Pay Transparency Laws in Ireland – Are you Ready for June 2026?

Timing and Scope

Ireland has until the 7 June 2026 to transpose the Directive into legislation. The Spring 2025 Legislative Programme suggested that the transposition will be by way of the Pay Transparency Bill. The Heads of this Bill are currently being drafted. It is envisaged that statutory guidance will issue before the Directive is implemented, to assist employers to comply with the obligations under the Directive.

For the purposes of the Directive, “Pay” is defined expansively to include basic salary and all complementary or variable components, whether in cash or in kind, such as bonuses, overtime compensation, allowances, statutory payments and occupational pensions.

Recruitment Transparency

Employers will be required to disclose the initial salary or salary range for a role either in the job advertisement or before interview. While it may not be necessary to publish the pay range in the advertisement itself, the information must be provided to candidates.

Employers will not be permitted to ask candidates about current salary or salary history. The Directive does not prevent negotiation of fixed or variable pay outside the stated range.

Employee Rights to Pay Setting Information

Employees will have a right to receive information on their individual pay level.

Employees will also have the right to receive information regarding the average pay levels for categories of workers performing the same work or work of equal value, broken down by gender.

The employee pay information rights will apply to all employees. At present, no minimum headcount threshold has been provided for. That may change when the draft legislation is published.

Employers will need to identify correct “categories of workers” (i.e., those who are performing the same work (or work of equal value)). Categories of workers is defined in the Directive to mean:

“workers performing the same work or work of equal value grouped in a non-arbitrary manner based on the non-discriminatory and objective gender-neutral criteria referred to in Article 4(4), by the workers’ employer and, where applicable, in cooperation with the workers’ representatives in accordance with national law and/or practice.”

Article 4(4) of the Directive defines the gender neutral criteria which will identify work of equal value. They include criteria such as skills, effort, responsibility, working conditions and if appropriate any other factors relevant to the specific job or position. Employers must be able to explain what each category of worker is paid and why pay is set at that level.

Employees having the right to receive this information through employee representatives or through an equality body so we may see the role of employee representatives increase even in small businesses and outside of the traditional redundancy/TUPE context. Guidance and the draft legislation should clarify in due course what this means in practice.

What can employers do now to prepare?

The key action points for employers now are:

• evaluate and monitor pay structures – compensation decisions (fixed and variable) in the coming months will form the basis of responses to information requests in 2026;
• start to identify categories of workers, paying particular attention to individual contributor roles – what category do they belong to?;
• where a GPG is identified, employers need to understand why it exists and ensure that any pay differentials revealed are justified on the basis of objective, gender neutral criteria.

High performing employees can be rewarded. Employees who do the same work can still be paid differently. There is no question about that – however the explanation for any such differential may soon have to be revealed and it should be explained by reference to gender neutral criteria.

Pay Progression Information

Employees will have a right to receive information on the criteria for pay progression, including how employees can progress to higher pay levels.

Again, pay progression information should be complied by reference to objective and gender-neutral factors.

How long do employers have to respond to these information requests?

A response must be provided within a “reasonable period” and, in any event, within two months of a request.

Prohibition on Pay Secrecy

Employers will not be able to prevent employees from discussing or disclosing their pay for the purposes of enforcing equal pay rights.

Employers may, however, restrict the use of such information for other purposes, such as disclosure to competitors.

It is not yet clear how these competing rights can be balanced. The draft legislation may cast light on this.

Enhanced Gender Pay Gap Reporting

GPG reporting now applies to employers with more than 50 employees.

The Directive provides for enhanced GPG reporting including reporting on the GPG among “categories of workers”. The enhanced reporting obligations will take place on a staggered basis from 2027 to 2031. The accuracy of the GPG information must be confirmed by management following consultation with worker representatives, who must also have access to the methodologies used. Employees can request clarifications regarding the data use, the methodology and the explanations provided for the GPG.

Joint Pay Assessments

Where a report shows a gender pay gap of 5% or more in any category of workers that cannot be justified by objective, gender-neutral factors and is not remedied within six months, a joint pay assessment must be conducted with employee representatives.

Statutory Guidance and Regulations will, in due course, elaborate on how this will work in practice. It is expected that the joint pay assessment will be carried out with employee representatives. The outcome will be shared with all employees. Where no representatives exist, the Directive contemplates employees appointing representatives to participate in the process.

The joint pay assessment can include the proportion of female and male employees who received pay increases upon returning from maternity, paternity, parental, or carers’ leave, where such increases occurred for their worker category during the leave period.

Remedies and Enforcement

The Directive envisages robust options in terms of redress including recovery of back pay (covering variable remuneration such as bonuses) and compensation for non-material damage such as lost promotion opportunities.

There is provision for strong anti-penalisation protection in the Directive which will be extended under Irish legislation to workers asserting their rights under the Pay Transparency legislation or those supporting such claims, such as witnesses.

Again, there is reference to a right to representation where an employee is asserting their rights or perhaps raising a grievance in relation to their pay information rights and this seems to go beyond the traditional, right to be represented by a trade union or colleague in those processes.

It also must be noted that there is a reference to collective redress mechanisms in the form of “class action” remedies being available in Member States. We do not currently have that so this may or may not be a feature going forward.

Next Steps

We strongly recommend employers to begin preparing for the Directive’s implementation by auditing current pay practices, identifying potential gender pay gaps and updating performance management and remuneration policies. Employers should:

• Ensure pay (salary, bonus, benefits, etc.) is structured at each individual job level and in each category by reference to documented gender neutral criteria;
• Build a coherent pay progression narrative by reference to clear and objective skills/criteria to next pay progression level;
• Start constructing non-arbitrary “categories of workers” who perform the same work or work of equal value. This will set the foundation for pay transparency information rights and GPG reporting for 2026 and into the future;
• Build a coherent performance management structure which is consistently applied to ensure that progression is based on merit and achievement and evidence based factors; and
• Remember that information from compensation awards that employers implement in 2025 for 2026 will form the basis of the first information requests.

Further Information

For further information, please reach out to your usual Maples Group contact or any of the persons listed on this page.