The implementation of the EU Pay Transparency Directive (the Directive) forms part of the EU’s broader strategy to strengthen the application of the principle of equal pay for equal work, or work of equal value, between men and women through enhanced pay transparency and enforcement mechanisms. The deadline for Member States to transpose the Directive is 7 June 2026. However, the Government has indicated that it may not meet full implementation by this date and instead intends to introduce the required measures on a phased basis. While the Government has missed the transposing date, employers are best advised to have regard to the terms of the Directive from that date.
Key Measures Introduced by the Directive
The Directive introduces new obligations for employers, some of which have already been partially reflected in existing Irish law. Under the new framework, employers will face increased requirements to disclose salary information and justify differences in pay, affecting both recruitment practices and internal pay structures.
1. Salary Transparency
Employers will be required to disclose the initial pay level or pay range for job applicants prior to employment. This is intended to ensure that candidates can make informed decisions and negotiate fairly from the outset. In addition, employers will no longer be permitted to ask candidates about their current or previous salary.
2. Employee Rights to Pay Information
Workers will benefit from enhanced rights to request, in writing, information on their individual pay and the average pay levels of others performing the same work or work of equal value, broken down by gender. As such, organisations must have transparent pay structures that clearly demonstrate equal pay for equal work or work of equal value. Employers must provide this information within two months of receiving a request and will also be required to remind employees annually of this entitlement to receive such information.
3. Ban on Pay Secrecy
Employers will be prohibited from including contractual clauses that prevent employees from disclosing information about their pay.
4. Gender Pay Gap Reporting
Gender pay gap reporting obligations have been in place in Ireland since 2022 and currently apply to employers with 50 or more employees. The Directive expands upon these requirements by introducing more detailed reporting across “categories of workers” performing the same work or work of equal value. This includes analysis of both basic salary and additional or variable compensation. These enhanced reporting obligations will be introduced on a staggered basis between 2027 and 2031.
5. Joint Pay Assessments
Where gender pay gap reporting reveals a gap of 5% or more that cannot be justified by objective, gender-neutral factors and is not remedied within six months, employers will be required to undertake a joint pay assessment in cooperation with employee representatives.
Conclusion
The Directive represents a significant shift toward greater transparency, accountability and fairness in European workplaces. Despite the absence of fully implemented legislation in Ireland, the Government has indicated that certain provisions – particularly those relating to recruitment practice, may be introduced first.
As a result, while June 2026 remains the formal EU deadline, full implementation in Ireland may extend beyond that date. Employers should immediately review their hiring practices, pay structures, job grading systems, and reporting processes to ensure compliance with the transparency requirements of the Directive.
As transparency becomes a legal requirement rather than a voluntary practice, the Directive is expected to have a lasting impact on workplace equality, recruitment practices, and organisational culture across Ireland and the wider EU.
For more information on this topic, please contact either Niamh Shanahan, Associate or David Pearson, Consultant, of our Employment Team.