Gender pay gap reporting, pay transparency and protected disclosures are creating practical work for employers well beyond the HR department, explains Laura Reidy in a recent webinar.
Employment law changes increasingly require input from payroll, finance and senior management, not just HR.
Three areas deserve particular attention: gender pay gap reporting, the EU Pay Transparency Directive and protected disclosures. For accountants advising businesses, or working within larger organisations, each can have financial and operational implications.
The practical message is straightforward. Employers should understand their current position before a reporting deadline, employee request or workplace dispute exposes a problem.
1. Gender pay gap reporting now reaches more employers
Gender pay gap reporting measures the difference in average pay between men and women across an organisation. It is not the same as assessing whether two people receive equal pay for comparable work.
The reporting requirements have progressively extended to smaller employers. Employers with more than 50 employees were brought within Ireland's reporting requirements in 2025. The reporting process uses a snapshot date in June, with the report due five months later.
Employers need to calculate measures including mean and median hourly pay gaps and examine areas such as bonuses, benefits and pay quartiles.
For finance and payroll teams, producing the figures is only part of the job.
The organisation also needs to understand what sits behind them. For example, a relatively small number of highly paid senior employees can materially affect an organisation-wide average.
That context matters when the figures become public.
Ireland has also introduced a central Gender Pay Gap Information Portal. The Government's published material stated that the portal was voluntary during its 2025 introduction, ahead of a mandatory reporting requirement for employers in scope in 2026.
This makes preparation a data exercise and a communication exercise. Employers need reliable calculations, but they should also be ready to explain what those calculations show.
2. Pay transparency goes further than reporting an average
Gender pay gap reporting and pay transparency are related, but they address different questions.
Gender pay gap reporting examines averages across the workforce. The EU Pay Transparency Directive focuses more directly on equal pay for equal work and work of equal value.
The Directive's transposition deadline was 7 June 2026. Irish Government material has confirmed that work has been under way to transpose Directive (EU) 2023/970 into Irish law.
For employers, preparation should not simply mean waiting for the final Irish legislation.
The Directive introduces significant principles around pay information for job applicants and employees. It also puts greater emphasis on objective, gender-neutral criteria for determining pay and pay progression.
That creates a useful question for employers now: could you explain why two apparently comparable roles are paid differently?
Job titles alone may not provide the answer.
Employers should examine the actual work involved, including responsibilities, skills, qualifications and other objective factors that affect the value of a role. They should also consider the wider reward package rather than looking only at base salary.
Where differences exist, the important issue is whether there is a clear, objective explanation for them.
Start with a pay and benefits audit
A practical first step is to review existing pay and benefits before greater transparency creates questions from employees.
Map the roles within the organisation. Compare pay levels and benefits. Look for differences between roles that may involve equal or comparable work.
Where there is a difference, document why it exists.
Employers should also examine how people progress through salary ranges. If additional responsibility, qualifications or experience result in higher pay, employees and managers need to understand those criteria.
Recruitment processes will need attention too. The Directive creates pay-information rights for job applicants, so organisations should prepare for greater transparency around the remuneration attached to vacancies.
The heavier work, however, may be establishing a defensible framework behind existing pay decisions.
For accountants and finance teams, that means pay data cannot always remain an isolated payroll issue. It may need to connect with HR policies, job structures, benefits and management decision-making.
3. Protected disclosures need to be recognised early
Protected disclosures present a different type of employment law risk.
Under Ireland's Protected Disclosures legislation, workers who report relevant wrongdoing in a work-related context can receive statutory protection against penalisation. Relevant wrongdoing can include criminal offences and failures to comply with certain legal obligations.
Importantly, employers should not assume that somebody needs to formally announce that they are making a protected disclosure.
Reports can be made orally as well as in writing. That means a concern raised with a manager or supervisor could require attention even when the employee has not used legal terminology.
This makes manager awareness particularly important.
A supervisor hearing an employee raise concerns about health and safety, regulatory compliance or another potential wrongdoing needs to recognise when the issue may require escalation.
Internal reporting arrangements matter as well. Organisations with 50 or more employees are generally required to establish internal reporting channels and procedures. Certain organisations covered by specified EU rules, including areas such as financial services and anti-money laundering, have additional requirements regardless of size.
For accountancy firms, that makes protected disclosures particularly relevant where an employee raises concerns about legal or regulatory compliance.
