EU Pay Transparency Directive Implementation in Ireland

Quick Hits

• All EU member states are required to transpose the EU Pay Transparency Directive into national law by 7 June 2026.
• Ireland currently proposes to introduce substantial changes to existing obligations under the Employment Equality Acts and the Gender Pay Gap Information Act 2021.
• Department of Children, Disability and Equality officials are currently developing a General Scheme to transpose the remaining elements of the directive into Irish law.
• Ireland recently indicated that it is unlikely to transpose the directive by 7 June 2026.

As the 7 June 2026 deadline approaches, it is becoming increasingly clear that many EU member states will not complete transposition on time. Ireland is among those that have already signalled a delay, with official parliamentary materials confirming that legislation to transpose the remaining elements of the directive is still being developed.

Against that background, the Department of Children, Disability and Equality (DCDE) has indicated that employers will not be penalised for not having all elements of the directive completed in June 2026. However, employers that fail to prepare now for implementation may find themselves inadequately prepared and at risk for noncompliance with the directive’s requirements as they are rolled out.

The directive aims to strengthen the principle of “equal pay for equal work or work of equal value.” Employers will be required to disclose the starting salary or salary range for a role in the job advertisement (this is more prescriptive than the directive). Employers will no longer be permitted to ask candidates about their previous pay history. These measures are designed to prevent historical pay inequalities from being carried forward and to ensure that salary decisions reflect the value of the role rather than an individual’s past earnings.

The directive also strengthens employees’ rights to access pay information. Employees will be entitled to request details of their own pay level as well as the average pay levels of colleagues performing the same work or work of equal value, broken down by gender. Employers must ensure that any pay differences can be objectively justified.

The European Union’s European Institute for Gender Equality (EIGE) is currently introducing a draft toolkit for gender-neutral job evaluation and classification. The DCDE is expected to hold workshops in 2026 to assist employees in carrying out job evaluation assessments.

In Ireland, employers with fifty or more employees are already required to report on their gender pay gap. The directive takes this further, introducing more detailed reporting categories and a phased timeline, with organisations with 150 or more employees required to report every three years and organisations with 250 or more employees required to report annually from 7 June 2027. Employers with one hundred or more employees will be required to report annually by 7 June 2031.

Employers are encouraged to stay informed about the implementation process in their respective jurisdictions. Information and updates on the progress of the directive’s implementation across the European Union can be found using Ogletree Deakins’ Member State Implementation Tracker.

Further information can also be found by listening to our podcast, “Understanding the EU Pay Transparency Directive: What Employers Need to Know.”

Ogletree Deakins’ London office, Pay Equity Practice Group, and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Cross-Border, Pay Equity, and Workforce Analytics and Compliance blogs as additional information becomes available.

Daniella McGuigan is a partner in the London office of Ogletree Deakins and co-chair of the firm’s Pay Equity Practice Group.

Lorraine Matthews, a practice assistant in the London office of Ogletree Deakins, contributed to this article.

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