Gender Pay Gap Reporting Ireland: Who Must Report at 50+ Employees?

Since 2025, gender pay gap (GPG) reporting in Ireland is a requirement for every employer with 50 or more employees. For many SMEs, 2025 was the first year they had to report and the 2026 cycle adds a new requirement to submit reports through the government’s Gender Pay Gap Portal. Understanding the implications of gender pay gap reporting Ireland is crucial for compliance.

The questions we hear most from payroll and HR professionals are more about the threshold itself: what happens if headcount moves around 50, and how are multiple payrolls counted. Here are the answers, with links to the official guidance.

This is a general informational article, not legal advice and we recommended that you consult with a solicitor or legal professional if you have specific questions in relation to your organisation.

In this article:

What goes into a gender pay gap report?
Who has to report the gender pay gap in Ireland?
Key dates: snapshot date and reporting deadline
My headcount moves between 48 and 52?
I run three payrolls, each under 50 staff?
Does gender pay gap reporting apply to schools?

Who has to report the gender pay gap in Ireland?

Short answer: Any employer, public or private, with 50 or more employees on its chosen snapshot date in June must publish a gender pay gap report that year.

Reporting was introduced by the Gender Pay Gap Information Act 2021 and phased in by size:

2022: employers with 250 or more employees
2024: employers with 150 or more employees
2025 onwards: employers with 50 or more employees

Employers with fewer than 50 employees are not required to report, although they can choose to.

Key dates: snapshot date and reporting deadline

Short answer: Pick a snapshot date in June. Your report is due five months later, on the same date in November.

Snapshot date: any date in June that you choose. Your headcount and the employees included in the report are based on that date.
Reporting period: the 12 months up to and including the snapshot date.
Deadline: the same date in November. A snapshot date of 20 June means a deadline of 20 November.
Where to report: for the 2026 cycle, reports must be submitted to the Gender Pay Gap Portal, as well as published on your own website if you have one.

My headcount moves between 48 and 52, do I need to report?

Short answer: It depends on your headcount on your chosen snapshot date in June. If you had 50 or more employees on that date, you must report for that year, even if you drop below 50 afterwards. If you had fewer than 50, you’re not in scope that year.

When you count, include everyone employed on the snapshot date, including:

People on leave (annual, sick, maternity, parental and so on)
People not rostered to work that day
Part-time and temporary employees

Contractors who aren’t on your payroll software as employees are not counted.

If your headcount sits close to 50, track it through June. An organisation at 48 in May can easily be at 51 by mid-June after summer hires. Count accurately on the date you choose, and keep a record of how you counted.

I run three payrolls, each under 50 staff?

Short answer: It depends on whether the payrolls belong to one employer or to separate employers. The obligation applies to each employer (legal entity), not to each payroll.

One company, several payrolls (for example weekly, fortnightly and monthly payrolls, or separate sites): add the headcounts together. Three payrolls of 20, 18 and 15 under the same company = 53 employees, so you’re in scope.
Separate companies in a group, each with its own payroll: each legal entity is assessed on its own headcount. Three companies of 20, 18 and 15 are each below 50, so none has to report — although you can publish a voluntary group report.

Where a group does publish one consolidated report, each in-scope legal entity still needs its own figures included.

If you’re unsure how your structure is treated, check the government guidance and FAQs or take legal advice.

Does gender pay gap reporting apply to schools?

Short answer: Yes, it can. Schools are not exempt, and a published pay scale doesn’t take a school out of scope. What matters is whether the employer has 50 or more employees on the snapshot date and in schools, the employer isn’t always the body that pays the staff.

The Gender Pay Gap Information Act 2021 explicitly covers public bodies, including education and training boards (ETBs), recognised schools run by ETBs and the boards of those schools.

Who counts as the employer?

ETB schools: staff are generally employed by the ETB, which reports on its whole workforce.
Primary and voluntary secondary schools: teachers are employed by the school’s board of management, even though the Department of Education pays them. The Act anticipates this: where an employer doesn’t hold its own employees’ pay data, regulations can require whoever holds it to provide it to the employer for reporting.

Counting to 50: include everyone the board employs on the snapshot date — teachers, special needs assistants, secretaries, caretakers and cleaners on the board’s payroll, including part-time staff and staff on leave. Most individual schools fall below 50, but larger post-primary schools can cross the threshold.

Why pay scales don’t mean a zero gap: a gender pay gap measures the difference in average hourly pay across the whole workforce, not whether men and women are paid the same for the same job. Even with every teacher on a published scale, a gap can appear if, for example:

More men than women hold principal, deputy principal or other posts of responsibility
Men and women are at different average points on the scale (length of service)
Lower-paid roles, such as SNAs and ancillary staff, are mostly held by women
Allowances or part-time hours differ between groups

If you manage a school near the threshold, check with the Department of Education or your school management body for any sector-specific guidance before your next June snapshot date.

What goes into a gender pay gap report?

Short answer: Hourly pay gap figures between men and women, bonus and benefit-in-kind figures, the gender split across pay quartiles, and a written statement explaining any gap and what you’re doing about it.

The report covers:

The mean and median hourly pay gap between men and women
The mean and median hourly gap for part-time employees and for temporary employees
The mean and median bonus gap, and the percentage of men and women who received a bonus
The percentage of men and women who received benefits in kind
The proportion of men and women in each pay quartile (lower, lower middle, upper middle, upper)
A narrative statement on the reasons for any gap and the measures you’re taking to reduce it

All of this comes from 12 months of payroll data, which is why clean, well-structured payroll records make reporting much faster.

Get your payroll data report-ready

Gender pay gap reporting is a payroll data exercise first. Quantum Payroll is built for Irish payroll, keeping pay, hours, bonus and benefit-in-kind data in one place so you can pull together the figures you need. If you’d rather hand payroll over completely, Quantum Bureau runs it for you.

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Official sources

This article is general information, not legal advice. Check the official sources above for the latest position.

Gender Pay Gap Reporting in Ireland: Do You Need to Report at 50 Employees?