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Employers to Begin Mandatory Reporting of Gender Pay Gap Information for the First Time

The Gender Pay Gap Information Act 2021 (“the Act”) came into force on 31st May 2022. The Act amends the Employment Equality Act 1998 and aims to ensure greater transparency regarding differences in the remuneration of employees by reference to gender.

In order to achieve this, the Act requires employers to:

The Employment Equality Act 1998 (Section 20A) (Gender Pay Gap Information) Regulations 2022 (“the Regulations”) were published on 3rd June 2022, however they also came into force on 31st May 2022. They set out details of how to do the various calculations and compile the information that employers need to publish.  Due to the complexity of the calculations and processes involved the Government has also published a guidance note to assist employers, most recently updated on 28th June 2022 (link below).

What is the Gender Pay Gap?

The gender pay gap is the difference in the average hourly wage of men and women across a workforce. It compares the pay of all working men and women; not just those in similar jobs, with similar working patterns or similar qualifications or experience. Often hourly earnings may be the same on the face of it, but other benefits may be afforded to men that are not afforded to women and such differences are also taken into consideration in calculating the gender pay gap of an organisation.

Key Points for Employers to Note

Number of employees           Year that reporting begins

250+                                        2022

150 – 249                                 2024

50 – 149                                   2025 

What Information Must be Published?

The Regulations set out details regarding the information that employers are required to report, and the formulae for all calculations required under the Act. In summary, the required information includes information relating to:

Mean – calculated by adding up all the earnings of male and of female and then dividing it by the number of people of that gender.

Median – calculated by finding the earnings of the person at the middle of the distribution of each gender.

Similar Legislation in Other Jurisdictions

Many employers, in preparation for the coming into force of obligations under the Act, have relied heavily on equivalent legislation in the UK. However, the Act contains much more far-reaching provisions than the UK equivalent such as the requirement for employers to examine 12 months of pay rather than one, its eventual application to all organisations with 50 employees or more, and its requirement for a further report to be published as at (ii) above in the event of a gender pay gap existing. The Act requires the employer to consider the pay of all employees whether full time, part time, temporary, on leave or otherwise and also to consider all aspects that may be considered renumeration such as bonuses, share options and benefits in kind, on the Snapshot date. The Irish legislation has gone significantly further than most other countries, with the exception of Iceland and Belgium. 

Takeaway for Employers: Employers with 250 or more employees should review their systems and prepare the required calculations to ensure that they will be in a position to comply with their obligations. By now, they should have chosen their Snapshot date and preparations should be underway so that reports can be published on time in December 2022. Consideration should be given to the possible explanation(s) for any differences in remuneration and what can be done to reduce or eliminate any pay gaps that may exist. Smaller organisations with between 50 and 249 employees should begin preparations for obligations that will extend to them in the coming years.

Links  –




Authors – Nicola MacCarthy,  Jenny Wakely & Anne O’Connell

30th June 2022

Anne O’Connell Solicitors

19-22 Lower Baggot Street, Dublin 2


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