Gender Pay Gap Reporting in 2025

Gender Pay Gap Reporting in 2025: What’s New for Irish Employers?

From 2025, gender pay gap (GPG) reporting in Ireland enters a new phase with enhanced regulatory requirements, broader employer coverage, and a centralised reporting system set to reshape how pay transparency is managed. For many employers – particularly small and medium-sized enterprises (SMEs) coming into scope for the first time – understanding these changes is critical for legal compliance and effective preparation. This article outlines the key developments for 2025, their implications for employers, and the practical steps necessary to ensure compliance.

The Gender Pay Gap vs Equal Pay

Before examining the 2025 updates, it’s important to clarify the distinction between the GPG and equal pay. The GPG measures the disparity in average hourly earnings between men and women across an entire organisation; it does not mean that men and women are being paid unequally for the same job.

In contrast, Ireland’s equal pay laws – notably the Employment Equality Acts 1998–2015 – specifically prohibit paying employees differently for like work (work that is the same or of equal value). In short, a company can have a GPG without violating equal pay laws, if for example more men occupy higher-paid roles. GPG reporting is about transparency in aggregate pay differences, whereas equal pay legislation deals with unlawful pay discrimination for the same work.

Expanded Employer Coverage in 2025

One of the most significant changes in 2025 is the expansion of which employers must report their GPG. Since June 2025, the employee threshold for mandatory GPG reporting dropped to 50 employees, down from previous thresholds of 250 employees (when reporting was first introduced in 2022) and 150 employees (in 2024). This means that many mid-sized companies and larger SMEs in Ireland will be subject to GPG reporting for the first time. The Department of Children, Equality, Disability, Integration and Youth estimates that lowering the threshold to 50 employees will bring roughly 6,000 organisations into scope, covering a majority of the Irish workforce. Employers with fewer than 50 employees remain exempt, but those at or above the 50 mark must now prepare to comply.

For newly in-scope employers, this expansion underscores the need to put robust payroll analytics and reporting processes in place. Smaller organisations often have limited HR infrastructure, so early planning is essential to meet the requirements and timelines discussed below.

Revised Reporting Timeline

Along with broader coverage, the reporting timeline has been tightened for 2025. Employers are required to choose a “snapshot date” in June 2025 to capture pay data for their workforce. The GPG calculations will be based on the 12-month period leading up to that snapshot date. Notably, the deadline to publish the GPG report has been moved up – reports must be published within five months of the snapshot date, by the end of November 2025, which is one month earlier than the previous December deadline.

This shorter timeframe means organisations will need to work quickly after the June snapshot to calculate their pay gap metrics, draft the required report (including narratives, as discussed below), and complete internal reviews. The change to a November deadline emphasizes the importance of earlier preparation. Employers should aim to have their data collection and analysis substantially completed over the summer so that any issues can be addressed well before the November cutoff. For companies unfamiliar with the process, starting early in 2025 is crucial to avoid last-minute compliance risks.

New Centralised Reporting Portal

A major development for 2025 is the introduction of a centralised online reporting portal for GPG data. On 8 March 2025, the government (Minister for Children, Equality, Disability, and Integration) announced that an official GPG reporting portal will launch in Autumn 2025. All employers in scope will be required to upload their GPG reports to this portal, which will serve as a public, searchable database of GPG information across all reporting organisations.

Previously, Irish employers satisfied the law by publishing their GPG report on their own website (or making it available at their premises). While companies may still choose to publish the report on their site, the government portal submission will be mandatory once it goes live. This central repository is designed to enhance transparency and comparability: anyone (employees, job seekers, the media, researchers, etc.) will be able to search the portal and compare pay gap data across companies and sectors. It also streamlines administration by consolidating reporting in one place.

For employers, the new portal means an additional step – registering and uploading the report – but also potentially less ambiguity about where and how to publish the data. It will be important for companies to follow any guidance on the portal’s format requirements. The increased visibility also raises the stakes on accuracy and narrative clarity, as reports will be more readily scrutinized side by side.

Summary of Reporting Obligations

Under the Irish regulations, each in-scope employer must calculate and report a set of key metrics on gender-based pay differences within their organisation. The required GPG metrics include:

• Mean and median hourly pay gap between male and female employees (the percentage difference in average pay for all men versus all women).
• Mean and median bonus pay gap between male and female employees.
• The proportion of male and female employees receiving bonus pay.
• The proportion of male and female employees receiving benefits in kind (non-cash benefits, e.g. company cars, health insurance).
• The percentage of male and female employees in each pay quartile of the organisation’s pay distribution (i.e. dividing the workforce into four equal parts from lowest paid to highest paid and reporting the gender split in each quartile).

These figures provide a multi-faceted view of where pay disparities exist – for example, differences in bonuses or the concentration of genders in lower vs. upper pay bands.

In addition to the numeric disclosures, a narrative statement must accompany the data. Employers are expected to provide an explanation for the causes of any GPGs that exist, and (importantly) to outline the measures being taken or planned to address those gaps. This narrative gives vital context to the raw numbers. For instance, an employer might explain that a gap is due to more men in senior roles, and then describe a mentorship or recruitment program to support women’s advancement. The narrative is an opportunity for employers to demonstrate awareness and proactive effort, which can influence how their report is perceived by both the public and their own employees.

