Irish Gender Pay Gap Reporting

Guidance, FAQs and Regulations relating to gender pay gap reporting in Ireland have been published by the government. Organisations with reporting obligations in 2022 effectively have until December to gather their data, calculate their figures, compile their narrative and publish. The guidance, FAQs and regulations, along with a summary of the Gender Pay Gap Information Act 2021, can be found here. It should be noted that we still do not have the formal regulations – however the government is clearly responding to calls to give employers the information they need to prepare.

 

There is a lot to digest in the material issued by government. Employers have limited time to take action. If you need help with meeting your obligations on the Act, or developing a wider strategy on either pay equity or broader diversity, equity and inclusion – do please reach out to us.

 

Read on for a snap shot summary of the rules including which organisations are affected, who needs to take action, what needs to be done, who needs to do it and when they need to do it by.

 

Which organisations are affected?

In 2022, employers in Ireland with 250 or more employees need to report their gender pay gaps in the manner set out by the regulations. The requirements will apply to employers with 150 or more employees from 2024 and those with 50 or more employees from 2025. 

 

What do organisations due to report in 2022 need to do now?

Affected organisations should assign responsibility for ensuring that the requirements are met: really, this is the first thing that needs to be done. It may or may not be practical or desirable to attempt the calculations in-house, and external support may be required. A lot here will depend on factors like:

 

  • The simplicity or complexity of payroll data
  • The level of confidence felt in understanding the regulations and the required calculations
  • The level of confidence felt in translating the organisation’s Diversity, Equity and Inclusion agenda into a published narrative
  • The degree to which an organisation wishes to use the gender pay gap reporting requirements as a springboard for concrete action
  • The number of distinct employing entities with an obligation to report within an organisation and the desire to proactively report on group or global figures

Mercer is available to help organisations with every stage of the process, whether on the narrow reporting requirements, on a deeper analysis that also looks at pay equity within roles or on the framing of a diversity, equity and inclusion strategy that covers the gender pay gap amongst other DEI issues. Contact us to find out more.

 

What exactly needs to be published?

Organisations will need to publish, in the manner to be set out in the forthcoming regulations and described in the new guidance note:

 

  • The difference between the mean hourly remuneration of employees of the male gender and that of employees of the female gender expressed as a percentage of the mean hourly remuneration of employees of the male gender.
  • The difference between the median hourly remuneration of employees of the male gender and that of employees of the female gender expressed as a percentage of the median hourly remuneration of employees of the male gender.
  • The difference between the mean bonus remuneration of employees of the male gender and that of employees of the female gender expressed as a percentage of the mean bonus remuneration of employees of the male gender.
  • The difference between the median bonus remuneration of employees of the male gender and that of employees of the female gender expressed as a percentage of the median bonus remuneration of employees of the male gender.
  • The difference between the mean hourly remuneration of part-time employees of the male gender and that of part-time employees of the female gender expressed as a percentage of the mean hourly remuneration of part-time employees of the male gender.
  • The difference between the median hourly remuneration of part-time employees of the male gender and that of part-time employees of the female gender expressed as a percentage of the median hourly remuneration of part-time employees of the male gender.
  • The percentage of all employees of the male gender who were paid bonus remuneration and the percentage of all employees of the female gender who were paid such remuneration.
  • The percentage of all employees of the male gender who received benefits in kind and the percentage of all employees of the female gender who received such benefits.
  • The difference between the mean hourly remuneration of employees of the male gender on temporary contracts and that of employees of the female gender on such contracts expressed as a percentage of the mean hourly remuneration of employees of the male gender.
  • The difference between the median hourly remuneration of employees of the male gender on temporary contracts and that of employees of the female gender on such contracts expressed as a percentage of the median hourly remuneration of employees of the male gender.
  • The respective percentages of all employees who fall within each of:
    (i) the lower remuneration quartile pay band,
    (ii) the lower middle remuneration quartile pay band,
    (iii) the upper middle remuneration quartile pay band, or
    (iv) the upper remuneration quartile pay band,
    who are of the male gender and who are of the female gender.

 

What needs to be done?

Where an organisation has to report, at a minimum the following actions need to be taken:

 

  • The data required to run the required gender pay gap calculations needs to be defined 
  • A reference date in June 2022 needs to be decided on
  • Following the reference date, the data needs to be gathered from payroll systems or elsewhere
  • Calculations need to be run to arrive at the numbers and statistics required
  • A report needs to be prepared, setting out:
    (i) in the employer’s opinion, the reasons for the differences found and
    (ii) the measures (if any) being taken, or proposed to be taken, by the employer to eliminate or reduce such differences.
  • The figures and the report need to be published no later than 6 months after the reference date in June chosen by the employer.

It may be desirable to go further. Calculating the gender pay gap is one thing; obtaining data that explains why that gap arises is another. In order to understand what factors give rise to the gender pay gap in a given organisation, the employer may wish to run analysis on pay equity – i.e. understanding what gaps may exist for particular roles and levels. This is not required by the Act – but it will help an organisation to understand whether the gap is a feature of different gender representation for different roles and levels, or whether in fact evidence of a gender pay gap also appears within particular jobs.

 

How must the report and figures be published?

The gender pay gap information must, in 2022, be published either on the employer’s website or in some other way that is accessible to all its employees and to the public. From 2023, the government says that it intends to provide a portal for publication.

 

Further questions

If you wish for help from Mercer in meeting your gender pay gap reporting requirements, or if you simply have questions, you can contact us.

Danny Mansergh
Danny Mansergh
Head of Career Consulting, Mercer Ireland
Lucye Provera
Lucye Provera
Global Pay Equity Solutions Manager, Mercer

Speak with a Consultant

We’re eager to speak with you. Please provide your details below.
*Required Fields