Irish Organisations with 250 or more Employees published their second Gender Pay Gap Reports in December.
As this year’s reporting season recently closed, it is a good time to note that the obligation to publish a Gender Pay Gap Report extends to Organisations with 150 Employees or more this year. This will bring a lot more Organisations within the scope of the legislation and increase the compliance load of those Employers who are completing the pay gap reporting exercise for the first time.
Gender Pay Gap Reporting Trends
While smaller Organisations may be completing their Gender Pay Gap Report for the first time in 2024, they will have the benefit of seeing what trends have emerged from the first two years of reports published by larger Employers.
The gender pay gap in Ireland has fluctuated over the years with Eurostat data showing that the gap went from 12.7% in 2011 to 14.4% in 2017 and back down to 11.3% in 2019 which are the latest figures available from that source. The CSO has also recently published a Distribution of Earnings by Gender Report for 2022 which shows that while gender representation across all employments is relatively equal (51.3% male v 48.3% female), there is a far greater proportion of males in the top 10% of earners (70.3% v 29.7%).
The reason a gender pay gap exists in an Organisation depends on a number of factors but the key takeaway from all the recent data that has been compiled is that men occupy senior and higher paid roles in greater proportion to women. The breakdown among the top 1% of earners is even more unevenly balanced in favour of men (74.8% v 25.2). Essentially, the more men that occupy the senior and higher paid positions in an Organisation, the greater that Organisation’s gender pay gap is likely to be.
How to Prepare for Gender Pay Gap Reporting Obligations
Organisations that are preparing to publish a gender pay gap report for the first time in 2024 may find the trends outlined above useful as a comparison tool against the pay data that emerges from their own review.
In practical terms, Organisations with 150 or more Employees should ensure that they take the following steps to comply with their gender pay gap reporting obligations in 2024:
Understand the Reporting Requirements
Organisations must choose a June snapshot date that also determines their reporting deadline, which is exactly 6 months after the June date selected. If your Organisation chooses 17th June 2024 as the snapshot date, the Gender Pay Gap Report must be published no later than 17th of December 2024.
The legislation requires Organisations that fall within its scope to report on the difference in remuneration between male and female employees in the following areas:
- the difference between both the mean and median hourly pay of male and female Employees;
- the difference between both the mean and median bonus pay of male and female Employees;
- the difference between both the mean and median hourly pay of part-time male and female Employees; and
- the percentage of male and female Employees who received bonuses and benefits-in-kind.
If a gap is identified from the pay data, Employers must also publish the reasons for any differences in pay between male and female Employees and the measures that are either in place or proposed to reduce or eliminate the gap.
Calculate Employee Numbers
Assess the number of Employees on the snapshot date in June. Any worker who has a contract of employment (full time, part time, fixed term, or specific purpose) with your Organisation on the snapshot date is an Employee for the purposes of the gender pay gap reporting obligations.
Access the Required Data
Organisations must then work back from the snapshot date to compile the relevant pay data. The relevant pay data is taken from the 12 month period immediately preceding and including the snapshot date. It may be necessary to obtain input from a range of stakeholders within the Organisation including, HR, finance, and senior leadership teams. The sooner the relevant stakeholders are identified the better.
Consider How to Communicate the Outcome
Depending on the outcome of this pay review exercise, a communications plan and strategy for dealing with any queries that might arise should be developed. If a small or negligible gap is revealed, this could obviously be highlighted as a positive reflection of the Organisation’s approach to equal opportunities. On the other hand, if a large pay gap is revealed, the Organisation should develop a narrative to explain why the pay gap exists and what is being done to reduce it.
Take Action to Reduce a Gender Pay Gap
If your Organisation discovers that there is a gender pay gap issue to be addressed, identify the reasons and consider what HR practices might need to be changed to reduce the pay differentials. This could involve examining policies around recruitment, learning and development, diversity and inclusion and work life balance but each Organisation will have its own specific reasons to address.