Employer Resources Newsletter - September 2025

HR Best Practice: Impact of Gender Pay Gap Reporting on the Nonprofit Sector

In 2025, 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. With many nonprofits preparing to publish a gender pay gap report for the first time this year, this article will explore the key aspects of compliance with the legislation as well as best practice measures around using gender pay gap reporting as a strategic HR tool.

Compliance with the Regulations

The most recent regulations governing gender pay gap compliance were published in May 2025.

Where an organisation is required to produce a gender pay gap information report, the regulations set out the following steps:

The organisation’s gender pay gap calculations will be based on their employees' remuneration for the 12-month period preceding a chosen snapshot date in the month of June.

For each person employed on the snapshot date, calculate their total ordinary pay, total bonus, identify benefits-in-kind (the 2024 Regulations widened the definition of “benefit in kind” to include share options and interests in shares) received and determine their total number of working hours worked for the reporting period. Calculate their hourly remuneration and note which employees were full-time, part-time or on fixed-term contracts over the reporting period.
Calculate the % of male and of female employees who were paid bonuses.
Calculate the % of male and of female employees who received benefits in kind.
Organise the employees into quartiles based on hourly remuneration of all male & female employees and calculate the proportions of male and female employees in each quartile.
Calculate the mean hourly remuneration of male and of female employees, then calculate the gender pay gap in mean hourly remuneration of all employees. Do the same for male and female part-time employees and for male and female employees on temporary contracts.
Calculate the median hourly remuneration of male and of female employees, then calculate the pay gap in median hourly remuneration of all employees. Do the same for male and female part-time employees and for male and female employees on temporary contracts.
Calculate the mean bonus remuneration of male and of female employees, then calculate the pay gap in mean bonus remuneration of all employees.

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.

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.

GPG Challenges for the Nonprofit Sector

While large organisations have the resources and infrastructure to comply with the gender pay gap reporting regulations, nonprofit organisations face more significant challenges. Nonprofit organisations with just over 50 employees may not have dedicated HR departments or extensive data management systems for instance. They may lack the resources to effectively analyse pay disparities, report the data, and implement corrective measures. Despite these challenges, nonprofits are encouraged to view gender pay gap reporting not just as a legal obligation but as a strategic opportunity for growth. Organisations that invest in closing the gender pay gap often see improvements in employee morale, engagement, and overall performance.

Strategic HR Considerations

So, while the introduction of gender pay gap reporting requirements means additional administrative and financial costs to gather, analyse, and report the required pay data, there are several long-term benefits associated with ensuring compliance:

Promoting a More Inclusive Workplace: Even relatively small nonprofit organisations can benefit from promoting gender equality by addressing pay disparities. With the increased focus on gender pay gap reporting, nonprofits are incentivised to foster an inclusive culture where employees are paid fairly for their work.
Improved Talent Retention and Recruitment: As jobseekers gain more pay transparency rights in the coming years, organisations that disclose their gender pay gaps and make efforts to close them may have a competitive edge in attracting candidates to fill vacancies. Conversely, failure to address the issue could result in losing out on skilled employees who value transparent pay practices.
Enhanced Reputation: Compliance with the gender pay gap regulations helps foster a reputation as a fair employer that is committed to diversity and inclusion. For nonprofits, this can be vital for attracting employees with the values required for working in the sector.

Is Your Gender Pay Gap Report on Track?

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 organisations ensure they are devoting enough resources to what can be an involved and specialised process.

As the November publication date is fast approaching, organisations should consider seeking external support to ensure compliance with their gender pay gap reporting obligations. As well as the technical pay data analysis, senior leadership teams need to 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 that emerges from the data. This narrative should also outline any steps the organisation might commit to in an effort to reduce any gender pay gaps.

How Adare’s Gender Pay Gap Service Helps

Reporting on the gender pay gap is not straightforward. A considerable amount of data must be gathered, analysed, and produced in a detailed report along with the actions to be taken after the report has been published.

