Gender pay gap reporting: What you need to do before June ends

The EU Pay Transparency Directive came into force on the 7th of June 2026, and Ireland missed its transposition deadline.

This makes Ireland the first EU member state that has failed to convert the Directive into national law on time.

Feeling a sig of relief? Well, just because it’s been delayed, it doesn’t mean employers can breathe easy.

What the Directive requires

The EU Pay Transparency Directive isn’t just about publishing salaries.

Under the Directive:

• Employers must include salary information or a pay range in job advertisements

• They can no longer ask candidates about their salary history

• On request from an existing employee, they must provide written information on that employee’s individual pay level and the average pay levels for comparable roles and for them to be broken down by gender

The Directive also introduces mandatory gender pay gap reporting.

According to the European Commission, the gender pay gap across the EU currently stands at 11.1%. The Directive is designed to close that gap through transparency and enforcement. Employers with 250 or more employees must publish gender pay gap reports annually from reportedly June 2027, and if you’ve got over 100 employees it will be from June 2031.

If a pay gap report reveals a gender pay gap of 5% or more that cannot be objectively justified, the employer must to carry out a joint pay assessment. This will require specific data and documents, along with a credible explanation.

Why Ireland’s missed deadline doesn’t let anyone off the hook

These obligations haven’t disappeared into thin air, they’ve just been deferred.

More importantly, it’s been indicated that employees may be in a position to seek compensation for non-compliance backdated to the 7th of June 2026 deadline.

For a fuller breakdown of what Ireland’s missed deadline means in practice, see our recent post, Ireland Missed the EU Pay Transparency Directive Deadline.

What does this mean for payroll?

Much of the commentary on pay transparency focuses on salary disclosure and gender pay gap reporting at a headline level.

However, “pay” is defined expansively in the Directive. It doesn’t covers just basic salary, but bonuses, overtime, allowances, statutory payments, and pensions. That’s everything that flows through payroll, and it has to all to be broken down by gender.

What should Irish employers do right now?

There are a few things you can do. If your company advertises roles without salary information or ranges, that practice has to change sooner rather than later. Also, start reviewing your recruitment process and building internal agreements on how pay bands are communicated to candidates.

The Directive requires pay data to be reported for categories of workers performing equivalent work. That means you need a defensible, documented system for grouping roles by equivalent value.

Also, run the numbers. What does your gender pay gap look like across each job category at the moment? If you’re surprised by the answer, it’s better to be surprised now as you’ve got time to act on it now.

Finally, check your payroll system. For employers who use bonus schemes, shift allowances, variable overtime, these new requirements will require a robust payroll system, so look at what you’re currently working with, and make sure that they’re a top-runner in the field.

Remember that the equal pay principle has been there all along

The right to equal pay for equal work has actually been part of EU law since the 1950s. This new Directive is to bring in more thorough mechanisms that the principle has been lacking in.

For most employers who are paying people fairly, the Directive’s requirements are manageable. But for those who aren’t, the Directive will surface these problems, and it’s better to find that out now before regulators doe.

If you’re looking for a new payroll software, check out how BrightPay Cloud helps Irish payroll bureaus and employers stay compliant.

This content may have been developed with the assistance of AI tools. Content is reviewed by a member of the Bright team before publication. Guidance on legislation can be obtained from your industry body.