Gender Pay Gap Reporting

Posted in : Supplementary Articles ROI on 17 June 2024
Caroline Reidy
The HR Suite
Issues covered: Gender Pay Gap; Reporting; What needs disclosed?; 5 Steps; Action planning; Compliance

The Gender Pay Gap is the difference between the average hourly wage between men and women in the workforce.

In 2022, Ireland had a gender pay gap of 9.6% i.e. the average male earned 9.6% more than the average female.

Equal pay is a different but connected issue which is about the prohibition of pay differences between men and women for “like work,” “work of equal value” or “work rated as equivalent.”  Such differences are not permitted under Irish law and this requirement is something that Irish employers already have to address.

However, even if an employer does not have an equal pay issue, a gender pay gap may still exist, for example if the majority of lower paid roles are filled by women.

Gender Pay in Ireland is a crucial step towards addressing pay inequality between men and women.


The Gender Pay Gap Information Act 2021 was signed into law on 13th July 2021.The Act amends the Employment Equality Acts 1998 to 2015 in the form of the Employment Equality Act 1998 (Section 20A) (Gender Pay Gap Information) Regulations 2022 (the “Regulations”).

Reporting Requirements

Organisations with 150 or more employees are asked to report on their gender pay gap. The Act widens the scope to employers with 50 or more employees in 2025.

Organisations are asked to select a ‘snapshot’ date in the month of June. Their reporting will be based on the employees they have on this date.

Organisations then have six months to prepare their calculations before reporting six months later, by the end of December.

It is intended that from 2025 the reporting date will change to 5 months from the snapshot date in June. This means that mandated organisations will report on their Gender Pay Gap in November 2025.

What needs to be disclosed?

The legislation requires employers to disclose statistics on pay differences between male and female employees across a range of elements, including hourly pay and bonus. Data must also be reported on differences between male and female employees across a range of working arrangements, including part-time employees and those on temporary contracts.

Disclosure will also be required on

  • The proportion of male and female employees who receive benefits in kind and bonuses.
  • The number of male and female employees across four pay bands.
  • There may also be a requirement to publish differences in pay by reference to job classification.

Where is it reported?

The gender pay gap information must be published on the employer’s website or in some other way that is accessible to all its employees and to the public. Employers are required to ensure that their gender pay gap report remains available and accessible for not less than three years from the date of publication or on which they were made available.

An online portal for reporting is under development currently. 

What are the 5 steps employers should take to ensure they are complying with gender pay reporting?

  1. Understand what is required to be reported and ensure that systems are in place which can easily produce the statistical data for publication. 
  2. Calculate your gender pay gap now to identify any equal pay risks or other systemic issues giving rise to the gap before it has to be published.
  3. Identify additional numbers, initiatives and plans to address the gap which you would like to disclose that can provide supporting information.
  4. Use the data and analytics to understand the root causes or why certain groups of staff are especially affected.
  5. Begin to craft the narrative of your disclosure and develop your communication plan. This could include sharing and discussing the data internally before going public.

How do I address Gender Pay Gap issues?

The employer must set out in their report its opinion as to the reasons why a gender pay gap exists and the measures that are being taken or that are proposed to be taken to eliminate or reduce the gender pay gap.

Understand that there may be varying factors that have influenced your figures such as historical changes, patterns of progression or industry sector. It is important that your response to any gender pay gaps is proactive and demonstrates positive changes. In reviewing any gaps, you may need to revisit the organisations policies and practices in the relevant areas such as recruitment, retention, Diversity & Inclusion, and remuneration.


An employee can bring a claim against their employer to the WRC in respect of non-compliance with the Act. The Act does not provide for compensation for the employee or for a fine to be imposed on the employer however an order can be imposed on the employer to take a specified course of action to comply with the Act. All decisions are published and will include the names of the employer and the employee.

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This article is correct at 17/06/2024

The information in this article is provided as part of Legal-Island's Employment Law Hub. We regret we are not able to respond to requests for specific legal or HR queries and recommend that professional advice is obtained before relying on information supplied anywhere within this article.

Caroline Reidy
The HR Suite

The main content of this article was provided by Caroline Reidy. Contact telephone number is +353 66 710 2887 / +353 86 775 2064 or email

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