Ireland has missed the June 2026 deadline for implementing the EU Pay Transparency Directive, but recent legislative developments indicate that progress is continuing. With further legislation expected, employers should use the additional preparation time to review their pay structures, recruitment practices and existing remuneration arrangements.
The EU Pay Transparency Directive (Directive (EU) 2023/970) represents one of the most significant developments in European equal pay legislation in recent years.
Its purpose is to strengthen the principle of equal pay for equal work or work of equal value between men and women by introducing greater transparency around remuneration and strengthening employees' ability to challenge pay discrimination.
Although Ireland was required to transpose the Directive into national legislation by 7 June 2026, this deadline has passed without full implementation.
The Irish Government has confirmed that implementation will take place on a phased basis, with further legislation required to introduce the Directive's remaining provisions.
Latest Development: October 2026 Legislative Progress
October 2026 has seen an important development in Ireland's approach to pay transparency.
The Employment Equality and Institutional Burials (Amendment) Bill 2026 progressed through the Oireachtas during October, with the relevant provisions addressing gender pay gap reporting.
The Bill provides a statutory framework for requiring employers within the scope of existing gender pay gap reporting legislation to submit their information through the Government's centralised Gender Pay Gap Portal.
Currently, employers with at least 50 employees are required to prepare and publish annual gender pay gap information.
The proposed changes will strengthen the reporting framework by making submission through the central portal mandatory, subject to the legislation's enactment, commencement and implementing regulations.
Importantly, this legislation does not introduce the full range of obligations under the EU Pay Transparency Directive.
During the Seanad debate on 20 October 2026, the Minister for Children, Disability and Equality confirmed that further legislation would be brought forward to complete the Directive's transposition.
For employers, this means that although legislative progress is being made, the broader pay transparency requirements remain subject to further Irish legislation.
What Will the Pay Transparency Directive Introduce?
Once fully implemented, the Directive will introduce several important obligations affecting how employers recruit, remunerate and communicate with employees.
1. Salary Transparency During Recruitment
Employers will be required to provide job applicants with information about the starting salary or salary range for a position.
This information must be provided in sufficient time to allow informed and transparent pay negotiations, such as in the job advertisement or before the interview.
Employers will also be prohibited from asking candidates about their pay history.
This represents a significant change for organisations that currently determine starting salaries by reference to an applicant's previous remuneration.
Instead, employers will need to establish objective, gender-neutral criteria for determining salary ranges and starting pay.
2. Greater Transparency for Existing Employees
The Directive will introduce enhanced rights for employees to access information about remuneration.
Employees will be entitled to request information regarding their individual pay level and average pay levels, broken down by gender, for categories of workers performing the same work or work of equal value.
Employers will generally be required to provide this information within two months of receiving a request.
This does not mean employees will automatically be entitled to access the individual salaries of their colleagues.
Rather, employers will need to provide appropriate comparative information while protecting personal data and individual confidentiality.
The Directive also requires employers to make available the criteria used to determine pay, pay levels and pay progression. These criteria must be objective and gender-neutral, subject to the Directive's provisions concerning smaller employers.
3. Equal Work and Work of Equal Value
One of the more complex aspects of the Directive is the requirement to assess whether employees are performing equal work or work of equal value.
This extends beyond comparing employees who hold identical job titles.
Employers will need to consider the relative value of different roles using objective, gender-neutral criteria.
Relevant factors include:
Skills and qualifications.
Effort required.
Responsibility.
Working conditions.
Other relevant factors specific to the position.
For example, two employees working in different departments may perform roles of equal value despite having different job titles and responsibilities.
Employers will therefore need to ensure that their job evaluation and grading structures are capable of identifying appropriate categories of comparable workers.
The Irish Government has confirmed that a dedicated gender-neutral job evaluation toolkit is being developed to support employers with this process.
4. Gender Pay Gap Reporting and the 5% Threshold
Ireland already has gender pay gap reporting requirements under the Gender Pay Gap Information Act 2021 and associated regulations.
However, the EU Directive introduces additional obligations relating to pay differences between men and women performing the same work or work of equal value.
Of particular significance is the 5% pay gap threshold.
Under the Directive, certain employers will be required to conduct a joint pay assessment where reporting identifies a difference in average pay of at least 5% between female and male workers within a category of workers, where that difference cannot be justified by objective, gender-neutral criteria and has not been remedied within six months.
