies that fail to fulfil their gender pay gap reporting obligations could suffer reputational damage.

Additionally, the Irish Human Rights and Equality Commission can submit an application to the Circuit Court or High Court for an enforcement order.

However, it’s expected that penalties for non-compliance will be introduced when Ireland adopts the EU Pay Transparency Act which is set to be enacted by June 2026.

What is the gender pay gap reporting portal?

According to guidance on the government’s website, the gender pay gap information must be published on the employer’s website or “in some other way that is accessible to all its employees and to the public”.

The gender pay gap legislation provides for a publicly accessible portal to assist an estimated 6,000 public and private organisations required to report their gender pay data.

The online portal will be searchable and will gather reports from all sectors in one place.

On 8 March 2025, Minister for Children, Disability and Equality Norma Foley announced that the new portal will be launched in autumn 2025.

What HR and payroll teams and employers need to do now

The job of compiling the data will likely fall to your HR and/or payroll team. However, other stakeholders should give their input into the report, including PR and communications teams, and senior management.

Their contributions will help to look at the overall picture and devise an effective strategy to close the gap.

So how should organisations with 50 or more employees prepare for the changes?

If you haven’t already begun to collate the data, you should start now. You can use your payroll software and your HR software to do this.

Mary advises you to not leave the gender pay gap reporting until the last minute.

She says, “Organisations need to approach this strategically, looking beyond the numbers to understand the ‘why’ behind any gaps.

“HR and payroll teams should work closely together to ensure accuracy in reporting and start gathering the required data well in advance.”

Aside from the figures, the regulations require a report.

Mary recommends that businesses have a clear narrative around their results.

She says, “If there’s a gap, be prepared to explain the factors contributing to it and, more importantly, what actions you’re taking to address it.

“This is where HR plays a key role, whether it’s reviewing promotion pathways, implementing structured pay reviews, or addressing gender balance in leadership pipelines.”

Communication is key.

Mary adds, “Reporting a gender pay gap isn’t necessarily a bad thing; ignoring it is. Engaging with staff, sharing action plans, and demonstrating a commitment to long-term improvement will make all the difference.”

Final thoughts on gender pay gap reporting

Now is a good time to give gender pay equity your full attention.

Mary says: “A reminder that the EU Directive on Pay Transparency is just around the corner and will bring increased focus on gender equality in the coming years.”

When the EU legislation is implemented, further changes to Ireland’s gender pay gap regulations will be required.

If your team prioritises its gender pay gap reporting obligations in 2025, your business will be well-prepared when further changes to pay transparency regulations come into effect in the coming years.