Adare understand the pain points and potential pitfalls organisations face and offer a solution that:

Analyses your organisation’s pay data
Identifies pay disparities and provides clear pay insights
Prepares your organisation’s gender pay gap report in a format that is ready for publication.

The Wheel's Pay and Benefits in the Community & Voluntary Sector Report

In December 2024, with the support of Community Foundation Ireland, The Wheel launched the sixth edition of Pay and Benefits in the Community & Voluntary Sector, a survey examining pay levels across Ireland’s community, voluntary and charity organisations.

The publication appears at a time of considerable change and challenge for the sector. Its purpose is to present a detailed overview of pay and benefits, while also analysing key HR indicators such as absence and turnover rates, investment in staff training, and other measures. The report also considers the priorities of HR departments, highlighting the shared challenges experienced by organisations within the community and voluntary field.

The research was conducted by NfPResearch on behalf of The Wheel, with input from 592 organisations employing more than 10,800 staff and involving 34,272 volunteers. Funding was provided by Community Foundation Ireland.

Download the report in full here.

Watch the report launch recording here.

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 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 organisation.

Dublin Office: (01) 561 3594 | Cork Office: (021) 486 1420 | Shannon Office: (061) 363 805

info@adarehrm.ie | www.adarehrm.ie

WRC / Labour Court Decisions

General Manager Awarded €97,666 for Gender Discrimination Relating to Equal Pay

The Adjudicator determined that the complainant has been discriminated against on the ground of gender and her entitlement to equal pay and was determined to be €97,666.

Background

The complainant employee assumed greater managerial responsibility over a period of time. The complainant claimed that she was discriminated against on the ground of gender relating to equal pay.

Summary of Complainant’s Case

The complainant stated that she was appointed General Manager of the organisation in 2017 on a basic salary with promise for a review in the future. The previous General Manager who was a male, had an annual remuneration in excess of the complainant’s remuneration. The complainant stated that as General Manager, her remuneration was also significantly below a male marketing contractor’s remuneration, who was engaged on a contract for service. She noted that the work she performed was of equal value yet remunerated significantly less than these two other posts.

Summary of Respondent’s Case

The respondent stated that the complainant was a valued employee. They noted that her appointment to the General Manager role was based on a governance requirement and that her principal duties up to this point had been confined to certain areas. The respondent put forward that the work that the complainant was performing was fundamentally different to both of the two noted male comparators, who had more senior strategic responsibilities and that the difference in remuneration could be justified based on the work performed as assessed by objective criteria relating to skill, experience and responsibility.

Findings and Conclusions

The adjudicator noted that the respondent, once the presumption of discrimination had been established, must prove the contrary.

The adjudicator was satisfied that the respondent had established that the role of the previous male General Manager involved performance of work of a greater value than the complainant’s role in that he had overall commercial responsibility for the organisation, and the complainant had not. It was therefore found that the complainant was not discriminated against on the ground of gender in this instance.

The adjudicator noted that the complainant established facts from which it may be presumed that there had been pay discrimination having regard to the absence of transparency in pay determination between her and the male marketing contractor comparator. The respondent had not provided an adequate explanation for the difference in pay between her role and that of the male marketing contractor and in the absence of an adequate explanation, it was determined that the complainant was discriminated against on the ground of gender and entitled to the same remuneration as this comparator.

Whilst the respondent put forward that the difference in career background and work performed by the marketing contractor was fundamentally different to justify the pay difference other than gender, the adjudicator noted that this had not proven why he was paid a greater amount, especially given that the complainant had evidenced that she was the most senior executive in the organisation and that she performed a role of greater value. It was found therefore not credible that the work performed by the male marketing contractor comparator would trump and have greater monetary value to the most senior role in the organisation.

Decision

The adjudicator determined that the complainant has been discriminated against on the ground of gender and her entitlement to equal pay, based on the absence of transparency relating to pay determination, was determined to be €97,666.

