Ireland
Automatic Enrolment Retirement Savings System Act 2024
Impact date: 1 January 2026 The Minister for Social Protection has signed a Commencement Order for the Automatic Enrolment Retirement Savings System Act 2024 (the “Act”). 1 January 2026 has been marked as the official launch date for the new auto-enrolment system (which will be called My Future Fund). The National Automatic Enrolment Retirement Savings Authority (“NAERSA”), the supervisory body which will be responsible for overseeing the system, will be established with effect from 31 March 2025.
The Act establishes a new retirement savings scheme requiring both employers and employees to make mandatory contributions, starting at 1.5% of gross salary and increasing to 6% after ten years. The State will also contribute to the scheme. The scheme targets employees aged 23 to 60 who earn at least €20,000 annually and are not part of a qualifying occupational pension scheme. Employees will have the option to opt out after six months of participation.
In order to effect the provisions of the Act and My Future Fund, the Finance Act 2024 (the “Finance Act”) was enacted on 12 November 2024 and makes a number of amendments to the Taxes Consolidation Act 1997 (the “TCA”). The amendments to the TCA provide that employer contributions to My Future Fund will be allowed as a deductible expense for corporation tax purposes but any repayment of contributions to an employer will be taxed as a trade receipt. Further, employee contributions will not benefit from tax relief (with the Stateʼs top-up contribution provided in lieu) but investment returns earned on funds within My Future Fund will be exempt from tax in the normal way. Additionally, upon retirement, participants may take up to 25% of their accrued fund as a tax-free lump sum with any balance withdrawn thereafter being liable to income tax under the PAYE system. Finally, any funds credited to a participant’s personal representative(s) on their death will also be subject to income tax; and benefits accrued under My Future Fund will be included for Standard Fund Threshold purposes.
Employer implications/action needed It is crucial for employers who have not yet developed an auto-enrollment action plan to start their preparations now to ensure their business is ready to meet the new requirements when the system launches. Employers must register on the portal, facilitate deductions and ensure compliance with minimum contributions.
Employer risk Under section 131 of the Act, if an employer fails to pay any contribution of which they are required, or who makes a deduction in respect of any contribution that they are obliged to make, will be found to be guilty of an offence. Additionally, an employer who makes false statements or falsifies documents to evade or reduce contributions to an employee's pension fund will also be guilty of an offence. Non-compliance with the Act or committing an offence under certain sections can result in a Class A fine or imprisonment for up to six months, or both. Furthermore, offences such as failing to comply with a compliance notice or document forgery can lead to fines up to €50,000 or imprisonment for up to three years, or both.
Links Automatic Enrolment Retirement Savings System Act 2024. Our Pensions team have prepared a briefing and commentary on the (then) draft AE Bill which is available here and more recent updates on the Act are available here, here and here.
National Minimum Wage increase
Impact date: 1 January 2026 The National Minimum Wage increased to €14.15 per hour from 1 January 2026, continuing Ireland's trajectory toward the living wage model set at 60% of median earnings. The USC 2% band ceiling also increased to €28,700, requiring payroll configuration updates and cost planning, particularly in labor-intensive sectors.
Employer implications/action needed N/A
Employer risk Medium risk. Failure to apply the correct rate is a breach of the National Minimum Wage Act and exposes employers to WRC complaints and reputational risk. Wage compression risks discrimination and retention claims where differentials are not managed.
Revised Code of Practice on Access to Part-Time Working
Impact date: 22 January 2026 The Code of Practice on Access to Part-Time Working 2026 (Code) was signed into law by the Minister for Enterprise, Tourism and Employment on 22 January 2026. The updated WRC Code of Practice has been signed into law to support greater workplace flexibility and inclusivity. It offers practical guidance on arranging part time work that suits modern organizational and employee needs, with a particular focus on supporting parents, carers, older workers and students. The Code also encourages employers to review their internal policies and to publish gender balanced data on the use of flexible working arrangements.
Employer implications/action needed Employers are advised to take the following steps:
- assess the feasibility of introducing or expanding access to part-time work at all levels, taking into account business and operational factors
- set out clear, objective criteria for identifying roles or functions that can be performed on a part-time basis
- review existing policies and ensure clear procedures to facilitate requests for part-time work
Employer risk N/A
Employment Permit Salary Changes
Impact date: 1 March 2026 On 2 December 2025, the Department of Enterprise, Tourism, and Employment, published a roadmap to increase employment permit minimum salaries. The phased increase will continue through 2030 under the Employment Permits Act 2024. Minimum salary for General Employment Permits will rise from €34,000 to €36,605. Minimum salary for Critical Skills Employment Permits will increase from €38,000 to €40,904. For meat processors, horticultural workers, healthcare assistants, and home carers, the minimum salary will increase from €30,000 to €32,691. Lower starting thresholds will apply for recent graduates, reflecting their early career stage.
Employer implications/action needed Employers must understand the new salary requirements and be prepared to meet them if this applies to an employee requiring a permit.
Employer risk N/A
Link Roadmap
EU Pay Transparency Directive — Transposition by June 2026
Impact date: 7 June 2026 (transposition deadline) Transposition of the EU Pay Transparency Directive is due by June 2026 and will introduce obligations that go significantly beyond current gender pay gap reporting requirements. The government set out proposals in January 2025 to implement parts of the Directive relating to the recruitment stage, including disclosure of the initial pay range in job advertisements and a ban on asking candidates about their current or past pay. The government's Autumn Legislative Programme for 2025 indicated that the Heads of a Pay Transparency Bill were in preparation, so further legislative steps are anticipated in 2026.
Employer implications/action needed Audit pay structures now and identify potential gaps by category of worker. Begin constructing documented, gender-neutral criteria for pay setting and progression. Remove salary history questions from application forms and recruitment processes immediately. Start preparing salary range disclosures for job advertisements. Engage with the draft Bill when published.
