EU Pay Transparency Directive: What Irish Employers Need to Do Before June 2026
As the 7 June 2026 deadline for the EU Pay Transparency Directive (Directive (EU) 2023/970) approaches, Irish employers are facing a complex and evolving legislative landscape. Although the Government has confirmed that Ireland will miss the formal deadline for full transposition, key elements will still begin to take effect on a phased basis under existing and upcoming legislation.
Ireland already has gender pay gap reporting obligations under the Gender Pay Gap Information Act 2021, which will sit alongside new recruitment transparency rules and, later, broader pay transparency rights. Together, these measures will significantly raise expectations on employers to provide clear, objective and gender‑neutral pay structures.
Will Ireland meet the June 2026 deadline?
The Department of Equality has indicated that Ireland will not have every aspect of the EU Pay Transparency Directive fully implemented by 7 June 2026. Instead, the Government has opted for a staged approach, splitting the reforms into two main pieces of legislation:
Updates to existing equality law via the Equality (Miscellaneous Provisions) Bill, which will cover recruitment and pre‑employment transparency.
A separate “Pay Transparency Bill”, still in development, which is expected to address broader employee rights to pay information, equal pay audits and enforcement mechanisms.
Crucially, the Department has also clarified that employers will not be “penalised” simply because the State itself has missed the transposition deadline. However, that does not mean employers can safely ignore the Directive until everything is in place.
What changes are coming for June 2026?
The first phase of Ireland’s pay transparency update focuses on recruitment and pre‑employment practices. Under the Equality (Miscellaneous Provisions) Bill, the following requirements are expected to apply:
Mandatory salary ranges: Employers will have to include a starting salary or a clear pay range in all job advertisements, or provide this information to candidates before the first interview.
Ban on salary history questions: Employers will be prohibited from asking candidates about their current or previous pay, bonuses or wider remuneration during the hiring process.
Gender‑neutral criteria: Job descriptions and pay structures must be based on objective, gender‑neutral factors such as skills, qualifications, responsibility and experience, rather than assumptions linked to gender.
No pay secrecy in recruitment: Employers should ensure that their recruitment policies and templates do not discourage candidates from discussing pay, and that hiring managers understand the shift towards openness.
These changes align Irish recruitment practice with the core goals of the Directive which are to prevent historical pay inequality from following candidates between roles, and to make pay decisions more transparent from the very start of the employment relationship.
What new rights will workers gain?
As the broader Pay Transparency Bill is introduced, Irish workers can expect a wider set of rights that reflect the full scope of the EU Pay Transparency Directive. While the exact Irish drafting is still awaited, employers should prepare for:
Right to pay information: Employees being able to request information on their individual pay and the average pay levels, broken down by gender, for workers doing the same work or work of equal value.
Ban on pay secrecy clauses: Contractual clauses that prevent employees from discussing their pay are likely to be restricted or prohibited, reinforcing a culture of openness.
Objective pay-setting and progression criteria: Employers will be expected to define and document gender‑neutral criteria for setting pay and granting increases or promotions.
Equal pay audits when gaps persist: Where gender pay gaps above a certain threshold persist within categories of workers and cannot be objectively justified, employers may be required to carry out joint pay assessments or equal pay audits.
These rights build on, rather than replace, existing obligations under the Gender Pay Gap Information Act 2021, which already requires many employers to publish annual gender pay gap figures and supporting narratives.
Will there be penalties for missing the June 2026 deadline?
The Department of Equality has stated that Irish employers will not face immediate penalties simply because the State has not fully transposed the Directive by 7 June 2026. This reflects the Government’s decision to phase implementation through multiple bills and to prioritise more complex measures, such as equal pay audits and expanded enforcement powers, for later.
However, employers should not assume that there is no risk at all until every detail is transposed. Under EU law principles, an Irish worker with a valid claim that falls within the scope of the Directive could, in certain circumstances, seek to rely on its provisions and may ultimately be entitled to have compensation backdated to the 7 June 2026 deadline. In practice, enforcement pressure is likely to come from a mix of individual claims, trade union activity, reputational scrutiny and the continuing requirements of existing equality and gender pay gap legislation.
Preparation steps for Irish employers
At Bridgit, we are working with clients across sectors to get ready for the EU Pay Transparency Directive and the upcoming Irish legislation. Our consistent advice is that HR, Reward and Legal teams should begin auditing pay structures and recruitment practices now, rather than waiting for every regulation to be finalised. Practical preparation steps include:
Define “categories of workers”: Group roles by “work of equal value” using factors such as skills, responsibility and working conditions, so you can respond to future data requests and interpret gender pay gaps in a meaningful way.
Audit pay structures: Review current pay bands, starting salaries and pay progression rules to identify unexplained gaps between men and women in the same category of workers. Document objective, gender‑neutral criteria used for pay decisions.
Remove pay secrecy: Review employment contracts and handbooks to remove or revise clauses that prevent employees from discussing their pay, and update policies to reflect a more transparent approach.
Update recruitment processes:
Ensure all Irish job adverts include clear salary ranges or starting salaries.
Remove salary history questions from application forms, interview guides and recruiter scripts.
Train hiring managers and recruiters so they understand they can no longer “anchor” offers to a candidate’s previous pay and must instead work within defined internal ranges.
Prepare for information requests: Assess whether your HR and payroll systems can quickly produce accurate data on individual pay and average pay levels by gender for each category of workers. Plan how you will verify, approve and share that information with employees.
Strengthen governance and ownership: Assign clear responsibility for pay transparency compliance across HR, Reward, Legal and Finance, and build a roadmap that anticipates equal pay assessments or audits, rather than reacting under time pressure later.
At Bridgit, our platform helps employers map categories of workers, analyse pay gaps, prepare for employee information requests and generate the documentation they will need as Ireland rolls out the Pay Transparency Bill. For organisations already reporting under the Gender Pay Gap Information Act 2021, this is a natural next step towards a more transparent, data‑driven approach to pay.