Recommendations for Employers

It is essential for employers to remember that, when faced with a discrimination claim, once the presumption of discrimination has been established, the onus is on the employer to prove the contrary. In this case, the employer did not provide an adequate explanation for the difference in pay between the female claimant’s role and the male comparator role and in the absence of an adequate explanation, it was determined that discrimination had occurred on the ground of gender. In such instances, employers will need to be able to show full transparency in relation to pay determination and be able to objectively demonstrate why roles have similar or different levels of responsibility, justifying the value of the associated remuneration package.

Furthermore, the male comparator in this instance was a contractor who worked for the respondent organisation on a contract for service. Employers should be aware that, whilst this is a contract for service, it is a contract of employment for the purposes of the Employment Equality Act.

Did You Know?

18 September is International Equal Pay Day: A Timely Reminder of Upcoming Pay Transparency Obligations

18 September marks International Equal Pay Day an annual call to action to close the gender pay gap. For employers across Ireland and the EU, the day also serves as a timely reminder of increasing regulation under the EU Pay Transparency Directive which is due to be implemented no later than June 2026.

What Is International Equal Pay Day?

International Equal Pay Day, observed annually on 18 September, highlights the ongoing issue of pay inequality between men and women worldwide. It was established by the United Nations to recognise persistent gender-based wage disparities and to promote concrete actions aimed at achieving equal pay for work of equal value.

Despite the principle of equal pay for equal work being enshrined in law for decades, the gender pay gap remains a reality across many sectors. According to Eurostat statistics, women in the EU earned on average 12% less per hour than men in 2023. In Ireland, the gap stood at 8.6%.

The EU Pay Transparency Directive – What Employers Need to Know

The EU Pay Transparency Directive, adopted in 2023 at EU level, represents a significant shift in how employers will be expected to address pay equality.

The Directive aims to enhance pay transparency and strengthen the enforcement of equal pay principles. Domestic legislation transposing the new rules into Irish law will be required by June 2026. Key provisions include:

1. Gender Pay Gap Reporting

Ireland has already introduced gender pay gap reporting. The Directive does however include wider compliance obligations including a requirement to report on any gender pay gap between “categories of workers” that do equal work or work of equal value.

2. Pay Transparency for Jobseekers

Employers must provide information about the initial pay level or its range in job vacancy notices or before the interview stage. Organisations will also be prohibited from asking candidates about their own pay history or existing rate of pay.

3. Right to Pay Information for Employees

Current employees will be entitled to request information on their pay level and the average pay levels, broken down by sex, for categories of employees doing the same or equivalent work.

4. Pay Assessment and Justification

Where a gender pay gap of more than 5% is identified and cannot be justified on objective gender-neutral criteria, employers may be required to conduct a joint pay assessment in cooperation with employee representatives.

5. Ban on Pay Secrecy

The Directive prohibits contractual terms that restrict employees from disclosing or discussing their pay.

Preparing for 2026

While the Directive will not be transposed into Irish law until 2026, now is the time for employers to begin preparing. We recommend the following steps:

Conduct internal pay audits to identify any unexplained pay disparities.
Review recruitment practices for compliance with the incoming increased regulation.
Update Employee Handbooks and contracts to identify if they contain pay secrecy clauses.
Develop internal processes for handling employee requests for pay information.
Train HR and line managers on the new legal obligations and communication protocols.

A Call to Action

International Equal Pay Day is s a timely prompt for action. The upcoming EU Pay Transparency Directive will bring about increased compliance obligations around how pay is managed, reported, and communicated.

Compliance will not only mitigate legal risk but also contribute to building a more equitable and transparent workplace. As we mark Equal Pay Day on 18 September, it is a good opportunity for all organisations to assess current pay practices and begin preparing for the new pay transparency framework which will be in place next year.

If your organisation would like guidance on conducting a pay audit or preparing for the EU Pay Transparency Directive, Adare’s experts are here to assist. Please contact us to learn more about how our Reward and Pay Equity Services can support your organisation’s pay transparency objectives.

Dublin Office: (01) 561 3594 | Cork Office: (021) 486 1420 | Shannon Office: (061) 363 805

info@adarehrm.ie | www.adarehrm.ie

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