Closing the Gender Pay Gap: Learning from Ireland’s Pay Data and European Transparency Reforms

Introduction

The gender pay gap (GPG) is a persistent feature of labour markets worldwide, and Ireland is no exception. In 2023, the Irish unadjusted gender pay gap amounted to 8.6%, in other words, the average women earned 8.6% less than the average man. While this gap was lower than the EU average (12%), there is no reason for complacency: according to 2022 data, the Irish gap widens to nearly 25% in the financial, insurance, and real estate sectors, to 19% in professional, scientific and technical activities, and to 17% in administrative and support services (CSO, 2023).

This paper examines the implementation of Ireland’s pay transparency regime under the Gender Pay Gap Information Act 2021. It argues that shortcomings in data quality, enforcement, and structural supports have limited its impact and risk reducing pay reporting to a symbolic exercise. The paper concludes with six recommendations to make transparency a mechanism for accountability and genuine equality—through accessible, high-quality data; stronger support and incentives for employer action; more effective enforcement; and complementary policies to address care-related inequalities.

The paper focuses mainly on the GPG, which is different from the right to equal pay. The GPG measures the overall difference in average hourly earnings between women and men across the workforce (e.g. in a given company or sector). It reflects patterns of occupational segregation, working hours and seniority rather than direct pay discrimination. By contrast, the right to equal pay is an individual legal entitlement: it requires that women and men doing the same work, or work of equal value, receive equal pay.

The causes of this gap are multiple and interconnected. One driver is vertical segregation: women are underrepresented in senior roles, where pay is highest, and progress up the career ladder remains slow. For instance, men still hold around 70–80% of leadership positions in Ireland. Another driver is horizontal segregation, whereby women are concentrated in lower-paid and undervalued sectors such as care, retail, and education. These structural inequalities are compounded by the unequal distribution of care responsibilities. High childcare costs and limited leave policies for parents continue to discourage women from remaining in or re-entering the workforce on a full-time and continuous basis. Without stronger supports for co-parenting, women’s career progression will remain constrained, and on average, they will continue to have lower earnings than men over their life courses (Citizen’s Assembly, 2021).

Cultural and institutional sexism (Benedi Lahuerta 2025) also plays a role. Gender stereotypes persist, influencing subject choices at school, occupational patterns, and organisational cultures. These factors reinforce pay inequities and highlight that tackling the GPG demands social and cultural change as well as institutional accountability.

Against this backdrop, pay transparency has emerged as a promising instrument within the toolbox to address gender pay inequity. It is not a silver bullet: reducing pay inequity is not an easy task, but transparency can contribute to equalising pay information between employers and employees, which decreases employers’ power to set unfair wages and helps workers identify and act against pay discrimination. However, beyond improving access to information, tackling the GPG also requires addressing its structural causes, such as women’s overrepresentation in low-paid sectors, persistent promotion barriers, inadequate working time, childcare and family leave policies, unconscious bias, and gendered negotiation patterns (Benedi Lahuerta, Miller and Carlson 2023; Benedi Lahuerta, Miller and Carlson 2024).

In Ireland, the Gender Pay Gap Information Act 2021 (“the GPG Act”) marked an important first step to improve access to pay information: it obliges employers with 50 or more employees to report various metrics broken down by gender annually. However, weaknesses in its design and enforcement limit its effectiveness. With the EU Pay Transparency Directive (2023/970) due for transposition by June 2026, Ireland faces a key opportunity: to build a more ambitious, effective system that makes transparency a driver of genuine equality rather than a symbolic exercise.

To what extent can pay transparency effectively contribute to reducing the GPG?

International evidence shows that pay transparency legislation can help reduce pay inequity—but only when designed and implemented effectively. Comparative research highlights five effectiveness dimensions (EDs) that determine whether pay transparency has real impact (Benedí Lahuerta and Aumayr-Pintar, 2024).

1. Wide coverage: Effective regimes set low thresholds and apply them across both public and private sectors. Countries like Denmark, Finland, Lithuania, Portugal, Spain or Sweden have thresholds below 50 workers for pay reports.

2. Fair and transparent recruitment procedures: Imposing proactive duties to employers to ensure fair and transparent recruitment has been shown to reduce pay inequality at entry points into organisations by empowering candidates to negotiate better salaries. For example, the EU Pay Transparency Directive requires employers to provide pay scale information in job advertisements and bans salary history questions during recruitment.