Next Steps for Employers

For employers – especially those reporting for the first time in 2025 – there are several practical steps that should be taken now to ensure smooth compliance:

• Audit your data: Begin by auditing payroll and HR records to ensure all relevant pay data (including base pay, bonuses, benefits, overtime, etc.) is accurate and complete ahead of the snapshot dates. Identifying any data quality issues or anomalies early will save time later. Make sure you have a clear headcount of all employees (full-time, part-time, temporary) as of the snapshot date, since the threshold and calculations include various types of workers.
• Perform a trial GPG calculation: It’s advisable to run internal GPG calculations before the official snapshot, using recent data. This practice run can highlight any significant gaps or technical questions about the calculations. If large gaps appear, management should be made aware and discussions can start on explanations and action plans.
• Prepare the narrative and action plan: Start drafting the narrative report that will accompany your numbers. This should explain any identified pay gaps and, crucially, describe measures to address them. Consider involving your HR, legal, and diversity & inclusion teams in crafting this statement – it should be truthful but also demonstrate commitment to improvement. If needed, seek legal input to ensure the narrative is appropriately worded (especially if it touches on sensitive matters).
• Get acquainted with the reporting portal: Keep an eye out for the launch of the government’s reporting portal in Autumn 2025. There may be user guides or training provided. It would be wise to register an account early and familiarise yourself with how to upload information.
• Meet the deadline and publish: Plan backwards from the November 2025 deadline to leave time for internal review and sign-off. By late October, you should aim to have the final metrics and narrative ready for executive approval. Remember that you will need to submit the report via the online portal (and optionally on your own website) by the end of November.
• Communicate internally: Once the report is published, be transparent with your employees about the results. Consider having an internal briefing or communication from leadership about what the numbers show and what steps the company is taking.

By tackling these steps early, employers will not only ensure compliance but also derive more value from the process – using it as a chance to diagnose and address underlying issues in pay and representation.

EU Pay Transparency Directive – Overlap and Future Impact

Looking beyond 2025, employers should be aware of incoming EU-wide rules that will significantly influence pay transparency and equal pay obligations. The European Union’s Pay Transparency Directive (Directive (EU) 2023/970) was adopted in 2023, and Ireland (like all member states) must transpose it into national law by 7 June 2026. While this directive shares the goal of promoting gender pay equity, it introduces additional requirements that go beyond the current Irish GPG reporting regime:

• Granular pay gap reporting: The directive will require employers to report on gender pay differences in much more detail – specifically, to break down pay gap data by categories of workers (such as by job level or role) and by pay type (basic vs. variable pay). This is a more complex task than Ireland’s current high-level average metrics, as it demands a finer analysis of internal pay structures.
• Action on significant gaps: Under the EU rules, reporting is not just a transparency exercise; it can trigger corrective action. If an employer finds an unexplained gender pay gap of 5% or more between male and female workers within the same category of work, and this gap persists for six months without objective justification, the employer must conduct a “joint pay assessment” with worker representatives. The purpose of this assessment is to analyse the gap in detail, identify the causes, and implement measures to close it. Moreover, the employer will be obliged to remedy the pay difference within a reasonable period. This mechanism means that large, unjustified pay gaps will no longer be a matter of simply reporting and explaining – they will demand concrete action plans and collaboration with employees to fix the issue.
• Broader transparency rights for individuals: The Pay Transparency Directive also grants new rights to employees and job applicants, which will affect employers of all sizes (not just those with 50+ employees). For example, pay transparency for job-seekers will require employers to disclose the initial pay level or salary range in job vacancy notices or before interviews. Employers will also be banned from asking candidates about their past salary history, a practice that can perpetuate pay inequality. Furthermore,  employees will have a right to request information about their own pay and the average pay levels of colleagues of the other gender doing the same work or work of equal value. Employers must provide this information within a set timeframe (e.g. within two months of request), which arms employees with data to assess whether they are being fairly paid. In addition, the directive will prohibit contractual clauses that prevent staff from discussing or disclosing their pay for the purpose of enforcing equal pay rights.
• Enforcement and compliance changes: The introduction of the directive is expected to bring more stringent enforcement of pay equality. Notably, Ireland’s adoption of these rules will likely involve introducing penalties for non-compliance – something that the current Irish GPG reporting law lacks. In fact, it is anticipated that when Ireland transposes the directive (sometimes informally referred to as the Pay Transparency Act in local discussions), it will come with financial or statutory penalties for failing to meet the new requirements.

In summary, the EU Pay Transparency Directive will complement Ireland’s GPG reporting framework but also raise the bar. It overlaps with GPG reporting in seeking to illuminate and reduce gender-based pay disparities, but diverges by mandating direct equal-pay remedies and extending transparency to all aspects of the employment cycle (hiring, promotions, etc.). From a compliance and operational standpoint, Irish employers should start preparing now. Reviewing compensation structures, updating recruitment practices (e.g. readying pay range disclosures for job ads and removing salary history questions), and setting up robust systems for handling pay data requests will put organisations in a strong position when the new rules arrive.

Conclusion

With expanded reporting thresholds, a tighter timeline, and a central reporting portal, GPG reporting in 2025 represents a significant shift in pay transparency standards for Irish employers. Those coming into scope for the first time should view this not just as a compliance exercise but as an opportunity to understand their workforce dynamics and demonstrate commitment to equality. Early and thorough preparation is vital – not only to meet the legal requirements, but also to reinforce a positive employer brand in an era of increasing transparency.

As future EU measures on pay transparency loom, staying proactive on GPG analysis will put employers ahead of the curve. By embracing these changes and actively addressing any gaps, organisations can improve trust among employees and position themselves as fair, inclusive workplaces.

This article was drafted by Stephen Barry (Trainee).