Employer risk Medium. The Directive's joint pay assessment mechanism and employee information rights may increase litigation exposure. Pay secrecy clauses will likely be unenforceable. Early preparation is recommended given the June 2026 deadline.
Gender Pay Gap Reporting
Impact date: Late 2026 Reporting on the Gender Pay Gap Portal is likely to become mandatory from 2026, enabling the government to track progress in reducing the gender pay gap across employers.
Employer implications/action needed All employers with 50 or more employees must now prepare to report via the portal rather than simply publishing reports on their own website. Employers should register with the portal now, audit their current pay data collection processes and ensure their 2025 reports are published. Begin preparing internal pay structures and job evaluation frameworks in anticipation of the more onerous requirements coming under the EU Pay Transparency Directive.
Employer risk Medium. Failure to report via the mandatory portal will constitute a breach of statute. Portal reports will be publicly searchable, increasing reputational exposure, particularly where gaps are significant.
Employment (Contractual Retirement Ages) Retirement Act 2025
Impact date: Awaiting WRC Code of Practice expected later this year. With this we expect to receive a commencement date. On the 16 December 2025, the Government signed into law the Employment (Contractual Retirement Ages) Act 2025 (the “Act”). Once the legislation comes into force, it will allow (but not compel) employees to continue working until the State pension age, which is currently 66 years old. Under the legislation, an employer cannot set a mandatory retirement age below the State pension age if the employee does not consent to retire.
Under the Act, if an employee does not consent to retiring at their employer’s contractual retirement age, they must notify their employer in writing of that fact not less than three months prior to the contractual retirement date. If the employer has established different notice periods (e.g. by way of employee handbooks) the employee must give no less notice than that specified period, but the required notice period must not exceed six months.
Employer implications/action needed Employers should be alert to the Act and should consider how this legislation may impact their workforce and if it will impact the normal retirement date currently set out in their pension schemes.
Employer risk Employees will be able to refer a complaint of a breach of the Act to the WRC if their employer imposes a mandatory retirement age which is lower than the pensionable age without their consent. The WRC may award re-instatement, re-engagement and/or an award of compensation of up to two years’ remuneration (or €40,000, whichever is greater). The Act includes another offence, namely, failure to provide a reasoned reply as set out above. Such an offence can attract the penalty on summary conviction of a Class A fine or a term of imprisonment not exceeding 12 months or both.
Link The 2025 Act
Statutory sick leave
Impact date: Further updates are awaited.
Under the Sick Leave Act 2022, employees are entitled to five days statutory sick leave per year, paid at 70% of normal pay up to a maximum of €110 a day. The initial allocation of three days set down in 2023 was increased by way of Ministerial Order to five days in 2024. It was anticipated that another Ministerial Order in 2025 would increase the allocation again to seven days. To date, this has not happened, though the Minister noted that a Ministerial Order does not have to be passed on 1 January.
It is important to note that where an employer provides a more favorable company sick pay scheme, employees are not entitled to benefit from both statutory sick pay and the company sick pay scheme.
Employer implications/action needed No action required at this point, though it is worth being aware that the mandatory allocation may change later in the year.
Employer risk An employer who does not comply with the Sick Leave Act 2022 may find themselves the subject of a WRC Adjudication.
Link Ministerial Statement is linked here.
Platform Work Directive EU 2024/2831
Impact date: Awaiting update on the date it will be transposed.
The EU Platform Work Directive (Directive EU 2024/2831), adopted in October 2024, must be transposed into Irish law by 2 December 2026. It introduces enhanced protections for individuals working through digital labour platforms, including a rebuttable presumption of employment status where direction and control exist, and substantial protections governing algorithmic management and data processing. Digital platform operators (e.g., gig economy intermediaries) should review contractual arrangements and data practices to mitigate misclassification and compliance risks.
Employer implications/action needed No immediate action required.
Employer risk N/A
Action Plan to Promote Collective Bargaining (2026-2030)
Impact date: N/A
In late 2025, the Government published an ‘Action Plan to Promote Collective Bargaining (2026-2030)’, aligned with the requirements of the EU Adequate Minimum Wages Directive. The Action Plan seeks to increase collective bargaining coverage primarily through encouragement rather than enforcement, consistent with Ireland’s voluntary industrial relations model.
Employer implications/action needed No immediate action required but employers should stay informed as new Codes of Practice and guidance are developed, review internal consultation and employee engagement structures. Be prepared for possible participation in government surveys or research, and monitor developments in WRC and Labour Court procedures.
Employer risk N/A
Equality and Family Leaves (Miscellaneous Provisions) Bill
Impact date: Further updates are awaited.
On 15 January 2025, the Department of Children, Equality, Disability, Integration and Youth published the General Scheme proposing amendments to a variety of Employment Equality Acts. Examples of the proposed amendments include:
- insertion of pay transparency obligations under the EU Pay Transparency Directive
- increased time limits for redress and increased redress amounts
- removing the differential rates of pay for disabled persons
- extending the jurisdiction of the WRC to include claims of prohibited conduct occurring at the point of entry to licensed premises
A report was published in October 2025 by the Joint Committee on Children and Equality regarding pre-legislative scrutiny of the Bill. There have not been any additional updates since this report.
Employer implications/action needed No action required currently, but employers should monitor the progress of the Bill.
Employer risk Should the amendments be passed, increased time limits and caps on redress will likely increase the number of claims brought to the WRC. The movement of jurisdiction from the District Court to the WRC for claims under the Equal Status Act 2000 in relation to licensed premises will likely also increase the number of claims brought, as the WRC process is more affordable and more claimant friendly.
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