Has Your Organisation Picked its Gender Pay Gap Reporting Snapshot Date?

This year, the Employee threshold triggering the requirement to publish a gender pay gap report moves from Organisations with 150 or more Employees to those with 50 or more Employees. According to Department of Children, Disability and Equality estimates, the reduced Employee threshold will bring as many as 6,000 Organisations within the scope of the Gender Pay Gap Information Act 2021. 2025 will therefore be the first year many Organisations prepare to publish a gender pay gap report. This article will explore the key aspects of compliance with the legislation, the correct pay data to be gathered and the importance of early preparation in project managing what can be a technical process involving various stakeholders.

Gender Pay Gap Compliance

As outlined in the introduction, Organisations with 50 or more Employees fall within the scope of the gender pay gap reporting legislation in 2025. This year will be the first time many Organisations face into the task of preparing a gender pay gap report. Some of the key compliance questions faced by first time reporters include….

What is the Snapshot Date?

Employers in scope of the legislation Employers are required to choose a snapshot date. The snapshot date must be in June but may be any date in June. The Organisation’s gender pay gap calculations will be based on their Employees’ remuneration for the 12-month period that precedes the snapshot date.

When Does the Organisation Assess the Employee Headcount?

“Headcount” or the number of Employees in an Organisation is determined on the snapshot date in June. Employee headcount includes:

• Employees on less-than-full-time
• Employees on secondment to another Organisation but still paid by the primary Organisation
• Employees on any type of statutory leave, including maternity leave (paid or unpaid).

Headcount excludes Employees who are on a career break for a period greater than 12 months on the snapshot date.

When is the Gender Pay Gap Report Published?

This year, the reporting deadline moves to November, a month earlier than previous years. Organisations must bear this tighter timeframe in mind. By way of example, if an Employer selects 17 June 2025 as their snapshot date, the gender pay gap report must be published no later than 17 November 2025.

What Pay Data Does Our Organisation Need to Analyse?

Organisations in scope are required (based on 12 months of pay data preceding the snapshot date) to publish a range of mean, median and quartile gender pay gaps.

Will Publishing the Relevant Pay Metrics Ensure Compliance?

As well as the required metrics, gender pay gap reports must also include the reasons a gender pay gap has developed in the Employer’s opinion and measures being taken by the Employer to reduce any gender pay gap that exists.

Where is the Gender Pay Gap Report Published?

From 2025, all gender pay gap reports will be made available on a centralised online portal that will be fully searchable by the public. The portal is scheduled to launch in the autumn.

Ensure the Correct Pay Information is Analysed

Pay data collection and analysis can be a technical and numerate process which may be best done in collaboration with HR and payroll teams and run through a project management framework or with the help of a dedicated HR consultancy.

During the first three years of gender pay gap reporting, the pay data to be gathered has included the differences between male and female Employee remuneration in terms of:

• Mean and median hourly pay
• Mean and median bonus pay
• Mean and median pay of part-time Employees
• Mean and median pay of employees on temporary contracts.

Further information required included:

• The proportion of male and female Employees that received bonuses
• The proportion of male and female Employees that received benefits in kind (e.g. company car)
• A breakdown of male and female Employees in each of four different pay quartiles – lower, lower-middle, upper-middle, and upper.

Once pay data are collected in June, work should begin promptly to translate them into the mandated metrics as reports must be published in November 2025.

Begin Preparations Early

Gender pay gap reporting is a technical area of compliance and with the reporting deadline moving a month earlier this year, it is vital that in-scope Employers begin preparing to project manage what can be an involved and specialised process.

As the June snapshot date is fast approaching, Organisations should consider the following compliance steps to begin their gender pay gap reporting:

• Ensure required pay data will be made available for analysis. May require cooperation with different stakeholders in finance and payroll departments for instance.
• Create a project plan well in advance of the snapshot date.
• Identify key stakeholders, deliverables, and timeframes to ensure the report is prepared in advance of the November deadline.
• Consider the narrative that will be included in the report considering any relevant industry or workplace factors that might explain the existence of a gender pay gap.
• Consider what steps the Organisation might commit to in an effort to reduce any gender pay gap that exists.

Irish employment law has been changing rapidly in recent years and it can be very challenging for businesses to stay on top of their compliance. If you would like to know more or get support from our experts on Gender Pay Gap Reporting, please contact us at 01 561 3594 or email info@adarehrm.ie.