In this week’s Blog, Nuala McGowan, ACA, CPA, AIA and founder of McGowan Accountancy Services looks at Ireland’s Gender Pay Gap reporting requirements and the rules that are set out under the Gender Pay Gap Information Act 2021.
Who must report?
As of 2025, all employers with more than 50 employees are required to report annually on their gender pay gap. The threshold was phased in over time:
- 250+ employees (from 2022)
- 150+ employees (from 2024)
- 50+ employees (from 2025)
When must reporting be done?
Employers must:
- Select a snapshot date in June each year.
- Calculate the required metrics based on employees employed on that date.
- Publish the report within five months, typically by the end of November.
What must be reported?
The report must include gender differences in:
- Mean hourly remuneration
- Median hourly remuneration
- Mean bonus remuneration
- Median bonus remuneration
- Proportion of employees receiving bonuses
- Proportion receiving benefits-in-kind
- Pay gaps for part-time employees
- Pay gaps for employees on temporary contracts
- The proportion of men and women in each of the four pay quartiles (lower, lower-middle, upper-middle, upper)
Narrative explanation required
The report cannot simply contain the numbers. Employers must also explain:
- The reasons they believe the gender pay gaps exist; and
- The measures being taken, or proposed, to reduce or eliminate those gaps.
Publication requirements
Employers must:
- Publish the report on their website (or make it publicly available by another means if they do not have a website).
- A central government Gender Pay Gap Portal exists and voluntary reporting began in 2025. The government has indicated that portal reporting is expected to become mandatory from the 2026 reporting cycle once legislative amendments are completed.
Non-compliance
The legislation provides enforcement mechanisms, including the possibility of applications to the Workplace Relations Commission or the courts to compel compliance.
Important distinction: Gender Pay Gap vs Equal Pay
Gender pay gap reporting measures the difference in average earnings between men and women across the organisation as a whole. It is not the same as an equal pay audit. An organisation can have no unlawful equal-pay issues and still have a gender pay gap if men and women are concentrated in different roles or levels of seniority.
If you’re preparing a report for your organisation, I can also walk through the specific calculations and the data typically required from payroll and HR systems.
For more information on this topic contact Nuala on on (090) 66 25818 or email nuala@