ALERT / OCTOBER 14, 2025
Ireland updates gender pay gap reporting regulations
Ireland has introduced regulations to expand existing gender pay gap reporting obligations from employers with at least 150 employees to employers with at least 50 employees, as part of a planned phased expansion.
The annual reporting deadline has also been shifted from December to November. These changes will apply to gender pay gap reports due in November 2025.
Additionally, Ireland has proposed draft legislation to transpose certain pre-employment pay transparency provisions of the European Union Pay Transparency Directive.
Background
Ireland's journey towards pay transparency began with the Gender Pay Gap Information Act 2021 and the Employment Equality Act 1998 (Gender Pay Gap Information) Regulations 2022 (the “2022 Regulations”), which introduced annual gender pay gap reporting obligations for certain employers starting in 2022 (see Lockton article here (opens a new window)).
The Employment Equality Act 1998 (Gender Pay Gap Information) (Amendment) Regulations 2025 (the “2025 Amendment Regulations”), which took effect from 31 May 2025, expands the employee threshold for reporting obligations under the 2022 Regulations, lowering it from 150 to 50 employees.
While Ireland had already implemented gender pay gap reporting obligations in 2022, the European Union Pay Transparency Directive (Directive (EU) 2023/970, the “EU Directive”) later entered into force on 6 June 2023 and requires each EU member state to transpose its provisions into their national law by 7 June 2026. The EU Directive sets minimum standards to strengthen pay transparency, promote equal pay for equal work, and impose gender pay gap reporting obligations on employers. While Member States must meet these minimum standards, they are also free to go beyond them, meaning national approaches to pay transparency may vary across the EU. (See Lockton article here (opens a new window) for more details on the EU Directive and creating a roadmap for compliance.)
On 15 January 2025, Ireland published the General Scheme of the Equality (Miscellaneous Provisions) Bill (the “Bill”). The Bill proposes the partial transposition of the EU Directive through two provisions on pre-employment pay transparency: requiring employers to disclose salary ranges in job advertisements and prohibiting employers from asking job applicants about their pay history. As the Bill is still undergoing the legislative process, it is subject to amendment and further debate.
Since the Bill only addresses pre-employment pay transparency requirements under the EU Directive, further legislative measures, particularly to adjust existing pay gap reporting obligations and introduce the right to pay information for employees, will be required for Ireland to fully transpose the EU Directive by the June 2026 deadline.
This article sets out key details on the changes to gender pay gap reporting obligations that have taken effect in 2025 under the 2025 Amendment Regulations, as well as the proposed new pre-employment pay transparency obligations under the Bill.
Key details
Changes to Gender Pay Gap Reporting Obligations in 2025
Changes in employee thresholds
Since the implementation of the Gender Pay Gap Information Act 2021, the reporting obligation has been introduced in phases, through successive regulations:
2022 Regulations (effective 31 May 2022): applied to employers with 250 or more employees
Employment Equality Act 1998 (Gender Pay Gap Information) (Amendment) Regulations 2024 (effective 31 May 2024): applied to employers with 150 or more employees
2025 Amendment Regulations (effective 31 May 2025): currently applies to employers with 50 or more employees
Employers with fewer than 50 employees remain exempt from pay gap reporting obligations.
Change in annual reporting due date
Under the 2022 Regulations, the annual gender pay gap report for a given year was due six months after a snapshot date in June (i.e., in December). The snapshot date refers to a date which employers are required to choose to base their annual gender pay gap calculations on. The snapshot date must be in June but may be any date in June.
However, from 31 May 2025, the 2025 Amendment Regulations have amended the 2022 Regulations such that reports for a given year are now due five months after the snapshot date in June (i.e., in November). As such, employers now have a shorter time frame to prepare their annual reports.
Launch of centralized gender pay reporting portal
Currently, employers are required to publish their gender pay gap reports on their own publicly accessible websites or in another way that is accessible to all their employees and the public.
However, in March 2025, the Irish government announced the upcoming launch of a new gender pay reporting portal, which is expected to go live in fall 2025. The portal will host a publicly accessible centralized database of employers’ gender pay gap reports.
Forthcoming regulations, expected to be issued soon, will mandate that all employers update their procedures for submitting annual reports via the new portal, effective November 2025.
Proposed New Pre-Employment Pay Transparency Obligations
Disclosure of salary ranges in job advertisements
The Bill proposes a new requirement for employers to include the salary or salary range in all job advertisements. This is more restrictive than the minimum standard set under the EU Directive, which provides employers the flexibility to choose between disclosing the salary or salary range either in the job advertisement or prior to the interview.
Prohibition on pay history inquiries
The Bill also proposes a new prohibition on employers from requesting information from job applicants about their current or former pay. This is in line with the minimum standard under the EU Directive.
Employer action: ACT
Employers with 50 to 149 employees in June 2025 will be required to publish their first gender pay gap report by November 2025. Employers with at least 150 employees should also ensure that they publish their reports by the new due date.
Employers should be aware that the link to the new gender pay reporting portal is expected to be accessible on the government’s website here (opens a new window) and that from November 2025 all employers with at least 50 employees must publish their gender pay gap report through the new portal.
As the Bill is still undergoing consideration and has yet to be passed, employers should monitor the legislative process.
If there are any material updates on the Bill or additional legislative proposals to further transpose the EU Directive, the Lockton Global People Solutions Compliance Practice will publish an update accordingly.
Further Information
General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 | gov.ie (opens a new window)