Do not leave these issues until there is a dispute
The common thread across these three areas is preparation.
For gender pay gap reporting, employers need accurate data and an explanation of what the figures mean.
For pay transparency, they need to understand how pay decisions are made and whether differences can be objectively explained.
For protected disclosures, managers need to recognise concerns early and know where to escalate them.
None of that starts with a tribunal claim or reporting deadline. It starts with reviewing the information, processes and decisions already inside the organisation.
For accountants working alongside HR teams, that creates a clear role: make sure the underlying data is reliable, identify unexplained differences and ensure employment-related financial information can withstand greater scrutiny.
FAQs
What is the difference between the gender pay gap and equal pay?
The gender pay gap measures the difference in average pay between men and women across an organisation. Equal pay concerns whether people receive equal pay for equal work or work of equal value. An employer can therefore have an overall gender pay gap without that automatically demonstrating an equal pay breach.
Which Irish employers have to report their gender pay gap?
Ireland’s gender pay gap reporting requirements have progressively extended to smaller employers. Employers with more than 50 employees were brought within the reporting requirements in 2025. Employers should check the current reporting rules, including applicable employee thresholds and submission requirements, before preparing their report.
When is gender pay gap reporting due in Ireland?
Employers in scope select a snapshot date in June and report their gender pay gap information five months later. The process involves more than calculating a headline percentage: employers need to consider measures including mean and median hourly pay gaps, bonuses, benefits and pay quartiles.
What is the EU Pay Transparency Directive?
The EU Pay Transparency Directive is intended to strengthen the application of equal pay principles. It introduces greater transparency around pay information for job applicants and employees and places greater emphasis on objective, gender-neutral criteria for determining pay and pay progression. Ireland is required to transpose the Directive into national law.
Is pay transparency the same as gender pay gap reporting?
No. Gender pay gap reporting examines average differences in pay between men and women across an organisation. Pay transparency goes further into how individual jobs are valued and how remuneration decisions are made. Employers therefore need to consider whether differences between comparable roles can be explained using objective criteria.
How should Irish employers prepare for greater pay transparency?
A practical starting point is a review of current pay, benefits and job structures. Employers can map comparable roles, identify differences in remuneration and document objective reasons for those differences. They should also review salary progression criteria and recruitment processes so managers can explain how pay decisions are made.
What should employers include in a pay and benefits audit?
Employers should examine roles, responsibilities, skills, qualifications, salary levels and relevant benefits. They should then identify potentially comparable work and investigate unexplained differences. The objective is to establish whether remuneration decisions can be supported by clear and consistent criteria.
What is a protected disclosure in an Irish workplace?
A protected disclosure involves a worker reporting relevant wrongdoing encountered in a work-related context. Depending on the circumstances, wrongdoing can include criminal offences or failures to comply with certain legal obligations. Employers need procedures for recognising, receiving and appropriately handling qualifying reports.
Does an employee have to call something a protected disclosure for it to qualify?
No. Employers should not rely on an employee using the words “protected disclosure” or “whistleblowing”. Reports can also be made orally. Managers therefore need to recognise when an employee’s concern could potentially fall within protected-disclosure legislation and know how to escalate it appropriately.
Which employers need an internal protected-disclosure reporting channel?
Organisations with 50 or more employees are generally required to establish internal reporting channels and procedures. Certain organisations operating in specified regulated areas can have obligations regardless of workforce size. Employers should check how the legislation applies to their organisation rather than relying on employee numbers alone.
Why do protected disclosures matter to accountants and finance teams?
Concerns about financial practices, regulatory compliance or other legal obligations can potentially arise within finance functions. Accountants in practice may also encounter these issues when advising employers. Clear internal procedures help managers identify concerns and route them appropriately rather than treating every workplace complaint in the same way.
What should employers do now about these employment law changes?
The common starting point is to review existing information and processes. Employers can check the reliability of gender pay gap data, examine how pay differences are justified, review recruitment and salary-progression practices, and ensure managers understand protected-disclosure procedures. This preparation can identify weaknesses before a reporting requirement, employee request or dispute brings them to the surface.
The contents of this article are meant as a guide only and are not a substitute for professional advice. The authors accept no responsibility for any action taken, or refrained from, as a result of the material contained in this document. Specific advice should be obtained before acting or refraining from acting, in connection with the matters dealt with in this article.
