Pay Transparency in Ireland: Latest Update on the EU Directive

Introduction

Ireland has yet to implement the EU Pay Transparency Directive despite the 7 June 2026 transposition deadline having passed. While the Government has indicated that implementation remains a priority and that requirements will be introduced on a phased basis, employers should start preparing now for significant new obligations relating to pay transparency, reporting and equal pay. This article outlines the latest position and the practical steps organisations should be taking.

Irish Government Update

The deadline for the implementation of the Pay Transparency Directive 2023/970 (the “Directive”) was 7 June 2026. Ireland, along with the majority of Member States, has not met the transposition deadline, which Ireland has confirmed to the European Commission. The EU Commission confirmed that it will not delay the transposition deadline or simplify the requirements of the Directive.

As of 22 July 2026, no draft bill has been published by the Irish Government and there is currently no indication as to when a draft bill will be available.  Drafting of the Pay Transparency Bill (the “Bill”), which appears to be intended to transpose the Directive, was included in the Government’s Summer Legislation Programme, which lists out the bills the Irish Government intends to publish, draft or take action in relation to.  However, the Bill was not included in the Irish Government’s priority legislation for publication or drafting for Summer 2026, making it unclear when a draft bill will be ready for publication.

Ministerial Comments

During parliamentary questions on 14 July, the Minister for Children, Disability and Equality, the minister who has responsibility for the implementation of the Directive,  (the “Minister”) was asked about the current status of Ireland’s transposition of the Directive. The Minister’s response indicated that a large portion of the Directive had already been transposed in the Gender Pay Gap Information Act 2021, which, along with the associated regulations, introduced gender pay gap reporting in Ireland in 2022 for organisations with 250+ employees. As of 2025, all organisations in Ireland with at least 50 employees are required to comply with gender pay gap reporting. For organisations with a multinational presence in Ireland, or employees across a group structure located in Ireland, headcount is based on employees who are employed by an Irish entity or paid through an Irish payroll. Employees who are employed by a non-Irish entity and based outside of Ireland can be excluded from the headcount, even if their duties relate to the work carried out by an Irish entity.

As regards the remaining aspects of the Directive, while the Minister confirmed that achieving transposition remains a priority for the Irish Government, with work ongoing in relation to developing necessary legislation to transpose the remaining aspects of the Directive, no date for publication of draft legislation was provided, nor was any indication given as to when a draft may become available.

However, helpfully from an employer’s perspective, the Minister did indicate that the Directive would be introduced on a phased basis and employers would not be penalised for not having all elements of the Directive completed in June 2026.

What Employers Should Be Doing Now:

• Conduct a pay audit across remuneration categories, including salary, bonuses, benefits and overtime.
• Review job grading and job evaluation systems to ensure roles performing work of equal value are appropriately identified.
• Assess any existing pay differentials and ensure they can be objectively justified on gender-neutral grounds.
• Consider whether group-wide pay structures could broaden the pool of comparators available to employees.
• Ensure employee demographic data, including gender breakdown information, is accurate and up to date.

Written by Marcus Dunne (Associate) and Aoife Bradley ( Partner)

For more information and advice on this directive, please contact a member of the Employment team or your usual Byrne Wallace Shields contact.