EU Pay Transparency Directive: why it's a game changer for Irish employers
In this guest blog, Pat Gurren unpacks why the EU Pay Transparency Directive is set to transform reward practice, and what employers must do before the 2026 tipping point.
In this guest blog, Pat Gurren unpacks why the EU Pay Transparency Directive is set to transform reward practice, and what employers must do before the 2026 tipping point.
Equality has been a founding principle of the EU since 1957. Yet gender pay gaps still exist in double digits across most member states. Decades of legislation haven't closed them. Now, the EU is taking a sledgehammer to pay secrecy.
In this guest blog, Pat Gurren, Founder of Gurren Compensation, explains why the EU Pay Transparency Directive marks the most significant shift in reward practice in decades.The directive makes the shift beyond reporting and policy intent to enforceable transparency. That changes who holds the burden of proof, who must disclose what, and what happens when organisations fall short. For Irish employers, preparing for EU pay transparency compliance is now an urgent priority. June 2026 is closer than you think.
The directive targets pay secrecy head-on. Employees gain a right to information about pay – specifically, the average compensation in their work category, broken down by gender.
Why does this matter? Pay secrecy has historically protected inequality. When employees can't see what colleagues earn, they can't identify or challenge unfair pay gaps. The pay secrecy clause ban removes that barrier.
Job candidates must receive salary information before negotiations - either in job postings or before discussing starting salary. Hiring managers cannot ask about current packages. Employees will expect clear, objective criteria for pay decisions and progression. Vague promises about 'merit' won't suffice.
The fundamental shift: from 7 June 2026, the burden of proof in equal pay claims moves from employee to employer. Currently, employees must get pay data and build their own case. After June 2026, that burden sits with you. Equal pay claims have been relatively infrequent because they're difficult to prove. That changes completely.
Employees can request information about their individual pay and average pay by gender for their work category. You must inform employees annually about this right and respond within 60 days. These rights begin in June 2026.
|
Employee Headcount |
First Reporting Deadline |
Reporting Frequency |
|
250+ employees |
June 2027 (using 2026 data) |
Annually |
|
150-249 employees |
June 2027 (using 2026 data) |
Every three years |
|
100-149 employees |
June 2031 (using 2030 data) |
Every three years |
Reports must be published on your website and potentially on a government portal.
'Work of equal value' is defined by skills, effort, responsibility and working conditions, not market value. If you report a gender pay gap of 5% or greater that you can't objectively justify, and you haven't addressed it within six months, you must conduct a joint pay assessment with worker representatives. This is mandatory.
The three-year run-in was deliberate. Pay gaps can’t be fixed overnight – they require gradual adjustment through pay cycles, hiring and promotions. Start now to do this thoughtfully.
Moving from opaque to transparent pay practices is a major shift. You'll need strong stakeholder management as everyone has views on rewards. You also need project management skills for this significant work.
The directive itself spells out the vast majority of what you need. Twelve EU member states have published draft legislation following the directive. Stop waiting and start preparing.
If you treat this as compliance theatre, it will backfire. Train managers to a new level of understanding on rewards. You'll be assessed on practices, not policies.
Good data is now the biggest challenge, not just to measure gaps, but to analyse and justify them objectively. Gender pay gaps at work category level need to become a monthly metric. Pay equity status is dynamic, especially with small gender headcounts.
Managers will need to explain job evaluation outcomes, salary bands and pay progression with confidence. Without this capability, trust erodes when you make pay information visible.
Preparation takes longer than you think. Many projects take 8–12 months, so the sooner you start, the more you can address pay gaps gradually through annual cycles rather than reactive adjustments.
This requires HR, reward specialists, legal teams and leadership working together on job architecture, pay-setting criteria, progression frameworks, performance management, data systems and manager capability.
Ireland already requires gender pay gap reporting for employers with 50+ employees. Use that foundation and build on it.