3. Proactive employer duties: Employers’ proactive duties to report pay gaps have been found to be more effective than allowing workersto discuss pay or request pay information from their organisations. This is partly due to ‘pay talk’ remaining a taboo in many cultures and workplaces.

4. Rich data requirements: Research demonstrates that the more detailed and disaggregated pay reports and pay audits are, the more useful they will be for employers and workers to understand the roots of pay inequity, and the more likely it is that actions will be taken to address it.

5. Action triggers: Transparency alone is insufficient unless it triggers action through incentives or sanctions. For instance, in Iceland, equal pay certification requires employers to demonstrate compliance with objective criteria, with sanctions for failure. Triggers, however, do not always need to be in the form of sanctions: giving trade unions or the public scrutiny over pay figures can also be effective. For example, in Belgium, reporting is linked to social dialogue, requiring collective bargaining around identified gaps (Vandekerckhove, 2024). In the UK, while strong sanctions are not in place, the public availability of all pay reports through a governmental website creates accountability and may be playing a role in companies’ efforts to lower their GPGs.

What are Ireland’s pay reporting obligations and how do they work in practice?

The principle of equal pay for equal work, or work of equal value, has been enshrined in Irish law since the transposition of EU equal pay provisions into the Anti-Discrimination (Pay) Act, 1974 (currently found in the Employment Equality Act 1998). In practice, however, equal pay claims have been rare and difficult to pursue. This reflects wider European trends, where litigation alone has proven an ineffective tool for closing gender pay gaps (Fredman, 2022). Against this backdrop, Ireland adopted the GPG Act 2021, which introduced mandatory gender pay gap reporting for employers above certain size thresholds. The GPG Act and the broad Irish legal framework have several positive aspects:

• Ireland already has the foundations of a dual transparency model, combining “top-down” employer reporting duties with “bottom-up” individual rights: Under the Employment Equality Act 1998, workers can ask their employer for information if they believe they are being paid less than a colleague of a different gender doing similar work (sections 19 and 76), and the Workplace Relations Commission (WRC) can view an employer’s silence as evidence of discrimination. Alongside this, the GPG Act requires larger employers to publish data on pay differences between men and women. This requirement, which applies both to public and private employers, places Ireland in a relatively good position to meet the new EU Pay Transparency Directive (2023/970) requirements and to strengthen accountability for fair pay. This dual model has partly shifted the burden of discovering and challenging unequal pay from individuals to employers, through employers’ duty to publish pay reports.
• In pay reports, employers must disclose not only mean and median pay gaps for basic hourly pay and bonuses, but also for benefits-in-kind, and for part-time and temporary employees, which goes beyond many domestic legislations and the Pay Transparency Directive. The inclusion of pay data for atypical workers is a notable strength, as part-time and temporary employment are key drivers of the GPG.
• In theory, Ireland’s enforcement model combines institutional oversight (through the Irish Human Rights and Equality Commission (IHREC)) with individual remedies. Sections 85B and 85C of the EEA 1998 empower IHREC to apply to the Circuit or High Court for compliance orders, while employees may file complaints before the WRC (Workplace Relations Commission). IHREC’s investigative powers, including the ability to require entire industries to perform equality reviews for individual employers or whole sectors, or draft action plans, represent a latent but potentially powerful enforcement tool (see further below).

These provisions give Ireland a relatively advanced pay transparency framework, at least in theory. They provide the legal and institutional basis for both organisational accountability and individual empowerment, partly aligning Ireland with forthcoming EU requirements. In practice, however, these strengths remain largely dormant: limited data detail, phased implementation, and weak enforcement mechanisms have prevented the Act from achieving its intended effect. The following limitations illustrate why the promise of the Irish model has not yet translated into impact:

