EU Pay Transparency

The EU Pay Transparency Directive was adopted in 2023 and requires member states to transpose it into national law by 7 June 2026. The Directive goes over and above Ireland’s current Gender Pay Gap reporting regime and introduces new obligations for employers right across the EU.

Key elements of the Directive include

• Pay transparency before hiring: under the directive, job advertisements must include a salary range, and employers cannot ask candidates about their pay history. This is something to be mindful of during the interview stage in particular, or when you have job application forms online. 
• Right to pay information: Employees will have the right to request information about average pay levels by gender for staff doing the same work or work of equal value. Retaining accurate records will be critical. 
• Gender pay gap reporting: Organisations with 100 or more employees will be required to report on their gender pay gap, with enhanced detail compared to current Irish requirements.
• Joint pay assessments: Where a reported pay gap of 5% or more cannot be justified, employers will be required to carry out a joint pay assessment with employee representatives – a potentially significant and time-consuming exercise.

Transposition of the Directive in Ireland

Given it is now 21^st May 2026, Ireland is unlikely to transpose the EU Pay Transparency Directive into Irish law by the 7 June 2026 deadline, and this is the same across many EU member states, where the legislative process has not kept pace with the deadline. 

This is not unusual, and transposition delays are relatively common, so it is nothing to be concerned about, but it also does not change the direction of travel. Heavier legislation is on the way, and companies should be prepared for it. The question is when the directive will be transposed, not if. Irish employers should not treat the delay as an excuse to defer preparation for the change. We recommend using this period to examine your current reporting and data available, so that you can make improvements ahead of the law coming into force. 

What Irish SMEs Should Be Doing Now

Whether you are already in scope for existing Gender Pay Gap (GPG) reporting or
are a smaller business anticipating future obligations, there are practical steps you
should be taking.

If you employ 50 or more people

You are already requested to comply with Ireland’s GPG reporting obligations. If you
have not yet published a gender pay gap report, this is something you should
prioritise. The reporting portal is public, therefore, gaps in reporting are noticeable.

If you employ fewer than 50 people

You are not currently in scope for Irish GPG reporting requirements, so the EU Pay
Transparency Directive will likely be your first reporting obligation on gender pay.
Now is the time to review your salary data, identify any unexplained gaps, and put
the internal structures in place to report when required.

For all employers, regardless of size, we recommend you

• Audit your data: Understand what your gender pay gap actually is before you
  are required to publish it. Surprises at the reporting stage are much harder to
  manage.
  
• Review your pay structures: Are internal pay decisions documented? The
  Directive will require employers to justify pay differences so informal decision
  making and undocumented results won’t cut it under legislative scrutiny.
  
• Look at your recruitment process: Under the incoming Directive, salary
  ranges will need to be included in job advertisements. If you don’t currently
  disclose pay bands, you should begin thinking about how to structure and
  communicate these when hiring.
  
• Take remediation steps where needed: Addressing pay gaps takes time.
  Employers who identify issues now and begin to address them will be in a
  much stronger position than those who wait until the new rules force
  disclosure.

How CAS Advisory Can Help

The good news is that CAS Advisory has been providing gender pay gap reporting
services to clients for some time, and our team is well-placed to support you,
whether you need to meet your existing reporting obligations under current Irish law,
or want to get ahead of the changes the EU Pay Transparency Directive will bring.
Our services cover the full reporting process: calculating and sense-checking your
gender pay gap figures, reporting, and advising on the practical steps to address
gaps over time. We are also working with clients on the groundwork for the incoming

Directive, reviewing pay policies, recruitment processes, and reporting systems
ahead of the changes becoming enforceable.
If you would like to discuss how we can support your team, please get in touch with
our experts by emailing contactus@casaccountants.ie.