Gender pay gap reporting – an update for employers

Gender pay gap reporting – an update for employers

As discussed in our article (, Gender Pay Gap reporting is coming to Ireland further to the Gender Pay Gap Information Act 2021 (the ‘Act’). Since then, the Government has provided additional guidance to employers in its recent publication ‘Gender Pay Gap Information Reporting: Your questions answered (Employers)’ (the ‘Guidelines’). Below is a recap of some of the key issues which have been highlighted in that report.

How is employer defined for the purposes of Gender Pay Gap Reporting?

Employer is defined in section 2 of the Employment Equality Acts. That section states that employer means the person with whom the employee has entered into or for whom the employee works under a contract of employment.

Further, the Guidelines also explain that for the purposes of agency workers, the person who is liable for paying agency worker shall be considered to be the employer.

What is the snapshot date?

Employers are required to choose a snapshot date which can be any date in June. That date will be key in calculating the requisite details on the gender pay gap in an organisation.

Once an employer has chosen its snapshot date, it will need to:

  • establish how many employees it has on the snapshot date – even if employees are on leave or not rostered to work on the snapshot date, they should still be included in an overall headcount;
  • gather data on those employees for the 12 months previous to the snapshot date;
  • do calculations based on the data for those employees; and
  • establish the reporting deadline, which will be 6 months after the snapshot date. So for instance if an employer chose 9 June as the snapshot date, then the deadline for reporting would be 9 December.

It is important to remember at this point that an employer is only required to report if it exceeds the following thresholds:

  • if an employer has 250 or more employees, the employer will have to report in 2022;
  • if an employer has 150 or more employees, the employer will have to report in 2024; and
  • if an employer 50 or more employees, the employer will have to report in 2025.

Thus the snapshot date for this year is only relevant to those employers who have 250 employees or more, and the legislation is being brought in on a phased basis.

Interestingly however, even if employees leave an employer during the course of the six months after the snapshot date and the employer would then fall below the threshold, the employer is still required to report. The number of employees on the snapshot date is what matters – not the number of employees thereafter.

How have employers to report the Gender Pay Gap?

For 2022, employers should report their Gender Pay Gap on their website, or in some other way that is publically accessible. This should be available for three years from the date of publication on the website, for example. There is no set manner of providing the information, and employers will need to consider the best way of conveying the information – and explaining any gender pay gap and methods to reduce it should it arise – to the public. At this point, employers do not need to submit the information to the Minister.

Moving forward, there is going to be a portal which is hoped will be in place for the 2023 reporting cycle where reports for all companies would be accessible. It is envisaged that such an online portal would allow members of the public to search for and view individual employers’ returns, as well as returns for employers in given sectors and regions. This reinforces the point that employers will need to strongly consider how they report and explain their figures, and any gender pay gap, particularly where members of the public can compare and contrast companies in the same sector. If not managed properly, this could have a knock on impact on recruitment and retention of staff.


These Guidelines give employers further insight and clarity into the Act and how it will work in practical terms. Those employers who are over the threshold for reporting this year should be going through an analysis of the work required to provide a report by the deadline, at some point in December this year.

For further information on this topic, please contact Laura Graham at










Laura Graham
Author: Laura Graham