The Gender Pay Gap Act was signed into law in 2021 and began in 2022 for organisations with 250+ employees. From 2025 it applies to organisations with 50+ employees. Under the Act, employers are required to publish gender pay differences using 20 different metrics mainly to do with average and median rates of pay and bonus payments.
The report is based on a snapshot date in June and the pay in the preceding 12 months. The June snapshot date is selected by the employer. All employees employed on the snapshot date should be included apart from an employee who does not identify as male or female, who can be excluded from the report.
The employer is also required to explain any negative pay gaps and how they intend to address them. Further changes are coming with the EU Pay Transparency Directive to be introduced in Ireland by June 2026.
Employers are required to publish the Gender Pay Gap report on the company website and upload it to a portal within 5 months of the snapshot date. The portal is currently under development by the Department of Children, Equality, Disability and Integration.
The Act refers to organisations which is relevant for employers with more than one company.
Additional information is available by clicking on the following links:
- The Gender Pay Gap Act, the official guidelines and the 2 addendums to the act: https://assets.gov.ie/static/documents/Guidance_Note-updated_2025.pdf
- The 2024 CSO stats on Irelands Gender Pay Gap: https://www.cso.ie/en/releasesandpublications/cp/gpg/csogenderpaygapreport2024/
How do I Approach Gender Pay Gap Reporting:
We have highlighted some of the main points worth noting and have broken it down into the steps involved.
Please note this is an overview of what is required not a comprehensive list of all payments for inclusion. When calculating the metrics for the report it is important to follow all the requirements in the Gender Pay Gap Act, which is linked to above.
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Step 1: Select a snapshot date in June 2025. We suggest the last Sunday in June is a good date to use. If you have 50 or more employees on that date a Gender Pay Gap report should be completed.
a. Within 5 months of the snapshot date:
(1) the report should be published on your company website and
(2) it should be uploaded to a portal currently under development by the Department of Children, Equality, Disability and Integration. The portal is likely to be ready in September.
b. The report should include:
(1) some metrics as outlined below,
(2) a general summary, and
(3) an explanatory note if you have any negative pay gaps.
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Step 2: Prepare a list of all your employees employed on the snapshot date, noting:
a. The part time employees.
b. Employees on a temporary contract.
c. The gender of each employee – where an employee does not identify as male or female they can be excluded from the report.
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Step 3: From your payroll software you need pay information for the 12 months up to your snapshot date split into the following 4 items:
a. Total Ordinary Pay: include overtime, bonus, premiums…. and exclude expenses, travel saver pass, bike to work… Note: where a payment is for a period outside the calculation period, the payment should be excluded, example, a bonus payment paid in July 2024 for the previous year should be excluded.
b. Total Bonus Payment: include commission, incentive schemes, small benefit payments (gift cards etc.).
c. Total Benefit in Kind.
d. Total hours.
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Step 4: Calculate an hourly rate of pay for all employees.
a. The calculation is:Â Ordinary Pay / hours = hourly rate of pay (see step 3)
b. For employees who recently started or unpaid in the calculation period the hourly rate is a rate that fairly represents what they would expect to be paid in a year.
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Step 5: Calculate the relevant metrics for the GPG report:
a. The mean difference between:
– The hourly rate of pay of all male and female employees.
– The hourly rate of pay of part-time male and female employees.
– The hourly rate of pay of temporary contract male and female employees.
– The bonuses paid to male and female employees, excluding employees with a zero bonus.
Calculation for all the above it is (male € – female €) / male €
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b. The median difference between:
– The hourly rate of pay of all male and female employees.
– The hourly rate of pay of part-time male and female employees.
– The hourly rate of pay of temporary contract male and female employees.
– The bonuses paid to male and female employees, excluding employees with a zero bonus.
Calculation for all the above it is (male € – female €) / male €
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c. The percentage differences:
– The bonuses paid to male and female employees, excluding employees with a zero bonus.
Calculation (1) number of male employees / number of male employees paid a bonus and (2) number of female employees / number of female employees paid a bonus
– The Benefit in Kind payments to male and female employees, excluding employees with a zero BIK.
Calculation (1) number of male employees / number of male employees paid bik and (2) number of female employees / number of female employees paid a bik
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d. Quartiles – sort the employees from lowest to highest hourly rate of pay. The first 25% of the employees are in Quartile 1, the next 25% in Quartile 2…
– The split of male and female in Quartile 1 (low).
– The split of male and female in Quartile 2.
– The split of male and female in Quartile 3.
– The split of male and female in Quartile 4 (high).
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Step 6: Write your Gender Pay Gap Report including:
a. The metrics from Step 5.
b. An explanatory note on any negative numbers.
c. Some general commentary on the report is advisable.
In Summary
Gender Pay Gap Reporting is here, and unavoidable. We are seeing many clients who are now required to comply with these reporting requirements and are struggling to understand how they should go about preparing their report and generating their data sets. Payroll software providers have yet to develop reporting functionality which will result in the majority of employers having to undertake manual calculations, adjustments and alterations.
We encourage anyone unsure about Gender Pay Gap Reporting to get in touch with their local Xeinadin office for assistance and guidance.