• The data required are basic and unadjusted: The Irish GPG Act focuses on headline figures, but richer data are needed to identify causes. Employers report raw averages without any requirement to disaggregate by education, age, or tenure. This limits the explanatory power of the figures and makes it difficult to distinguish between structural causes (such as occupational segregation) and discriminatory practices (Benedi Lahuerta, 2024; Carthy, 2024; Benedi Lahuerta, Rechjrt and Patrick, 2024).
• Reporting has been phased over several years, so while firms with 250+ employees started reporting in 2022, those with 150+ and 50+ employees only started doing so in 2024 and 2025, respectively. This means that, for the first years, only a limited number of large employers were captured, reducing comparability across sectors and excluding most small and medium-sized enterprises (SMEs), which make up over 99% of Irish businesses (CSO, 2023).
• The legislation leaves wide discretion to employers in how they frame their explanatory statements. Research on the first three years of reporting shows that many organisations provide vague or generic explanations, citing “pipeline issues” or “sectoral norms”, without linking them to specific measures (Keane, 2025). This undermines accountability.
• Accessibility is poor: Reports are hosted on individual company websites rather than a central public portal, and many contain data only in images with no explanatory or alt-text, making it inaccessible for anyone using a screen reader. As a result, comparing data across employers, sectors, or over time is cumbersome for workers, unions, researchers and the public (O’Sullivan, 2024).
• Enforcement and triggers are limited: The Irish Human Rights and Equality Commission (IHREC) is empowered to seek compliance through the courts, but there are no financial penalties for poor-quality reporting or for failing to implement remedial measures (Carthy, 2024). This contrasts with jurisdictions such as Iceland, where equal pay certification is mandatory, or Spain, where equality plans are subject to labour inspectorate oversight (Gómez-Millán Herencia 2024). In practice, IHREC has not taken any action against uncompliant companies since reporting started in 2022. Other action triggers, such as the fear of reputational damage, are also limited as the launch of the promised central pay reporting portal continues to be delayed.

The shortcomings of the Irish pay transparency model are best observed when compared to evidence-based effectiveness dimensions (discussed above) and the EU Pay Transparency Directive (Directive (EU) 2023/970), which must be transposed by June 2026. The Directive introduces several innovations absent from the Irish Act:

• Recruitment transparency: employers must provide information on pay ranges in recruitment, they cannot ask applicants about salary history, and they must allow ‘pay talk’ in the workplace.
• Pay reporting: alongside the current GPG public reports, employers must provide internal pay reports broken down by job category, gender, and both basic and variable pay.
• Gender-neutral job evaluation: Member States must establish objective and gender-neutral job classification systems to be used by employers.
• Enforcement: national authorities must ensure sanctions, remedies, and compensation for breaches.

Unless Irish law is updated quickly, Ireland will fall short of the Directive’s more ambitious requirements and will face the risks of late transposition, including being fined, as seen recently with the Work-Life Balance Directive (CJEU, Case C-69/24).

The GPG Act 2021 in practice: Insights from Employers’ Pay Reports

Three years of mandatory GPG reporting in Ireland has provided valuable insights into how employers approach transparency. However, the evidence shows that many organisations have treated reporting as a reputation management exercise rather than a driver of organisational change (O’Sullivan, 2024; Keane, 2025).

Analysis of company reports reveals poor quality and recurring strategies to deflect attention from structural inequalities and present inequalities as inevitable, often misleadingly presenting contextual and institutional factors such as sectoral demands or organisational culture as immovable. The key issues we have identified are:

• Poor quality: In 2024, at least 130 reports had “errors”, defined as reports which were removed, with missing data with no explanation or with incorrectly reported data (Keane, 2025).

Figure 1: Errors reported by PayGap.ie in 2024/25 employer reports. Source: PayGap.ie

• Normalising inequality: A lack of women in senior roles is presented as a natural consequence of historical trends or educational choices, rather than a reflection of promotion criteria, work cultures, or recruitment biases. This framing shifts responsibility away from organisations and reduces pressure to implement structural reforms.
• Organisational cultures: Narratives in reports also highlight cultural frames that perpetuate inequality. Long-hours cultures, expectations of constant availability, and assumptions about women’s caregiving roles all limit career progression. Without structural supports such as affordable childcare and non-transferable paid parental leave (including for children of primary school age), women are less able to sustain continuous full-time careers, leading to slower progression and higher attrition. These issues are reinforced by the Irish legal and policy context. Despite reforms, Ireland continues to have some of the highest childcare costs in Europe, and family leaves remain more gendered and far less generous than in many OECD countries (Doorley and O’Shea, 2025). The country also faces an acute childcare crisis, with over 39,000 children aged 1-3 years on the waiting list for childcare services in 2023-24 (Foley et al. 2025). This combination limits the ability of fathers to take up caring roles and perpetuates gendered divisions of labour.
• Vague explanations: Employers frequently attribute pay gaps to broad “pipeline issues” or the nature of their sector, without linking these claims to concrete actions. For example, companies may note that women are underrepresented in senior roles in their industry, but fail to explain how they intend to improve promotion pipelines or recruitment processes.
• Ignoring history: Few reports make reference to previous years’ data. As a result, positive changes are often presented as the outcome of natural progression, while negative changes are left unexplained. This undermines the ability of workers, unions, and policymakers to track genuine progress.
• The role of narratives: The way organisations narrate inequality matters. By framing pay gaps as inevitable, employers reinforce stereotypes and reduce the perceived urgency for change. Conversely, when organisations acknowledge structural barriers, such as lack of flexible promotion pathways or unaffordable childcare, they open space for more ambitious policy interventions.
• Box-ticking language: Many employers list generic diversity initiatives, such as unconscious bias training or mentoring schemes, without demonstrating their actual impact on reducing pay disparities. International findings show that symbolic equality measures are rarely effective unless they are linked to structural reforms (European Institute for Gender Equality [EIGE], 2022, 23-25).

