Ireland Requires Employers to Report Pay Disparities by Gender

​New regulations in Ireland require employers to report differences in pay between men and women.

Under the new law, employers in Ireland must submit this data:

• The percentage differences between the mean and median hourly pay of male and female employees.
• The percentage differences between the mean and median bonuses of male and female employees.
• The percentage differences between the mean and median hourly pay of male and female part-time employees.
• The percentage of male and female employees who received bonuses.
• The percentage of male and female employees who received benefits.

The reporting requirement will apply to all public- and private-sector employers with 250 or more employees at first, but it will extend to organizations with 150 or more employees in 2024 and then to all employers with 50 or more employees in 2025.

To start, employers must collect their data as of June 2022 and submit reports to the government by December 2022. The information will be available to the public as well as the government.

The law's intent is to ensure accountability and transparency around pay disparities, according to Deirdre Malone, associate partner with the firm EY Ireland in Cork.

If employers don't comply with the law, they could face court action by the Irish Human Rights and Equality Commission or by employees, who may complain to the Workplace Relations Commission, Malone explained. 

More specifics should be coming out soon about the reporting requirements. "We are still awaiting regulations to officially commence the act, which are expected to provide further detail and clarity for employers on what will be required," said Síobhra Rush, an attorney with Lewis Silkin in Dublin. "It's also expected that the Department of Children, Equality, Disability, Integration and Youth will publish guidance for employers on how gender pay gap calculations should be performed and possibly presented."

She added, "Until then, it would be advisable for employers to have at least taken some preparatory steps, such as considering which of their group entities may have to report. Employers should also check and monitor the headcount of these entities. They should also consider who the key stakeholders in the business are likely to be in terms of gathering the data, such as payroll to obtain the pay data, HR analysts to collect the people data, more-senior-level HR to understand the initiatives that can be created or which may already exist to reduce any gaps, and PR [and] communications to assist with writing the report."

Defining the Gender Pay Gap

The gender pay gap is the difference between the average hourly wages for men and women across the entire workforce, regardless of seniority. This is not the same as the pay rates for equal work.

Ireland's gender pay gap was 11.3 percent in 2019, the latest year statistics were available, according to Eurostat, a statistical agency of the European Union. Among all countries in the European Union, the average gender pay gap was 14.1 percent in 2020. The gender pay gap is generally much lower for the youngest workers and tends to widen with age, Eurostat reported.

Companies should consider what is contributing to their gender pay gap. What are the company's recent patterns in hiring, promotions, raises and career development?

A gender pay gap may result from unequal pay for equal work, but also from differences in the characteristics of men and women in the workforce, including age, occupation and number of hours worked, according to Eurostat's report. Women tend to be concentrated in lower-paying job sectors like health care and education, and men tend to be concentrated in higher-paying job sectors like finance and IT.

Rush commented, "Given that historically, women have been underrepresented in many areas of work, and particularly at senior levels, it's to be expected that most employers will have [a pay gap]. The gender pay gap can be caused by various different factors, including historical/social factors, lack of women in senior roles, labor market experience, family responsibilities and potentially equal pay issues."

She added, "Employers in Ireland will have to identify and disclose the causes of their gender pay gaps. Their gender pay gap reports will also have to include the measures being taken or proposed to eliminate or reduce any pay gap, which is not currently required in the U.K."

This is a chance for organizations to reflect on where they could improve. Jackie Gilmore, a partner with the firm EY Ireland in Dublin, said, "Organizations can use this as an opportunity to put the mechanisms in place to ensure that women are being promoted and attracted into senior positions."

In many countries, the worldwide COVID-19 pandemic worsened the existing gender disparities in pay and employment. Shane Gallen, an attorney with Lewis Silkin in Dublin, said, "It is certainly widely reported that globally this has been the case."

Leah Shepherd is a freelance writer in Columbia, Md.