Gender Pay Gap Reporting: New Legislation Proposes Additional Employer Obligations

The publication of the Employment Equality and Institutional Burials (Amendment) Bill 2026 (the Bill) includes an anticipated change to existing gender pay gap reporting arrangements.

The Bill proposes amendments to the Employment Equality Act 1998 that would require Organisations within scope to report their gender pay gap information to the Minister for Children, Disability and Equality, alongside their existing publication obligations.

What would the proposed legislation introduce?

Reporting to the Minister

The key aim of the Bill is to establish a formal requirement for in-scope Organisations to submit their gender pay gap information to the Minister. This would add a reporting obligation to the existing framework under which Organisations publish their gender pay gap results.

Confirmation of the accuracy of reported information

In-scope Organisations would also be required to confirm the accuracy of the information submitted, qualified by the wording “in so far as” the Employer is aware.

A process for correcting non-compliant submissions

The proposed legislation provides for the Minister to return an Employer’s statement where it does not satisfy the applicable requirements. The Organisation would then need to rectify the identified issues and resubmit the statement in accordance with the relevant rules.

Publication and comparison of gender pay gap data

The Bill would also provide the Minister with authority to publish the information received in accordance with the relevant regulations and to use it for comparison purposes.

Further detail on how this power will operate is expected to be confirmed in the implementing regulations. It can be assumed that the Government’s online portal, which has been available for voluntary registration since November 2025, is likely to be the vehicle for both reporting to the Minister and making comparisons.

What action should Organisations take?

Organisations with 50 or more Employees should continue to prepare for and fulfil their existing gender pay gap reporting obligations for the 2026 reporting cycle.

At the same time, those Organisations should be aware of the proposed requirement to report information to the Minister through the online portal. This requirement is expected to become a legislative obligation before the November reporting window opens, subject to the progress and commencement of the legislation.

In-scope Organisations should therefore monitor developments concerning the Bill and any guidance issued on the new reporting arrangements.

What happens next?

The Bill is still progressing through the legislative process and has not yet become law. Its provisions may change before enactment, and the precise requirements will depend on the final legislation and any regulations subsequently introduced.

Employers should keep the proposed changes under review to ensure they are ready to meet any additional requirements applicable to the 2026 reporting cycle.

How Adare Can Help

Organisations that take a proactive approach to gender pay gap reporting will be better positioned to demonstrate transparency, accountability and commitment to workplace equality.

Adare’s Pay and Pay Equity Services are here to ensure your Organisation meets the new November deadline. Our expert team will:

• Thoroughly analyse your pay data for full GPG compliance
• Pinpoint disparities and deliver actionable insights
• Prepare your official GPG report ensuring timely publication

Minimise the risks of non-compliance and let Adare take the hassle out of preparing your GPG report.

Book Your GPG Consultation Now