GENDER pay gap (GPG) reporting in Ireland has moved firmly from policy discussion to legal reality. With the reporting threshold reduced to employers with 50 or more employees, many organisations are now within scope for the first time.
For some, GPG figure publication has prompted uncomfortable but necessary questions about senior representation, promotion pathways, and the long-term impact of part-time working patterns.
It is crucial to understand what GPG reporting measures, and what it does not.
At its core, gender pay gap reporting is not about proving discrimination. Rather, it is about pay transparency.
The GPG reflects the difference between the average hourly earnings of men and women across an organisation as a whole. It does not determine whether men and women are paid equally for the same role. Unequal pay for equal work is already unlawful. GPG reporting is about workforce wide transparency.
Why transparency matters
The principle is simple: what gets measured gets examined. Publishing pay gap data exposes structural patterns that might otherwise remain hidden; for example, under representation of women at senior levels or concentration in lower paid roles.
For employers, transparent reporting strengthens governance and reputation. For employees, it provides clarity around how pay and progression operate in practice.
The snapshot
Each year, employers must select a ‘snapshot date’ in June for their reporting. Anyone employed on that date is included in the headcount, regardless of whether they are physically at work. This includes full-time, part-time, and fixed-term employees, along with those on maternity, paternity, parental, adoptive or sick leave.
Only those directly employed and paid by the organisation are counted. Agency workers paid by an agency and independent contractors operating on a business-to-business basis are excluded, unless they are on a contract of employment.
Employers calculate pay metrics using data from the previous 12 months. Even if staffing numbers subsequently fall below 50, the reporting obligation remains. Reports must be published within five months (usually November), placed on the employer’s website and, from 2025, uploaded to a central Government portal. They must remain accessible for three years.
Employers must publish: mean and median hourly pay gaps; mean and median bonus gaps; proportion of men and women receiving bonuses and benefits in kind; gender distribution across four pay quartiles; separate figures for part-time and temporary employees
A written explanatory statement outlining the reasons for any gap and the measures being taken is mandatory. In practice, this narrative attracts the greatest scrutiny.
Key points to consider when preparing
Many reputational difficulties arise not from the figures themselves, but from lack of preparation. Treating GPG reporting as a payroll calculation alone, failing to analyse workforce structure, or publishing without clear internal communication can undermine trust in the employer.
Practical steps to prepare for reporting include:
- Conducting an early data review well in advance of the snapshot date
- Stress-testing payroll and bonus data for accuracy and consistency
- Understanding the workforce profile and promotion pipelines
- Aligning the narrative with existing diversity, talent and workforce strategies
- Planning internal communications before external publication
Also, employees should receive context and explanation internally before figures appear online. Where organisations fail to manage this step, trust can be undermined quickly if employees learn of the results through media coverage or a Government website.
What if your organisation has a gender pay gap?
Having a gender pay gap is not unlawful. Many organisations, particularly in historically male dominated sectors, will report one. What matters is how leadership responds. Employers are expected to analyse the underlying causes and outline credible, measurable actions. These may include leadership development, flexible working supports, recruitment practices, succession planning, or reviewing progression pathways. Closing the gender pay gap is a long term project, not a quick fix.
There are currently no automatic financial penalties for non-compliance, but employees may bring concerns to the Workplace Relations Commission, and enforcement action can follow. Further obligations are expected as Ireland prepares to implement the EU Pay Transparency Directive
Ultimately, GPG reporting is more than a compliance exercise. It is a leadership test. Organisations that approach it strategically rather than defensively will be better positioned to build trust, strengthen governance, and demonstrate genuine accountability in practice.
Looking ahead
Gender pay gap reporting is not simply a compliance exercise; it is a governance, cultural, and leadership issue. Done well, it provides organisations with meaningful insight into how pay, work and progression operate in practice. It can be a powerful diagnostic tool for employers, and it can act as a catalyst for trust, accountability and sustainable change.
by Pat Rockett
Workplace Matters is written by human resource management and employment law experts HR Hub, based on O’Connell Street in Limerick.