Ireland


Gender pay gap reporting

Impact date: June 2025 (Snapshot date) and November 2025 (Published report). The Pay Transparency Bill has not yet passed In 2025, the requirement to report on gender pay gaps will apply to more businesses. If an organization has 50 or more employees (whether in the public or private sector), they will now be required to publicly disclose their gender pay gap data. This is a significant expansion from the previous threshold of 150 or more employees.

Organizations with 150 or more employees had to report on their gender pay gap by December 2024. It is now anticipated that in 2025 the reporting deadline will be brought forward to November.

The report published needs to include several key metrics:

  • The difference between the average (mean and median) hourly pay of your male and female employees
  • The difference between the average (mean and median) bonuses paid to men and women
  • The percentage of men and women who received bonuses and benefits-in-kind
  • How the workforce is divided into four pay bands from lowest to highest paid, and the proportion of men and women in each band

On 18 February 2025, the Government’s Spring Legislative Programme noted that heads were in preparation on the Pay Transparency Bill which will transpose the EU Pay Transparency Directive and aims to ensure pay transparency for roles advertised by business and public sector organizations. This follows the previous Bill lapsing with the dissolution of Dáil Éireann on 8 November 2024.

Employer implications/action needed Employers must determine if their organization meets the 50-employee threshold. Employers should study the specific reporting metrics and ensure they understand how to calculate them. Employers should prepare to gather and analyze the relevant data in order to be ready for the November deadline. Employers should have a draft report which they can edit and add to throughout the year, which will help keep on top of the data.

Employers should monitor the status of the Pay Transparency Bill, and may wish to audit their current practices to identify areas requiring review in due course. Should the Bill pass, employers must ensure that they do not publish or display an advertisement which discriminates or signals an intention to discriminate. Moreover, employers will have an obligation to publish approximate pay upon employment. As such, employers should move to display the approximate remuneration on their job descriptions and advertisements.

Employer risk Employees can bring a claim to the WRC for non-compliance. The Irish Human Rights and Equality Commission may also apply to the High Court for an enforcement order.

Link Employment Equality (Pay Transparency) Bill 2022

Automatic Enrolment Retirement Savings System Act 2024

Impact date: 30 September 2025 The Minister for Social Protection has signed a Commencement Order for the Automatic Enrolment Retirement Savings System Act 2024 (the “Act”). Under the Commencement Order, 30 September 2025 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 State’s 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 Although there is still work to be done to meet the proposed launch date for My Future Fund, having an official start date gives employers a clear target for finalizing their plans. 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 in less than a year.

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.

General Scheme of the Employment (Restriction of Certain Mandatory Retirement Ages) Bill 2024

Impact date: Awaited (drafting is underway) The Government has approved the drafting of the Employment (Restriction of Certain Mandatory Retirement Ages) Bill 2024 (the “Bill”). Should the legislation come into force, it would allow (but not compel) employees to continue working until the State pension age, which is currently 66 years old. Under the proposed legislation, an employer cannot set a mandatory retirement age below the State pension age if the employee does not consent to retire.

Under the current draft of the Bill, 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 proposed Bill and should consider how this proposed legislation may impact their workforce and if it will impact the normal retirement date currently set out in their pension schemes.

Employer risk N/A

Link Briefing

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.

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

The Government’s Spring Legislative Programme published on 18 February 2025 notes that revised heads are in preparation, and so further updates are awaited.

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.

Link The link to the General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 can be found here.

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Julie Galbraith Partner


E: juliegalbraith@eversheds-sutherland.ie T: +35 316 644 398

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