The joint pay assessment provisions apply to employers subject to the Directive's relevant reporting obligations.
It is important to distinguish this requirement from an organisation's overall gender pay gap.
A company reporting an overall gender pay gap greater than 5% will not automatically be required to undertake a joint pay assessment.
The relevant assessment concerns differences within categories of workers performing the same work or work of equal value, together with the additional statutory conditions.
When Will the New Requirements Apply?
The original deadline for transposing the Directive into national legislation was 7 June 2026.
Ireland did not meet this deadline.
The Government has acknowledged the delay and confirmed that implementation will proceed on a phased basis.
It has also indicated that employers will not be penalised simply because they had not implemented all elements of the Directive by the June 2026 deadline.
However, this does not remove existing obligations under Irish employment equality legislation or gender pay gap reporting requirements.
The precise commencement dates for the remaining pay transparency obligations have not yet been confirmed.
Employers should therefore distinguish between their existing legal responsibilities and the additional obligations expected under the Directive.
What Should Irish Employers Be Doing Now?
Although full implementation remains outstanding, employers should not wait until the legislation is enacted before beginning their preparations.
For many organisations, the most significant challenge will not be publishing salary ranges but ensuring that existing remuneration arrangements can be objectively explained and justified.
1. Review existing salary structures
Employers should examine current salary arrangements across their workforce, including basic salary, bonuses, allowances and other relevant remuneration components.
Where employees performing comparable work receive different levels of pay, employers should establish whether those differences can be supported by objective, gender-neutral factors.
2. Introduce or review job grading
Organisations without formal grading structures should consider how they will assess roles consistently.
Job titles alone are unlikely to provide a sufficiently robust basis for identifying work of equal value.
3. Review recruitment practices
Employers should consider how salary ranges are determined, communicated and applied during recruitment.
Recruitment teams and hiring managers should also prepare for restrictions on asking candidates about previous salaries.
4. Examine existing pay differentials
Historical salary negotiations, inconsistent starting salaries and discretionary remuneration decisions may create challenges where employers cannot objectively explain differences.
Conducting an internal pay review can help identify areas requiring further examination.
5. Ensure HR and payroll data is accurate
Reliable workforce information will be essential for reporting and responding to employee information requests.
Employers should consider whether their current HR and payroll systems can accurately capture the necessary remuneration and employee data.
6. Establish clear governance
Responsibility for pay decisions should be clearly defined.
Employers should consider introducing consistent approval processes for starting salaries, pay increases, promotions and exceptions to established salary bands.
Will Smaller Employers Be Affected?
A common misconception is that the Directive will only apply to larger organisations.
While certain reporting obligations are linked to employer headcount, many of the Directive's wider transparency provisions are not restricted to large employers.
For example, the requirements concerning recruitment transparency and employees' rights to pay information will have implications for smaller businesses.
The Directive also allows certain exemptions or modifications for smaller employers in specific areas.
Consequently, businesses with fewer than 50 employees should not assume that they will be outside the scope of the forthcoming legislation.
What Happens Next?
Further Irish legislation is required to give effect to the remaining provisions of the EU Pay Transparency Directive.
The Government has indicated that implementation will be phased, although the precise timetable and detailed national requirements remain to be confirmed.
In the meantime, employers should continue complying with existing gender pay gap reporting obligations and begin reviewing their internal remuneration structures.
The introduction of greater pay transparency is likely to require closer collaboration between HR, payroll, finance and senior management.
For organisations without established grading structures or consistent remuneration practices, early preparation will be particularly important.
Final Thoughts
While Ireland's delay in implementing the EU Pay Transparency Directive provides employers with additional preparation time, it should not be interpreted as a reason to postpone action.
The forthcoming legislation will place greater emphasis on transparency, objective pay decisions and the ability to demonstrate that employees performing equal work or work of equal value are remunerated fairly.
For employers, the priority should be understanding existing pay arrangements, identifying potential inconsistencies and ensuring that remuneration decisions are supported by clear, objective criteria.
The key message is simple: employers should not wait until the legislation is fully implemented to understand whether their current pay practices are ready for greater scrutiny.
How WorkWise HR Can Help
At WorkWise HR, we support Irish employers in preparing for legislative developments and ensuring their HR practices remain practical, consistent and compliant.
Whether your organisation requires assistance reviewing existing pay structures, developing HR policies or understanding the implications of forthcoming employment legislation, our team can provide practical guidance tailored to your business.