As Organisations across Ireland prepare for the 2026 gender pay gap reporting cycle, many Organisations have queried whether it is permissible to select a different snapshot date this June? In summary, the answer is yes, it is permissible to do so. Under the current legislative framework, Employers retain discretion in selecting a snapshot date during the month of June on which Employee remuneration data is captured for gender pay gap reporting purposes. There is no requirement to apply the same date year-on-year, provided that the chosen date falls within the prescribed reporting window.
Existing Legal Framework
At the date of writing, the existing Employment Equality Act 1998 (Section 20A) (Gender Pay Gap Information) (Amendment) Regulations 2025 governing gender pay gap reporting remain in force for the 2026 reporting cycle. These require Employers to:
- Select a snapshot date within the month of June; and
- Publish their gender pay gap report within five months of that date.
This approach affords Organisations a degree of flexibility in selecting a snapshot date that more accurately reflects workforce composition and pay structures. For example, Organisations may wish to avoid periods affected by seasonal workforce fluctuations, variable remuneration cycles, or organisational restructuring.
Notwithstanding this flexibility, consistency and transparency remain important considerations. Where an Organisation elects to change its snapshot date from that used in a prior reporting period, it would be prudent to clearly document and, where appropriate, disclose the rationale for any such change. This is particularly relevant where variations may impact the comparability of year-on-year data.
Anticipated Developments: EU Pay Transparency Directive
While the current reporting requirements remain unchanged for 2026, it is anticipated that Ireland’s gender pay gap reporting regime will evolve in line with the forthcoming EU Pay Transparency Directive later this year.
The Directive requires Employers to report on gender pay disparities across defined ‘categories of workers’ performing work of equal value. This represents a significant departure from the existing model, which focuses on aggregate organisational metrics.
The introduction of categorised reporting will necessitate:
- More detailed job classification and grading frameworks;
- Robust methodologies for assessing work of equal value; and
- Enhanced internal analysis of role comparability across the Organisation.
In addition, it has been confirmed that in-scope Organisations will be required to submit their gender pay gap reports to the State’s central Gender Pay Gap portal for the 2026 reporting cycle. While the portal operated on a pilot (voluntary) basis in 2025, it has been reported that legislative updates will make using the portal mandatory.
Recommended Preparatory Steps
In light of the anticipated reforms, Organisations should take proactive steps to ensure readiness for more detailed reporting obligations. In particular, Employers should consider:
- Reviewing and, where necessary, refining job classification structures;
- Ensuring that payroll and HR systems can support enhanced data collection and analysis;
- Developing clear and defensible approaches to assessing work of equal value; and
- Preparing for increased transparency and potential scrutiny from Employees and other stakeholders.
Conclusion
Organisations may, for the 2026 reporting cycle, select a different snapshot date within the permitted month of June and continue to report in accordance with the existing regulatory framework. However, any such change should be carefully considered and appropriately documented.
More broadly, Employers should remain cognisant of the significant changes on the horizon. Early preparation for the enhanced requirements under the EU Pay Transparency Directive will be essential to ensure compliance and to support effective organisational governance in a new era of pay transparency.
Adare’s Gender Pay Gap Reporting Services
Adare Trusted People Partners’ Reward and Pay Equity Services are designed to help in-scope Organisations to meet their evolving pay transparency compliance obligations.
Our Gender Pay Gap Analysis and Reporting service goes beyond compliance. Adare’s experts will:
- Analyse your pay data for full GPG compliance
- Identify any disparities and provide clear insights
- Prepare your official GPG report, ready for submission
How your pay data is reported will impact how your Organisation is perceived. Let Adare ensure your Organisation is ready to meet its gender pay gap obligations.
Adare’s Pay Transparency Services
We also support Organisations who are preparing for compliance with the EU Pay Transparency Directive by:
- Assessing readiness for Employee pay information requests
- Supporting the development of clear job architecture and role categorisation aligned with ‘work of equal value’ principles
- Reviewing pay structures, pay ranges and progression frameworks to ensure they are objective and defensible
- Conducting pay risk and equal pay assessments ahead of Employee requests
- Advising on practical processes for responding to pay information requests clearly, consistently and compliantly
- Supporting HR and leadership teams with guidance, training and communications as pay transparency obligations evolve
Adare is a team of expert-led Employment Law, Industrial Relations and best practice Human Resource Management consultants. If your Organisation needs advice, support, or guidance about pay transparency compliance requirements or any HR issues, please contact Adare by calling (01) 561 3594 or emailing info@adarehrm.ie to learn what services are available to support your business.