Ireland – EU Directive transposition updates and current pay gap reporting

As member states begin to integrate the EU Pay Transparency Directive into their own national laws, we’re starting to see draft legislation that transposes various parts of the Directive. On January 15, 2025, Ireland published such draft legislation. If passed, these provisions would address some of the transparency aspects of the Directive.

This article discusses what these proposed changes would do, and it also gives a general overview of existing pay gap reporting in Ireland.

Transposition updates: Draft legislation introduced

The first provision would require a remuneration rate or range to be included in all job postings. To do this, it would amend Ireland’s existing Employment Equality Act of 1998. This requirement would actually go beyond the Directive requirements, which say that the pay rate or pay range need to either be in the job posting or be provided in advance of the interview.

The second provision would prohibit employers from asking job applicants about their current or past remuneration rates. This would also involve amending the Employment Equality Act of 1998, in this case by adding a new section.

As of February 2025, the future trajectory of this draft legislation is unclear. National elections in late 2024 changed the composition of the Irish government, and the new government is still solidifying its legislative priorities.

Additional transposition needed for pay transparency 

If the draft legislation passes, more changes to Irish law would still be needed in order to fully comply with the EU Directive. This would include:

• Employers providing information about pay ranges for categories of workers doing the same work, or work of equal value to any employee who requests it.
• Specific, gender-neutral criteria must be used to make decisions about career progression and pay levels, and this criteria must be visible to employees.
• On request, employers must also provide a pay comparison (including the employee’s pay and the average pay of comparable peers) to any employee who asks for it.
• Employee's voluntary disclosure of pay information must be protected.

The draft legislation would not address any of the pay equity or gender pay gap reporting requirements of the EU Directive, which would need to be handled separately.

Gender pay gap and reporting in Ireland

Ireland has already been taking action on gender pay gap reporting. We’ve written on these requirements in detail—please see our earlier article for more information. 

The basic reporting requirements in Ireland are:

We note that Ireland’s original reporting requirements started with organizations with 250 or more employees, but the requirements have been gradually expanding to cover smaller employers. This provides some useful groundwork for future Directive implementation, as many employers are already getting into the habit of annual reporting.

However, a few more things will change as the EU Directive is fully transposed:

• Currently, although employers are required to say what they are doing about their pay gaps, the laws will need to be more specific about what employers must do when they identify a pay gap. The Directive will set a threshold for required action (a pay gap of 5%), and it will require a written action plan with a clearly defined timeline and more accountability.
• The pay gap reporting metrics will change. Right now, Ireland requires mean and median gender pay gaps and a breakdown of gender distribution by salary quartile. But the Directive requires its measures to be broken up into job categories of workers doing the same work or work of equal value.
• Employees will be guaranteed the right to see their employers’ pay gap information.
• In the event of a pay dispute, employers bear the burden of proof. In other words, the employer must be able to show why the employee’s pay is what it is.

Further support with PayAnalytics by beqom

Pay equity analysis: If Ireland’s draft legislation passes, employers will need to set a salary range for each posted job. For many employers, this will entail an in-depth review of the pay structure. PayEquity by beqom gives organizations the insight they need to make informed pay structure changes and data-driven decisions. It also makes it straightforward and cost-efficient to measure and close any pay gaps.

Compensation assistant: If you’re working on your pay equity, the compensation assistant tool helps keep you on track. By providing ongoing support with pay and promotion decisions, it helps you make sure that a closed pay gap never reappears—so your organization can deliver on its pay equity promises.

Reporting: Pay gap reporting in Ireland will follow its existing requirements until the EU Directive is more fully transposed. We have built-in reports for Ireland, allowing you to comply with these current reporting requirements with just the click of a button.