Pay transparency is no longer a “nice to have” or a future HR trend, it is a legal requirement on the horizon for Irish employers.

Ireland is currently preparing to implement the EU Pay Transparency Directive, which will significantly change how organisations advertise roles, set pay, manage internal salary structures, and respond to employee queries about pay. While the final Irish legislation has not yet been enacted, the direction of travel is clear, and employers should be preparing now.

The legislation stems from European Union Directive (EU) 2023/970, introduced to strengthen the principle of equal pay for equal work or work of equal value. Across Europe, unexplained gender pay gaps and opaque pay-setting practices have persisted for decades. The Directive aims to address this through mandatory transparency, accountability, and enforcement mechanisms.

Ireland must transpose this Directive into national law by 7 June 2026.

1. Salary Transparency in Recruitment

Employers will be required to:

 • Include salary ranges or starting pay levels in job advertisements.

 • Provide pay information before interviews, not after.

 • Stop asking candidates about their salary history.

This represents a major cultural shift, particularly for sectors where pay negotiation has traditionally happened behind closed doors. 

2. New Employee Rights to Pay Information

Employees will gain the right to request:

• Their individual pay level, and

• The average pay levels of colleagues performing the same work or work of equal value, broken down by gender.

Employers must respond within a defined timeframe and ensure the information is accurate, objective, and defensible.

3. Objective Pay Structures Will Be Essential

Employers will need to clearly document and communicate:

 • How pay is set

 • How pay progression works

 • What criteria justify pay differences (e.g. qualifications, experience, responsibility, performance)

Informal or historic pay practices that cannot be objectively justified will present a significant legal risk.

 4. Pay Secrecy Clauses Will No Longer Hold

Employees will have a protected right to discuss pay for the purposes of enforcing equal pay. Any contractual clauses that attempt to prevent this will be unenforceable.

This does not mean employers lose control of their pay structures but it does mean those structures must stand up to scrutiny.
5. Gender Pay Gap Reporting Will Go Further

Ireland already has gender pay gap reporting obligations under existing legislation. The new framework:

 • Aligns reporting more closely with EU standards

 • Introduces joint pay assessments where significant unexplained pay gaps exist

 • Requires employers to take corrective action, not just publish figures

 

While some reporting thresholds apply primarily to employers with 50+ employees, many of the transparency obligations particularly recruitment transparency and employee pay information right will apply much more broadly.

Small and medium-sized employers are not exempt from preparation.

What Should Employers Do Now?

• Reviewing job descriptions and grading structures

• Auditing pay consistency across comparable roles

• Removing outdated confidentiality clauses

• Training managers on lawful pay conversations

• Preparing systems to respond to pay information requests

The organisations that struggle most with this legislation will not be those with pay gaps, but those who cannot explain them.

Pay transparency is not about publishing everyone’s salary publicly,  it is about ensuring  fairness, consistency, and accountability.

Handled well, it can strengthen trust, improve retention, and reduce risk. Handled poorly, or ignored, it can expose organisations to legal challenge, reputational damage, and regulatory scrutiny.

If you have not started preparing yet, now is the time.