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This update highlights three major employment law developments in Ireland in 2025 through to 2026:
- Introduction of the My Future Fund auto-enrolment pension scheme from January 2026;
- Mandatory gender pay gap reporting for employers with more than 50 staff from 31 May 2025 with detailed data and action plans required; and
- Transposition of the EU Pay Transparency Directive mandating pay transparency and reporting.
HR professionals, employers, and payroll teams must review policies, prepare relevant data, update necessary work practices and monitor legal updates to ensure compliance with these requirements.
2025 was another busy year in Irish employment law. In this update which was published by Legal Island on Thursday 11 December, Addleshaw Goddard look at three areas that came into sharp focus for HR professionals and employers in 2025, providing some top tips for employers to prepare for these areas to develop further into 2026.
Auto Enrolment
The long-awaited pension auto-enrolment scheme, My Future Fund ("AE Scheme") is coming into force on 1 January 2026 and employers have been busy preparing for its launch.
Some key points to note:
- From 1 January 2026, employees will automatically be enrolled
into the AE Scheme if they are:
- Between the age of 23 – 60 and earn more than €20,000 per year across all employments (for example part-time workers with multiple jobs).
- New and existing employees including those on probation as well as casual, seasonal, part-time or fixed-term workers.
- Automatic enrolment into the AE Scheme will not apply to employees if contributions are being paid, by the employee themselves (through payroll) or by their employer, into a qualifying occupational pension scheme, qualifying Personal Retirement Savings Account (PRSA), qualifying trust retirement annuity contract or qualifying Pan European Pension Plan. Employers should note that the Department of Social Protection has indicated that regulations are being prepared this December which aim to impose minimum contribution rates into such qualifying arrangements that must be met for employees to be considered to be exempt from the AE Scheme.
- The AE Scheme is overseen by the National Automatic Enrolment Retirement Savings Authority ("NAERSA") who will assess employee eligibility using payroll data and issue Auto-enrolment Payroll Notifications (AEPNs) to employers or payroll providers, specifying the required contribution rates.
- Both employer and employees must contribute 1.5% of gross earnings (up to €80,000 salary cap), both increasing by 1.5% every three years to a maximum of 6% in year 10. The State contributes 0.5% initially in Year 1 to 3 increasing over time to 2% by Year 10.
- Auto-enrolment will commence from day one of employment and if there is an occupational pension scheme in place, any waiting periods must be considered.
- Employers / HR teams should engage with their pension's brokers payroll teams and legal advisors to plan and prepare for auto-enrolment (or being exempt from it).
Gender Pay Gap (GPG) Reporting
Some key points to note:
- From 31 May 2025, all organisations in Ireland with 50 or more employees are required to publish a GPG report in 2025 containing information relating to the remuneration of their employees for the purpose of showing whether there are differences in such remuneration referable to gender and, if so, the size of such differences. There is very specific information and data that must be broken down further in this report.
- Employers must set out in their GPG report a statement detailing the reasons for the GPG and what measures the employer will take to eliminate or reduce it.
- Employers must publish their GPG data within 5 months of a June "snapshot" date that they can pick by reference to the employees they employ on that date with the calculations being based on those employees' remuneration for the 12-month period that precedes the snapshot date.
- The GPG report must be published on the employer's website or in a manner accessible to all its employees and the public. The Government launched an online central GPG Portal on a voluntary basis in November 2025. From 2026 it is expected that reporting through the portal will be mandatory for employers who employ more than 50 employees and legislation in this regard is awaited.
- If an employer meets the 50 plus employee threshold, they should gather the required GPG information in order to assist in preparing their report well in advance of the snapshot date. The report will take significant time to prepare and will need to be carefully drafted once the data has been analysed in detail. Organisations should be aware of the reputational risks and potential impact on talent attraction and retention should there be a significant gender pay gap reported.
EU Pay Transparency Directive – Implications for Irish Employers
The EU Pay Transparency Directive (the "Directive") is expected to be transposed into Irish law by 7 June 2026, but employers eagerly await the final Irish legislation which is still being prepared. Despite the lack of published legislation which transposes all of the requirements of the Directive, employers should start to prepare and analyse information.
The Directive applies to all workers workers, (including part-time workers, fixed term contract workers and those with a contract of employment with an employer or agency), job applicants, and covers both public and private sectors.
Some Key Principles under the Directive
Pay Transparency for Job Seekers
- Employers must disclose pay levels/ranges in job advertisements and before interviews.
- Information must be provided to applicants to enable transparent pay negotiations.
- Employers cannot ask about an applicant's pay history.
- Job advertisements and recruitment must be gender neutral and non-discriminatory.
Transparent Pay Setting and Pay Progression Policy
- Employers are required to put in place easily accessible information about the criteria that will be used for determining pay, pay levels and pay progression.
- There is provision for this requirement to provide information about pay progression to only apply to organisations that employ more than 50 workers.
Right to Information
Employees have the right to request (and receive in writing) information on their individual pay level and the average pay levels, broken down by sex, for categories of workers doing the same work as them or work of equal value. An employer must provide this information within 2 months of the request. Employers must annually inform workers of their right to request pay information. Employees cannot be prevented from disclosing their pay to others.
Joint Pay Assessments
- The Directive sets out that these assessments will be required
to be prepared provided that certain thresholds are met, namely:
- where an employer's GPG Report shows a 5% or more GPG in any category of employee;
- the employer has not justified such a difference in average pay level by objective and gender-neutral factors;
- any unjustified pay gap has not been remedied within six months of the GPG report
How employers can prepare
- Review current pay, recruitment practices and policies to identify disparities.
- Establish robust and transparent pay practices.
- Prepare for data collection and increased reporting.
- Educate managers and employees.
- Monitor legislative developments.
- Examine current job descriptions and ensure that there is objective, gender neutral criteria in place.
- Legal, HR and Payroll teams need to co-operate in order to ensure obligations under the Directive are implemented smoothly
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
