EU Pay Transparency
The EU Pay Transparency Directive was adopted in 2023 and requires member states to transpose it into national law by 7 June 2026. The Directive goes over and above Ireland’s current Gender Pay Gap reporting regime and introduces new obligations for employers right across the EU.
Key elements of the Directive include:
- Pay transparency before hiring: under the directive, job advertisements must include a salary range, and employers cannot ask candidates about their pay history. This is something to be mindful of during the interview stage in particular or where you have job application forms online.
- Right to pay information: Employees will have the right to request information about average pay levels by gender for staff doing the same work or work of equal value. Retaining accurate records will be critical.
- Gender pay gap reporting: Organisations with 100 or more employees will be required to report on their gender pay gap, with enhanced detail compared to current Irish requirements.
- Joint pay assessments: Where a reported pay gap of 5% or more cannot be justified, employers will be required to carry out a joint pay assessment with employee representatives – a potentially significant and time-consuming exercise.

Transposition of the Directive in Ireland
Given it is now 21st May 2026, Ireland is unlikely to transpose the EU Pay Transparency Directive into Irish law by the 7 June 2026 deadline and this is the same across many EU member states, where the legislative process has not kept pace with the deadline.
This is not unusual and transposition delays are relatively common, so it is nothing to be concerned about but it also does not change the direction of travel. Heavier legislation is on the way and companies should be prepared for it. The question is when will the directive be transposed, not if. Irish employers should not treat the delay as an excuse to defer preparation for the change. We recommend using this period to examine your current reporting and data available, so that you can make improvements ahead of the law coming into force.