If all these aspects remain unaddressed, these practices risk turning pay gap reporting into a symbolic exercise.

Conclusion and Policy Recommendations

The GPG Act 2021 has placed Ireland on the path towards greater pay transparency, but in its current form it risks being more symbolic than transformative. The first years of reporting under the GPG Act reveal that in the absence of stronger standards, centralised transparency, effective enforcement, and evidence-based guidance for employers, they are likely to approach pay transparency as a box-ticking exercise.

Indeed, comparative evidence underscores that design matters. Poorly designed pay transparency laws may raise awareness but fail to deliver change. Ireland can learn from what has been effective in other jurisdictions to use the implementation of the EU Pay Transparency Directive as an opportunity to introduce changes to transform pay reporting into a driver of genuine equality through access to pay information.

The forthcoming transposition of the EU Directive provides an opportunity to address these weaknesses, align Ireland with best practice, and ensure that transparency becomes a lever for structural change rather than a compliance exercise. By tightening standards and enhancing accessibility, Ireland can ensure that reporting leads to genuine accountability and cultural change. Otherwise, pay gap reporting risks reinforcing the very inequalities it was designed to address.

If implemented effectively, the Directive could mark a shift from awareness to accountability. To ensure pay transparency becomes an engine of structural and cultural change rather than a compliance exercise, Ireland should consider the policy and regulatory actions outlined in the following recommendations:

1. Strengthen reporting standards and data requirements
   • Require employers to link pay data to specific actions and outcomes, explaining clearly which measures contributed to improvements, or why gaps persist.
   • Introduce standardised templates and require greater disaggregation (especially by job category) to enhance comparability and analytical value.
2. Establish a central public reporting portal
   • Create a single searchable public database for all pay gap reports, ensuring accessibility and long-term data retention.
   • Enable benchmarking by sector and company size, fostering reputational incentives and transparency.
3. Mandate action plans and independent reviews
   • Require employers to submit annual action plans alongside their pay reports.
   • Introduce an independent review mechanism (via an independent monitoring body) to assess reports and plans against measurable targets and ensure follow-up.
   • Impose proportionate and dissuasive sanctions for persistent failure to improve or to comply.
4. Introduce equal pay audits and certification schemes
   • Pilot an Equal Pay Certification model inspired by the Icelandic (Benedi Lahuerta 2021) or Italian (Degl’Innocenti 2024) experiences, requiring employers to demonstrate compliance with objective criteria through periodic audits.
   • Link certification to tax or public procurement incentives to encourage substantive action.
5. Develop a National Evidence-Based Toolkit for Employers
   • Create a practical national guidance toolkit on effective equality interventions, distinguishing between symbolic and evidence-based measures.
   • Include best practices on inclusive recruitment, promotion, and work-life balance policies, informed by social science research and national data.
6. Go beyond pay transparency: Address structural inequalities through interventions to tackle care-related inequalities (in line with recommendations from the Citizen’s Assembly (2021), UNICEF (2024) and the EU-recommended Barcelona 2030 targets).
   • Progressively move towards a publicly funded, accessible and regulated model of affordable pre-primary education(3-5 years), following the models of other countries like France and Spain, and in line with the demands of the ‘Together for Public’ Alliance.
   • Expand to invest 1% of GDP in childcare by 2030 (UNICEF 2024) to provide affordable high-quality early-years childcare for children aged 0–3 years.
   • Encourage coparenting and uptake of family leaves by equalising paid paternity leave to paid maternal leave, introducing at least two months of untransferable paid parental leave for each parent of children up to eight years old, and raising payment levels to encourage take-up.

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