Gender pay gap reporting has been a legal obligation for large Irish employers since 2022. The scheme is phasing in on a stepped basis — each year, the reporting threshold drops, drawing more employers into scope. Understanding where the threshold is in 2026, what reporting involves, and what the consequences of non-compliance are is now a practical requirement for a growing number of Dundalk businesses.
This article — part of our payroll and employment guides — covers the current position clearly, without the jargon that makes employment law unnecessarily inaccessible.
What Is the Gender Pay Gap?
The gender pay gap is the difference between the average earnings of men and women in an organisation, expressed as a percentage of men’s average earnings. It is not the same as unequal pay — paying men and women differently for doing the same work, which is already illegal in Ireland under the Employment Equality Acts.
The gender pay gap reflects a broader structural picture: the distribution of men and women across different levels and roles within an organisation. An organisation might pay men and women equally for equivalent work but still have a significant gender pay gap because more men occupy senior, higher-paid positions and more women occupy junior or part-time roles.
Gender pay gap reporting does not require employers to have a zero gap. It requires them to measure and publish the gap — the underlying belief being that transparency creates accountability and incentivises employers to address structural imbalances over time.
Who Must Report in 2026?
The Gender Pay Gap Information Act 2021 introduced reporting obligations that are being phased in by employer size:
From 2022: employers with 250 or more employees. From 2024: employers with 150 or more employees. From 2025: employers with 50 or more employees.
The 50-employee threshold, which came into effect in 2025 as part of a broader wave of employment law changes in Ireland, means that a significant number of medium-sized businesses in Dundalk and County Louth are now in scope for the first time. If your business employs 50 or more people — on a full-time or combined full-time equivalent basis — you are likely required to report.
For 2026, the threshold remains at 50 employees while the government reviews whether to extend it further to smaller employers. If you are just below the threshold, it is worth monitoring — the direction of travel is clearly toward broader coverage.
What Does a Gender Pay Gap Report Contain?
The report must be published on the employer’s website and includes the following metrics, calculated separately for full-time, part-time, and temporary employees:
The mean (average) gender pay gap — the percentage difference between the mean hourly pay of male employees and the mean hourly pay of female employees.
The median gender pay gap — the percentage difference between the median hourly pay of male and female employees. (The median is generally considered a more reliable measure than the mean because it is less affected by extreme values at either end of the pay scale.)
The mean and median bonus pay gap — comparing the bonus payments received by male and female employees.
The percentage of male and female employees who received a bonus payment.
The percentage of male and female employees who received benefits in kind.
The proportion of male and female employees in each pay quartile — dividing the workforce into four equal groups from lowest-paid to highest-paid and showing the gender split in each.
These figures must be accompanied by a written narrative explaining the reasons for the gaps reported and any measures being taken to address them.
The Snapshot Date and Reporting Timeline
The report is based on a snapshot date each year — the date on which the required data is gathered. The snapshot date is typically in June, and the report must be published within six months of the snapshot date, giving employers until approximately December to publish.
The specific dates are set by regulations under the Act, and employers should confirm the current year’s dates with their HR or legal advisors.
Common Mistakes and Pitfalls
Misunderstanding “employee” headcount. The 50-employee threshold applies to the number of employees, not full-time equivalents in all cases. The legislation and associated regulations specify how headcount is calculated — part-time workers generally count as individuals, not as fractions. This means a business with 30 full-time and 25 part-time employees may be in scope even if the full-time equivalent headcount is lower than 50.
Narrow data collection. The report requires hourly pay data for all employees — which means converting annual and monthly salaries to an hourly rate. For employees with variable hours, complex shift patterns, or significant overtime, this calculation requires careful data collection throughout the reference period.
Ignoring bonus data. Bonus pay is included in the calculation, and the bonus gap is reported separately from the base pay gap. Organisations with predominantly male senior leadership who receive substantial bonuses — and predominantly female support staff who do not — will see this reflected in the bonus gap figures.
Publishing without a narrative. The numbers alone, without explanation and a statement of what the employer is doing to address any gaps identified, are not compliant. The narrative is a legal requirement, not an optional addition.
Not publishing on the employer’s website. The publication must be on the employer’s own website, in a manner that is accessible and clear. Sending the report to the Workplace Relations Commission without publishing it on the website is non-compliant.
Consequences of Non-Compliance
The enforcement mechanism for gender pay gap reporting is the Irish Human Rights and Equality Commission (IHREC), which has power to investigate complaints and seek injunctions from the Circuit Court requiring compliance. The WRC can also receive complaints from employees who believe their employer is not complying.
The reputational consequences of non-compliance — or of publishing a report that reveals a large and unexplained gap — can be significant. In a tight labour market where attracting female talent is a competitive priority for many businesses, gender pay gap reporting is increasingly a matter of employer brand management as well as legal compliance.
What to Do If You’re in Scope
If your business employs 50 or more people and has not yet addressed gender pay gap reporting, the steps are:
Review whether you are in scope. Establish a data collection process that captures hourly pay, bonus, and benefits data for all employees. Calculate the required metrics using the methodology set out in the Act and regulations. Prepare a written narrative explaining the figures and any action being taken. Publish the report on your company website before the deadline.
This is an area where the involvement of your payroll provider and HR advisor is important — and if you are relatively new to managing payroll, our new employer’s guide to Irish payroll covers the foundational setup. The data is sensitive and the calculations need to be consistent year on year to provide a meaningful trend picture.
If you need guidance on whether your business is in scope or how to approach the reporting process, we are happy to help.
Paddy Malone FCA AITI
Paddy is the principal of Malone & Co. Chartered Accountants in Dundalk. A Fellow of Chartered Accountants Ireland and a Chartered Tax Consultant with the Irish Tax Institute, he has been advising businesses across County Louth and the North-East for over 35 years.