Gender Pay Gap Reporting Ireland 2025: Employer FAQ and Step-by-Step Compliance Guide

Need help finalising your Gender Pay Gap (GPG) report? If your organisation has 50 or more employees, you’re legally required to publish a Gender Pay Gap report in 2025.

Below you’ll find straightforward answers to the most common, practical questions: who to include, what counts as pay, and how to publish correctly.

Watch our Masterclass recording: Gender Pay Gap Reporting 2025.

Who must report - and when?

All Irish employers with 50 or more employees on their chosen snapshot date in June 2025 must report their Gender Pay Gap data.

• Snapshot date: Any date in June 2025

• Deadline: Publish your report within five months of that snapshot date (e.g., 1 June → 1 November; 30 June → 30 November 2025)

• Retention: Keep your report publicly accessible for three years

• Where to publish: On your company website and, once required, upload to the State’s Gender Pay Gap reporting portal

These timelines reflect the updated 2025 Employment Equality (Pay Transparency and Gender Pay Gap Information) Regulations, which shortened the reporting window from six to five months.

Who should be included in the data?

Include all employees employed by your organisation on your chosen snapshot date, even if they are on leave or not rostered to work that day.
Use their remuneration for the 12 months preceding the snapshot date to calculate pay metrics.

Do not include:

• Employees who left before the snapshot date

• Agency staff who are paid by a third-party employer

• Contractors who invoice on a business-to-business basis

Tip: Headcount includes all full-time, part-time, and fixed-term employees directly employed and paid by you.

What counts as pay - and what doesn’t?

Ordinary Pay — Include:

These are regular payments and taxable allowances relating to employment.

• Basic salary or hourly wages

• Allowances such as recruitment, retention, or relocation allowances

• Overtime or shift premiums, if part of normal remuneration

• Pay for piecework

• Pay for sick leave

• Employer top-ups to statutory leave (maternity, paternity, parental, adoptive leave)

• Fixed taxable travel or subsistence allowances that form part of salary

• Pay for Garden Leave

Include these only if they are processed through payroll as taxable income.

Ordinary Pay — Exclude:

• Payments or benefits that are not remuneration for work done.

• Benefit-in-kind (BIK) — e.g., company car, healthcare

• Reimbursement for expenses e.g. travel and subsistence

• Redundancy payments or ex gratia severance payments

• Payments in lieu of leave or expenses payments
  
  

If it’s a reimbursement or non-taxable benefit, do not include it.

Bonus Pay — Include:

Bonus pay is bonuses related to performance, productivity, incentive or commission during the reporting period.

• Payments in the form of money

• Securities

• Vouchers

• Securities options

• Interests in securities, or, which relate to profit sharing, productivity, performance, incentive or commission

Bonus Pay — Exclude:

Items that do not meet the definition of remuneration or fall outside the reporting window.

•  Bonuses paid outside the 12-month reference period

Tip: Bonuses should be calculated before deductions at source

Total Remuneration

Total of ordinary pay + bonuses.

How to Handle Special Cases

Certain employee situations need a little extra care when preparing your report.

Follow these rules to stay compliant and consistent.

Employees on leave:

Count anyone on paid or unpaid leave (maternity, paternity, parental, sick, or annual) who is still employed on the snapshot date.

Use actual pay received in the previous 12 months, including any employer top-ups to statutory leave.

Example:
If an employee worked 3 days per week for 6 months due to parental leave, their total pay should be calculated based on actual hours worked in that period.

Backpay:

• Include backpay that was paid during the 12 months before your snapshot date, even if it relates to earlier work.

• Exclude backpay from previous reporting periods that was not actually paid in the current 12-month window.
  

Mid-year joiners or leavers:

Include only employees who are still employed on the snapshot date. Use the actual pay and hours they worked since they joined your organisation.

Part-time and temporary workers:

Include all part-time, temporary, and fixed-term employees employed on your snapshot date.
Use actual hours worked, not contracted hours.
If workforce composition skews results (e.g. mostly female part-time staff), explain this in your narrative.

Cross-border or split-payroll employees:

Include employees paid by your Irish entity through an Irish payroll, even if they work abroad.  Exclude employees paid entirely from a non-Irish payroll to avoid double counting.

Contractors and agency staff:

Report only individuals employed directly by your organisation.

• Agency workers are reported by the agency that pays them.

• B2B contractors or consultants are excluded unless they’re on your payroll as employees. 

How do we calculate the Gender Pay Gap?

1. Collect payroll data for all employed on your snapshot date, covering the previous 12-month period

2. Separate ordinary pay and bonuses.

3. Calculate gross hourly pay: divide total pay by total hours worked.

4. Work out the mean and median gender pay gaps for both hourly and bonus pay: mean, median, % differences.

5. Work out the mean and median gender pay gaps for employees on temporary contracts and part time hours for hourly and bonus pay: mean, median, % differences.

6. Calculate the percentage of men and women receiving bonuses.

7. Calculate the percentage of men and women receiving BIK

8. Determine gender distribution across quartiles (lower, lower-middle, upper-middle, upper).

9. Prepare your narrative explanation - why the gap exists and what actions you’re taking.
   

Gender Pay Gap reporting isn’t just a compliance task, it’s an opportunity to track progress and strengthen your organisation’s approach to equality.

By keeping clear records of your data, calculations, and narrative, you’ll make future reports smoother and more meaningful.

If you’re preparing your report or doing it for the first time, you can get step-by-step support in our Gender Pay Gap Reporting Masterclass Recording 2025.

More Frequently Asked Questions (FAQs)

Q: Should we include employees who left before the snapshot date?
A: No. Only include employees employed on your snapshot date using their previous 12 months’ remuneration.

Q: How do we handle employees on parental leave?
A: Use actual pay for hours worked within the previous 12-months, including any employer top-ups, not contracted hours.

Q: Employees paid hourly vs salary – how do we report?
A: Use actual pay and hours. Highlight if hourly workers skew results.

Q: How about contractors and casual workers?
A: Only include if they are on payroll.

Q: Bonuses – include gift cards or commissions? A: Include cash bonuses and commissions

Q: Split roles across Ireland and UK – what to report?
A: Report only the Irish payroll portion. Do not double-count the salary.

Q: Does the Gender Pay Gap report need to be published on our website?
A: Yes, the report must be published on your company website and uploaded to the State portal once required - unless you don’t have a website, then you need to have a physical version of the report available at its registered offices and available to public and to employees.

Q: Should we include social welfare top-ups?

A: Include only the top-up paid by the employer as part of remuneration.