Mid-Year Update
As we look ahead to the second half of the year, here are some key areas to consider for your business.
Gender Pay Gap reporting
Applies to those who employ 50 or more employees
Any date in June can be selected as the snapshot date
Five months to collect and report the data
The Gender Pay Gap Information Act 2021 first came into effect on 31 May 2022 and requires employers to report and publish information on gender pay gap.
The gender pay gap refers to the difference in average gross hourly earnings between men and women.
There is an important distinction to be made between unequal pay and the gender pay gap. Paying women less than men for the same job, purely on account of their gender is illegal under employment equality legislation. The gender pay gap is different in that it refers to the gap between what is earned on average by women and men based on gross hourly earnings of all paid employees.
Gender pay gap reporting has no way of determining whether men and women are being paid less for the same work or subject to bias or discrimination. Instead, it typically indicates that men and women are not equally represented at the different levels of an organisation. It also often points to more women than men in part-time roles. It is an assessment of gender representation and workforce participation.
Who needs to report
The reporting requirement was introduced on a phased basis but from 2025, the reporting obligations will apply to those employers who employ at least fifty employees.
Employers should only include those employees who are employed on the relevant date in their calculations. The relevant date is any date in the month of June that is selected by the employer, referred to as the ‘snapshot date’.
To comply with the Act, employers are required to complete a head count of all employees on the snapshot date. The data must include the differences in mean and median hourly, bonus pay, part-time and temporary employees by gender.
The reporting period
Employers are obliged to report on the average hourly pay gaps for the reporting period. This is the 12-month period ending on the snapshot date. Therefore, if an employer selects 30th June 2025 as the snapshot date, the reporting period would be from 1st July 2024 to 30th June 2025. If an employee did not receive any pay during the 12-month reporting period, they will not be included in the calculations.
In order to report on its gender pay gap, employers are required to calculate the:
Total number of working hours
Total ordinary pay
Total Bonus Pay
Identify those employees who received a benefit in kind.
Categorise employees employed on a part-time basis and those on temporary contracts as the mean and median hourly pay gaps have to be reported separately for those on part-time or temporary contracts.
Reporting deadline
Previously, once a snapshot date had been chosen, employers then had 6 months after that date to report and publish their gender pay gap on their company website. However, for 2025, a new portal will be launched in the autumn, and the gender pay gap reports will be uploaded there. The reporting deadline date is also changing, and employers will now have 5 months from the snapshot date to collect and report the data.
Where statistics indicate differences in relation to gender, there must be an accompanying report that sets out the reasons for the difference and the measures that are being taken to reduce or eliminate the difference.
Pension auto-enrolment
Delayed to 1 January 2026
Only pension deductions paid through payroll will be considered for exemption
Employers can register for portal access by end 2025
The Government has confirmed that the start date for pension auto-enrolment (AE) is to be delayed from 30 September 2025 to 1 January 2026. The delay aligns the system with the new tax year and allows more time for payroll system readiness.
The National Automatic Enrolment Retirement Savings Authority (NAESRA) is in the process of being set up. Employees will be automatically enrolled in the AE system by NAERSA if they:
Are aged between 23 and 60
Earn gross pay from all employments of €20,000 or more
Are not exempt from AE
Exemption from AE will apply if there are employee and/or employer contributions being made via payroll to a PRSA or pension scheme.
For employers who have not yet decided on a strategy for AE, they will now have additional time to prepare and to consider what suits their business best.
Items to consider
Identify which current employees fall within the scope of AE.
Assess costs and administration - consider the costs and administration of running a single scheme versus a dual scheme.
Employment law considerations - the legislation does not allow employers to enrol employees into their existing pension schemes to comply with AE. Employers will need to review current contracts of employment. If an employer wants to follow the single scheme approach into their current scheme, the employment law implications of contractually auto-enrolling employees into an existing scheme will need to be considered.
Benefit changes - If an employer wishes to use their existing pension scheme, amendments may be required e.g. waiting periods until probation has been passed. There are no waiting periods in AE.
Employer Portal - NAERSA has confirmed that an employer portal will be available by the end of 2025. All employers will need to register regardless of whether they intend to have auto-enrolled employees or not.
Enhanced Reporting Requirements (ERR)
A reminder to all employers making tax-free payments or benefits to employees and directors that certain expenses and benefits must be reported to Revenue on or before the date of reimbursement. The relevant expenses are:
Travel and Subsistence
Remote Working Daily Allowance
Small Benefit Exemption
ERR is separate from the payroll submissions. Even if items are processed through payroll, they must still be reported under ERR.
For the duration of 2024, there were no formal compliance interventions by Revenue, and through a service for compliance approach, supported employers through the first year of its operation. The expectation now is that all relevant employers have their systems in place and are complying with the reporting.
If you have any questions, please do get in touch with Nicola Tyndall.