Ireland's Implementation of the EU Pay Transparency Directive Faces Delays

The Irish government has confirmed that the Directive will be introduced in stages, and several parts of the legislative framework are still under development.

Partial Implementation Through Existing Legislation

Ireland already has legislation in place addressing gender pay gaps, most notably the Gender Pay Gap Information Act 2021. Under this legislation, employers in Ireland are already required to report on gender pay gaps.

However, the EU Pay Transparency Directive introduces a broader range of obligations than those currently required under Irish law. As a result, additional legislation will be necessary for Ireland to fully comply with the Directive.

What Has Been Proposed So Far?

In January 2025, the Irish government published the Equality and Family Leaves (Miscellaneous Provisions) Bill 2024. The proposal includes measures intended to implement Article 5 of the EU Pay Transparency Directive, which concerns pay transparency prior to employment.

Salary Information in Job Advertisements

Under the proposal, employers would be required to include salary information or salary ranges in job advertisements. The aim is to ensure that candidates receive clear information before salary negotiations begin.

Ban on Questions About Previous Pay

The proposal would also prohibit employers from asking job applicants about their current or previous salary. This is intended to reduce the risk of historical pay discrimination being carried forward into new employment relationships.

What Is Still Missing?

Several key elements of the Directive have not yet been implemented in Irish law, including:

• the right for employees to request information about their own pay and average pay levels for workers performing the same work or work of equal value;

• requirements for objective and gender-neutral criteria governing pay setting and career progression;

• rules concerning pay secrecy and employees' right to discuss pay;

• expanded pay reporting obligations;

• joint pay assessments where unexplained pay gaps of at least 5% are identified;

• enhanced rules on burden of proof and sanctions.

These remaining provisions are expected to be addressed through a separate Pay Transparency Bill, but no comprehensive draft legislation has yet been published.

Status: What Happens Next?

Ireland is unlikely to have a complete legal framework in place by 7 June 2026. Instead, the government has indicated that implementation will take place gradually.

This means that employers in Ireland should closely monitor developments. Certain provisions, particularly those relating to recruitment practices, may be introduced first, while more extensive obligations concerning pay reporting, access to pay information, and job evaluation may follow later.

What Does This Mean for Employers in Ireland?

Although the final legislation has not yet been adopted, employers should begin preparing now. Recommended actions include:

• reviewing salary ranges and considering how they can be incorporated into job advertisements;

• removing salary history questions from recruitment processes;

• assessing existing pay structures;

• documenting criteria used for pay setting and career progression;

• identifying roles that constitute the same work or work of equal value;

• preparing systems for expanded pay reporting obligations;

• analysing and addressing unexplained pay gaps.

Organisations that begin preparing now will be better positioned to comply when Ireland's full pay transparency framework is introduced.

Read more about the implementation of the Directive here.