Employment law update: Key developments Irish employers should prepare for this autumn

Ireland's employment law landscape continues to evolve at pace, with significant developments in pay transparency, gender pay gap reporting, the use of artificial intelligence in the workplace and retirement age legislation all requiring employer attention. As organisations plan for the remainder of 2026, preparation rather than reaction remains key.

Pay Transparency Directive

Although the deadline for implementation of the EU Pay Transparency Directive (EU) 2023/970 passed on 7 June 2026, Ireland is among the majority of Member States that have yet to complete transposition.

It is not yet clear when the Directive will be transposed into Irish law. The Government's Summer 2026 Legislative Programme indicates that a Heads of Pay Transparency Bill is in preparation.

The Directive represents a significant strengthening of the principle of equal pay for equal work and work of equal value and is expected to bring substantial changes to recruitment practices, pay transparency obligations and equal pay enforcement.

For more information on the obligations contained in the Directive, see our previous update.

We will continue to monitor developments. The Department of Children, Disability and Equality has indicated that the reporting requirements introduced by the Directive will be implemented on a phased basis according to employer size.

Next steps for employers

Employers should begin preparing now by reviewing recruitment practices, assessing pay structures and identifying categories of workers performing equal work or work of equal value. Organisations may also benefit from conducting an initial pay audit and considering how future pay information requests and reporting obligations will be managed in practice.

Employers should also have regard to the EU guidelines on gender-neutral job evaluation and classification and consider whether existing job architecture, reward frameworks and compensation structures are capable of supporting future compliance requirements.

Gender Pay Gap Portal

On 18 June 2026, the Government made the Gender Pay Gap Portal available for public view.

The Portal enables employees, job applicants and other stakeholders to view and compare reported gender pay gap information across organisations, representing a significant step towards greater transparency.

The Government has confirmed that the Gender Pay Gap Information Act 2021 will be amended to require employers within scope to upload their reports to the Portal from the 2026 reporting cycle onwards.

The reporting obligations, which were introduced on a phased basis, now apply to employers with 50 or more employees.

Next steps for employers

For the 2026 reporting cycle, employers must choose a snapshot date in June 2026 and publish their gender pay gap information within five months of that date.

Given the increased visibility provided by the Portal, employers should ensure that both the content and presentation of their reports are carefully considered. Many organisations may also wish to review the narrative accompanying their data and identify any actions being taken to address underlying pay gaps.

Employers should note that, in addition to uploading reports to the Portal, they remain obliged to publish their Gender Pay Gap report on their own website or otherwise make it publicly available where no website exists.

EU AI Act: Draft guidelines on high-risk AI classification

The European Union's Artificial Intelligence Act (AI Act) entered into force on 1 August 2024. The AI Act identifies a number of employment-related AI systems that may be classified as high risk because of their potential impact on workers' rights, employment opportunities and career progression.

On 19 May 2026, the European Commission published draft guidelines on the classification of high-risk AI systems. The publication of the draft guidelines provides employers with greater clarity on how AI systems used in employment settings may be classified.

Most employers will be regarded as deployers under the AI Act. As the use of AI continues to increase across recruitment, workforce management and performance monitoring, ensuring compliance with the AI Act should become an important governance priority.

AI systems used for recruitment and selection, performance monitoring and certain employment-related decision making may be classified as high risk under the AI Act. The rationale for this classification is the potential impact such systems may have on individuals' employment opportunities, working conditions and fundamental rights, including equality, privacy and data protection rights.

Next steps for employers

Employers should consider conducting an audit of AI systems currently used across HR and management functions, reviewing contracts with technology providers and implementing appropriate governance measures. Training for HR personnel and managers, together with appropriate human oversight of significant employment decisions, should also be considered. Employers should review privacy notices and workplace policies where necessary.

Employment (Contractual Retirement Ages) Act 2025

The Employment (Contractual Retirement Ages) Act 2025 and the Workplace Relations Commission's updated Code of Practice on Longer Working came into effect on 29 June 2026.

The 2025 Act introduces a new statutory framework governing contractual retirement ages below the State pension age and creates a formal process through which employees may seek to remain in employment until age 66.

The legislation applies to employees whose contractual retirement age is below the State pension age and requires employers to carefully consider any request from an employee wishing to remain in employment beyond their contractual retirement age.

Employers who refuse such a request must be able to objectively justify the contractual retirement age by reference to a legitimate aim and demonstrate that the measure is appropriate and necessary. Legitimate aims may include considerations such as safety, physical capability requirements and succession planning, although each case will turn on its own facts.

Employees who believe their rights under the legislation have been breached may bring a complaint to the Workplace Relations Commission. Available remedies include reinstatement, re-engagement or compensation of up to 104 weeks' remuneration or €40,000, whichever is greater.

The legislation also prohibits penalisation of employees who notify their employer of an intention to remain in employment beyond their contractual retirement age.

Next steps for employers

Employers should review employment contracts, retirement policies and procedures to ensure they align with the new framework. Consideration should also be given to whether existing contractual retirement ages can be objectively justified where required. Training for HR teams and management should also be considered, together with the implementation of clear notification and record-keeping procedures.

Proposed paid leave following early miscarriage

The Government has announced plans to introduce a new statutory entitlement to paid leave following an early miscarriage, representing a significant development in workplace support for pregnancy loss.

On 14 July 2026, Cabinet approved proposals to provide five days of paid leave for women who experience a miscarriage before 23 weeks of pregnancy.
Currently, women are entitled to full maternity leave in the case of a stillbirth after 23 weeks' gestation. However, there is no equivalent statutory paid leave entitlement where a miscarriage occurs before that point.

The proposed Pregnancy Loss Leave Bill 2026 would provide for five days' paid leave together with associated employment protections, including protections against penalisation and dismissal connected with the exercise of these rights.

The text of the Bill has not yet been published and the proposal must still progress through the legislative process before becoming law.

Next steps for employers

While the legislation is still at proposal stage, employers should monitor developments closely and consider how any future entitlement may interact with existing family leave, sickness absence and employee wellbeing policies.

Looking ahead

The second half of 2026 continues to bring significant employment law developments for Irish employers. From pay transparency and gender pay gap reporting to AI governance, retirement age reform and proposed pregnancy loss leave, organisations face increasing compliance obligations and heightened scrutiny.

Employers that review policies, procedures and workforce practices now will be best placed to manage risk and respond effectively as these developments continue to evolve.

If you would like to discuss any of the developments outlined above or their potential impact on your organisation, please contact a member of our Employment team.