- within Law Department Performance, Strategy and Tax topic(s)
Employment
Upcoming minimum wage increase
The National Minimum Wage Order 2025 took effect from 1 January 2026, increasing the national minimum hourly rate to €14.15.
For more information, see here: National Minimum Wage Order 2025.
Increased minimum salary thresholds for work permits
The Government has announced new increased minimum salary thresholds which will occur in phases, with the first increase to apply from 1 March 2026, raising general employment permits to €36,605 (from €34,000) and critical skills permits to €40,904 (from €38,000), while meats processors, horticultural workers, healthcare assistants, and home carers rise to €32,691 (from €30,000). These adjustments are part of a gradual roadmap to balance worker rights and business needs, with further increases planned until 2030, and applying to both new and renewal applications.
For more information, see here: Government unveils roadmap for gradual increase in employment permit salary thresholds.
Pay Transparency Directive
The deadline for the transposition of the Pay Transparency Directive into Irish law is 7 June 2026. Irish employers need to take steps now to prepare for its implementation. The Directive is part of a wider EU strategy seeking to tackle concerns about the enforcement of the principle of equal pay between men and women by eliminating pay secrecy, promoting transparency in pay setting and career progression and strengthening enforcement mechanisms.
For more information, see our briefing here: The Pay Transparency Directive: What does it mean for Irish employers? and this episode of our podcast series here: The EU Pay Transparency Directive.
Changes to retirement ages
The Employment (Contractual Retirement Ages) Act 2025 was signed into law by the President on 16 December 2025. The Act aims to restrict employers from enforcing a mandatory retirement age below the State Pension age of 66, unless the employee consents to it. Significantly, the Act introduces a new offence in respect of which both bodies corporate and inpiduals can be prosecuted. A commencement order is required before the changes introduced by the Act become effective.
For more information, see here: Employment (Contractual Retirement Ages) Bill 2025 goes to the President to be signed into law.
Changes to equality legislation
It was announced in the Legislation Programme for Autumn 2025 that the Heads of Bill for the Equality and Family Leaves (Miscellaneous Provisions) Bill were being revised. The Heads of Bill follows on from a review of Ireland's equality legislation that was announced in 2021 and contains significant changes to Irish equality law, which will have implications for all employers. Provision is also being made for leave for bereavement and pregnancy loss in the draft Bill.
For more information, see our insights blog post here: Significant changes to equality legislation proposed.
Gender pay gap portal launched on voluntary basis
The Gender Pay Gap Portal launched on a voluntary basis only in 2025, allowing employers who are members of IBEC and the 30% Club to voluntarily report on the portal in 2025. The Government has said that legislation is being drafted to amend the Gender Pay Gap Information Act 2021 to provide the legislative basis for employers to be required to report their gender pay gap information via the online portal in 2026.
For more information, see our insights blog post here: Gender Pay Gap Portal to launch on voluntary basis only in 2025.
Pensions
Automatic enrolment
The automatic enrolment (AE) system came into force on 1 January 2026. Employees aged between 23 and 60, who earn in excess of €20,000 gross per year (from all employments) and who are not already enrolled in an occupational pension scheme or other pension arrangement, will be automatically enrolled into "My Future Fund", the fund set up by the Government to accept AE contributions.
Employers whose employees are currently participating in an occupational pension scheme or PRSA should note that the Government has introduced regulations setting minimum standards for such schemes/PRSAs in order for their members to qualify as being in exempt employment. For defined contribution schemes and PRSAs, employer contributions must be at least 1.5% of an employee's gross pay or €1,200 per year (whichever is less) and combined total employer and employee contributions must be at least 3.5% of gross pay or €2,800 per year (whichever is less). For defined benefit schemes, continued service in employment must entitle the employee to accrue a "long service benefit". If a scheme or PRSA does not meet the new contribution standards, both the employer and the employee will be required to contribute to the AE system separately and such contributions may be in addition to continuing existing contributions to the scheme/PRSA.
Introduction of Pension Scheme Authorisation Regime
In a number of public statements throughout 2025, the Pensions Regulator indicated that the Pensions Authority (the Authority) were liaising with the Department of Social Protection to prepare legislation that would introduce a new authorisation regime for occupational pension schemes in Ireland.
The Government's 2025 Autumn Legislative Programme includes an "Occupation Pensions (Amendment) Bill" which is stated to be intended "to develop detailed policy and legislative proposals relating to the regulation and supervision of Master Trust pension schemes and to ensure the appropriate statutory protections are provided for these schemes".
Although the Legislative Programme refers solely to master trusts, statements from the Pensions Regulator have indicated that "it is intended that all funded retirement schemes will be subject to authorisation, based on the requirements of IORP II and an enhanced version of the Code of Conduct.". The timeline for the implementation of the authorisation regime is unclear, but if introduced in 2026 it is likely to introduce a significant additional layer of regulation for all occupational pension schemes as there has been no indication of any grandfathering provisions in relation to existing pension schemes.
Expiry of IORP II derogation for One Member Arrangements (OMAs) established prior to 22 April 2021
Under the transitional arrangements for the introduction of IORP II in 2021, OMAs which were established prior to 22 April 2021 were granted a five-year derogation from the requirement to comply with the provisions of IORP II and the Code of Practice. This derogation will expire on 21 April 2026 and we anticipate that providers of OMAs will shortly be reaching out to employers and beneficiaries of such OMAs, if they have not already done so, to discuss future options in respect of their OMAs. These options are likely to include wind-up of the OMA and transferring its assets to a master trust, personal retirement savings account (PRSA) or personal retirement bond. The wind-up of these OMAs is a key area of focus as set out in the Pensions Authority's Statement of Strategy 2025-2029.
Introduction of in-scheme drawdown
The Authority is currently consulting on the possibility of introducing "in-scheme drawdown" (ISD) for defined contribution (DC) pension schemes.
The proposed in-scheme drawdown (ISD) arrangement will permit DC scheme members to retain and draw down the balance of their fund within the scheme post-retirement, following the payment of a lump sum. ISD will be optional for schemes and will not replace existing retirement options. The retained balance will constitute a vested retirement benefit.
ISD does not involve guarantees, does not require a separate ring-fenced fund, and the member remains part of the scheme until all assets are drawn down. Trustee obligations continue until the member ceases to hold assets in the scheme.
The consultation closes on 20 January 2026 and the Authority is likely to introduce its proposals for ISD shortly thereafter. The Authority's consultation paper is available here.
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.
