Ireland missed the 7 June 2026 transposition deadline for the EU Pay Transparency Directive. This does not mean the Directive is not coming. The European Commission confirmed on 22 May 2026 that it will not delay or simplify the Directive, and member states will be required to transpose all elements.

When can we expect to see transposition of the Directive?

There is no confirmed date yet. Current expectation is that draft legislation may appear later this year, with the more substantial obligations, meaning everything beyond the recruitment stage, unlikely to commence before 2027. We will update clients when we get confirmation.

Will it apply to me?

Gender Pay Gap reporting already applies to employers with 50 or more employees. You pick a snapshot date in June to report on all staff captured on payroll that day, and publish a report with a November deadline.

Some elements of the Pay Transparency Directive are expected to apply to all employers, regardless of size, for most obligations, including recruitment transparency, pay secrecy clauses, the right to request pay information, and the shift in the burden of proof.

Enhanced reporting obligations are the only element specifically set out for employers with 150 or more employees. We cannot confirm this with absolute certainty until we see the final Irish legislation.

Pre-employment likely to be the first phase of transposition

How should you prepare?

• Audit your contracts and review any pay secrecy provisions that restrict employees from discussing pay to establish whether they are being paid fairly. HRDuo clients can access updated template contract language in the HR Content Hub.
• Review recruitment processes, interview guides, and application forms to ensure salary history information is not being requested.
• Document salary ranges for all roles. These will need to be approved before recruitment begins, not at the offer or negotiation stage.
• Review structures: if pay differences exist between comparable roles and you cannot objectively justify them, now is the time to address them. Start documenting the rationale behind all pay decisions.
• Publish your Gender Pay Gap report by November 2026 if you have 50 or more employees. HRDuo clients can access this under Manager/Reports/PayGapReport.

Can I ask a candidate about their salary expectations?

When the recruitment transparency provisions are transposed into Irish law, employers are expected to be prohibited from asking candidates about their current or previous pay history.

In the interim, the safest approach is to lead with your approved salary range rather than asking candidates what they expect.

Do I need to include salary in a job advertisement?

The Directive requires applicants to receive information about the pay level or pay range before the interview. Draft Irish legislation may go further and require salary ranges to be included in job advertisements, but this is not yet confirmed. Start by ensuring salary ranges are documented and approved before any recruitment begins.

If the Directive has not been transposed, is it enforceable?

The practical enforcement of employee rights under the Directive will depend on the Irish legislation transposing it. However, the concepts and principles within the Directive may begin to influence how equal pay cases are decided at the WRC and Labour Court.

Existing equality exposure under the Employment Equality Acts also remains, and employers should continue to ensure pay decisions can be objectively justified.

Consider Your Job Architecture

Job architecture — what is it and do I need it?

Job architecture is the foundation on which almost everything else in the Directive sits. Without it, you may find it more difficult to respond accurately to right-to-information requests, report by category of worker, or defend pay decisions if challenged.

It involves documenting job descriptions for every role, evaluating roles consistently against objective criteria, grouping roles into job families, and setting documented salary bands.

The European Commission and EIGE published a practical toolkit in March 2026 to support employers with this process. Each Member State is also expected to publish national guidance and run employer workshops. Given that Ireland has missed the transposition deadline, we do not yet have clarity on timing.

The HRDuo platform currently supports gender pay gap reporting. We have also updated our contract templates to remove pay secrecy clauses, which are now available in the HR Content Hub. We will continue to update our content library, templates, and platform as the Irish legislation develops, and we will keep clients informed at every stage.

Possible second phase of transposition

• Right to Request Pay Information
• Objective pay and pay progression criteria, shared with employees
• Enhanced reporting obligations for 150+ employees
• A Joint Pay Assessment where reporting reveals an unjustified gap of 5% or more within a category of workers
• Shift in the burden of proof

What should I tell an employee who is now requesting pay information?

Until the Directive is transposed, there is no specific statutory right for employees to request pay information under the Directive. Employers should, however, continue to comply with existing obligations under equality and data protection legislation.

We recommend starting to build the processes and data foundations needed to respond accurately and consistently when the obligation does apply.

Will employees be able to find out what their colleagues earn?

No. The Directive does not give one employee the right to see a named colleague’s pay. The right to request covers an employee’s own pay level and the average pay for their category of worker, broken down by gender.

Individuals cannot be identified from the figures you provide. Once the right applies, you will have a set period to respond, expected to be up to around two months, though the final Irish timeframe is not yet confirmed.

What if I have a pay gap of over 5% that I cannot justify?

If a pay gap exists that you cannot objectively justify, the time to address it is now.

Once the Directive is transposed and reporting obligations apply, an unjustified gap of 5% or more within a category of workers can lead to a formal joint pay assessment with employee representatives.

How does this work for a group of companies?

Each legal entity will generally be treated as a separate employer for the Directive. The Directive sets minimum standards, but each member state transposes it into its own national law, and those laws will differ on timing, thresholds and detail, for example, whether salary must appear in a job advert.

Each entity must comply with the law of the country in which it operates, so obligations can vary from one part of the group to another. How Irish group structures are treated will depend on the final Irish legislation, and we will update clients as this becomes clearer.