Understanding Irish Gender Pay Gap Reporting Metrics

In December 2024, companies in Ireland with 150-249 employees will have to release their first gender pay gap (GPG) report under the Gender Pay Gap Information Act 2021. The requirement, which came into force in May 2024 for smaller companies, represents a major shift, particularly for HR teams. It’s worth noting that the requirement will also extend to organisations with 50 to 149 or more employees in 2025 and has been in force for those with 250 or more employees since 2022.

The extended reporting mandate, a key element of a broader strategy, is set to significantly enhance female workforce participation and address gender employment disparities across even more workplaces. While it won’t entirely resolve the underlying issues, it is a crucial and positive step forward. However, it does introduce an additional burden for smaller companies.

Non-compliance with these regulations can lead to serious reputational damage. Therefore, it’s vital that all affected companies thoroughly understand and adhere to these new reporting requirements. Yet, as our recent research uncovered, with just weeks to go, more than half of businesses remain ill-prepared, as only 45% have reviewed their pay rates by gender in the past year.

In our blog, we explained what the pay gap is and what GPG reports entail. 

Here, we delve into the specific aspects of GPG reporting requirements and best practice.

Key Considerations When Reporting Your Gender Pay Gap

GPG reports must, by law, follow specific rules. That means abiding by strict definitions and certain parameters. The Government has published some comprehensive guidance for employers, which you should familiarise yourself with. However, it’s extremely detailed and complex, so you might want to get some advice from an expert. 

Standout directives include:

1. All public and private sector employers with 150 or more employees need to select a snapshot date in June 2024. All calculations and reporting are based on the employee data as of this chosen date.
2. The deadline for reporting is within six months of the June 2024 snapshot date, falling in December 2024 for all organisations. 
3. Reports must feature a series of essential metrics that capture a comprehensive picture of the gender pay gap, including:

• Hourly pay differences between male and female employees.
• Bonus pay differences between male and female employees
• The proportion of male and female employees receiving bonuses and benefits in kind.
• The distribution of male and female employees across pay quartiles.

     4. Reports must also include commentary that addresses various aspects of the organisation’s gender pay gap and sets out an action plan of measures to address the gender pay gap and promote gender equality.

     5. GPG information must be published on the employer’s website or in some other manner that is accessible to all its employees and to the public for a period of at least three years. 

Knowing what you need to include in your GPG report is only the first step. To ensure that it complies with requirements, you need to have a plan in place, collect, and then analyse all the necessary information. 

To help, we’ve outlined some actionable steps that will help you complete the process.

Gender Pay Gap Reporting Compliance and Best Practice

To ensure transparency and make real progress in closing the gender pay gap, you need to go beyond just meeting legal requirements. From collecting detailed pay data to calculating the gap and creating an explanatory narrative, these measures will help you create a fairer and more inclusive workplace.

1. Identifying employees and collecting the data

• Identify your workforce: The first step is to accurately identify all employees as of your chosen snapshot date in June 2024. This is the foundation for all of your gender pay gap calculations, covering everyone employed on the snapshot date, whether full-time, part-time, on temporary or fixed-term contracts, or on statutory leave.
• Collect comprehensive pay data: Next, you must gather detailed information on all pay elements for each employee, such as basic salary, bonuses, overtime, and other benefits. Statutory and top-up payments made to employees on statutory leave, like maternity, paternity, or parental leave, should also be included in your pay calculations.

2. Calculating the gender pay gap

• Convert pay data to hourly rates: You then need to convert the collected pay data into an hourly rate to standardise comparisons between full-time and part-time workers. This will allow you to calculate both the mean (average) and median (middle) gender pay gaps, ensuring that the differences in earnings between men and women across your organisation are transparent​.
• Address special pay components: With effect from 31 May 2024, The Gender Pay Gap Information Regulations (the Regulations) have been updated and now require you to factor share options, interest in shares, and certain statutory leave payments (e.g., maternity, paternity) into the gender pay gap calculations as part of employees’ “basic pay” and “benefit in kind.”​ Handling these components correctly when calculating the gap is essential.

3. Analysing the pay gap

• Break down the data by contract type: You must conduct additional analyses for specific groups, such as part-time employees or those on fixed-term contracts, to provide a clear picture of disparities within these categories. This analysis is crucial as part-time workers, who are more likely to be women, often face larger pay gaps.
• Examine pay quartiles: You are further required to split your workforce into four equal quartiles based on hourly pay to see the distribution of men and women across different pay levels. This pay quartile analysis will flag whether men dominate higher-paying roles and women occupy lower-paying roles, as is often the case in organisations with large pay gaps​. 

4. Prepare the Narrative

• Identify causes of the pay gap: Creating a narrative is a critical element of the report. You must prepare a written explanation outlining the reasons behind the gender pay gap. You should include factors like the underrepresentation of women in senior roles, gender imbalances in bonus payments, or a higher proportion of women working part-time​.
• Outline your solutions: Your narrative must also include actions your company is taking or plans to take to address these issues. Strategies may range from mentorship programs aimed at promoting women to senior roles to revisiting bonus criteria to ensure they are distributed more fairly.

5. Establish continuous monitoring and a regular reporting process

• Annual reporting requirements: Compiling your GPG report isn’t a one-off requirement—it’s something that you must do every year. To prepare for this ongoing task, you should implement a system for regular data collection and monitoring. It could include the likes of:
  • Regular pay audits
  • Monitoring recruitment and promotion practices
  • Reviewing bonus and incentive structures
  • Developing more flexible working policies

This will also enable you to make continuous improvements in reducing gender disparities.

• Develop an action plan: Beyond merely meeting reporting requirements, you should encourage your company to create comprehensive action plans that address the root causes of the pay gap, such as occupational segregation or barriers to career progression for women. This is where your narrative comes to life. You need to show that the plans you’ve proposed are more than just words on paper and that you’re taking affirmative action to reduce your pay gap.

Where To Get More Gender Pay Gap Reporting Information

We realise GPG reporting can be daunting, especially if it’s your first time. We hope this guide helps, but we recognise it won’t be able to answer all of your questions. If you’re in any doubt or have specific queries, we recommend you seek specialist advice from a legal professional. 

You can also access more information from reliable sources, such as: 

• Citizens Information’s advice on Gender Pay Gap Reporting for Employers with links to relevant legislation and further guidance. 
• The government’s downloadable Gender Pay Gap Information Reporting FAQs for Employers guide.
• Gov.ie website’s page How to Report on the Gender Pay Gap. 

Additional free resources from HRLocker:

• Read our blog post What You Need to Know about the New Irish Gender Pay Gap Reporting Requirements
• Download our Gender Pay Gap Policy template
• Watch our Gender Pay Gap Reporting webinar
• Access our latest Gender Pay Gap Reporting in Ireland Report