2025 in Review: Employment Law & Pensions

This year saw significant legal developments in both employment law and pensions, many of which set the stage for sweeping changes to come in 2026. Our Employment & Benefits team review the top five highlights of 2025.

What you need to know

• Gender Pay Gap reporting and thresholds: Gender Pay Gap reporting requirements were extended to organisations with 50+ employees. The much anticipated Gender Pay Gap portal, however, fell short of what was promised by the Department.
• Auto-enrolment: Originally scheduled to launch in September 2025, the Auto-enrolment Retirement Savings Scheme called ‘My Future Fund’ was delayed until 1 January 2026.
• Gender balance on corporate boards: The European Union (Gender Balance on Boards of Certain Companies) Regulations 2025 was enacted, designed to increase diversity on corporate boards of in-scope companies.
• Review of equality legislation: The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 was published in January 2025. It proposes to amend the Employment Equality Act 1998, the Equal Status Act 2000 and the Workplace Relations Act 2015. It has since undergone pre-legislative scrutiny by the Joint Oireachtas Committee on Children and Equality.
• Prospective legislation: Significant legislative work was carried out, including on the enaction of the Social Welfare (Bereaved Partner’s Pension and Miscellaneous Provisions) Act 2025 Act and the publication of the Employment (Contractual Retirement Ages) Bill 2025 and the Protection of Employees (Employers' Insolvency) (Amendment) Bill 2025. A number of other potentially impactful Bills have been earmarked in this year’s legislative programmes for drafting and publication.

2025 has proven to be a landmark year for Irish employment and pensions law. Many of the key developments this year were foundational, laying the groundwork for significant changes to come that will reshape employer responsibilities and employee rights.

Gender Pay Gap reporting and thresholds

This year, the Gender Pay Gap (GPG) reporting requirements contained in the Employment Equality Act 1998 (as amended) were extended to organisations with 50+ employees. The reporting deadline was also moved from December to November, giving employers just five months from their chosen snapshot date in June 2025 to report on their gender pay gap.

The Minister for Children, Equality, Disability, Integration and Youth announced that a new gender pay reporting portal would be launched ahead of this year’s reporting deadline. The portal promised to simplify the process of gender pay gap reporting by consolidating reports from all private and public sector organisations onto one accessible database. The portal intended to replace the requirement for organisations to publish reports on their own websites.

The Department originally estimated that 6,000 companies would have use of the portal. However, it has recently indicated that the portal will now launch as a “pilot scheme” only and be available to “select employers”.

Read: New Gender Pay Reporting Portal - What employers need to know

Auto Enrolment

Originally scheduled to launch in September 2025, the Auto-enrolment Retirement Savings Scheme called ‘My Future Fund’’ has been delayed until 1 January 2026.

Employees will be automatically enrolled in the scheme if they are aged between 23 and 60, not currently part of a pension plan and earn €20,000 or more a year. Under the scheme, the employer, employee and Government all pay a certain amount into the employee’s fund. Employers who do not meet their obligations under the scheme may be subject to penalties.

The amount paid into the scheme will depend on the employee’s salary. In year one to three, the employer and employee will pay 1.5% of the employee’s annual salary each into the scheme. The Government pays 0.5%. These amounts increase in increments as the years progress. After 10 years the employee contribution rate is 6%, the employer contribution rate is 6% and the Government contribution rate is 2%. It is not permissible to pay more or less than the set rate.

Both the employer’s and the Government’s percentage contributions are capped based on a gross annual salary of €80,000 per year. If the employee earns more than €80,000 gross per annum, the employee can still contribute but the employer and the Government will not match the employee’s contributions on any income over €80,000.

The Minister for Social Protection formally established the National Automatic Enrolment Retirement Savings Authority (NAERSA) in October 2025. NAERSA will oversee the auto-enrolment scheme, handle administration requirements and invest contributions on the participants’ behalf.

The Department of Social Protection announced, in December 2025, some last-minute changes to how auto-enrolment will be rolled out, these included the imposition of minimum contribution rates to occupational pension schemes of 3.5% of salary, of which 1.5% must be paid by the employer. The Department also indicated that, where existing employees are enrolled in pension schemes, their consent must be obtained. We are awaiting legislation underpinning these changes.

Read: Minimum Pension Contribution Rates to be Introduced - Urgent Pensions Auto-Enrolment Update

Gender balance on corporate boards

The European Union (Gender Balance on Boards of Certain Companies) Regulations 2025 came into force on 30 May 2025. They implement Directive (EU) 2022/2381. The measures are aimed at improving diversity on the boards of companies that have their registered office in Ireland and whose shares are admitted to trading on a regulated market in at least one Member State. They do not apply to micro, small or medium-sized enterprises (SMEs).The Regulations introduce legally binding requirements to improve the representation of women on the boards of in-scope companies in Ireland. In-scope companies must ensure that at least 40% of non-executive director roles are held by members of the “underrepresented sex” by 30 June 2026. In addition, they must set quantitative objectives to improve gender balance among executive directors and specify how this has been/is to be achieved. These obligations are supported by strict reporting, publication, and selection process rules, with annual compliance required.

Non-compliant companies will be publicly named from 1 December 2027 onwards.

Read: New Gender Balance Rules for Boards

Review of equality legislation

The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 was published in January 2025. It proposes to amend the Employment Equality Act 1998, the Equal Status Act 2000 and the Workplace Relations Act 2015 to provide for, among other significant changes:

Pay transparency

The Bill includes a proposal that employers provide information about salary levels or salary ranges at job advertisement stage, prior to employment. The Bill also prohibits employers from asking job applicants about their own pay history or their current rate of pay. These proposals aim to implement Article 5 of the Pay Transparency Directive, which Ireland must transpose into national law by 7 June 2026.

Extension of time limits and changes to compensation amounts under EEA

The Bill proposes an extension of the time limits that apply when bringing claims under the Employment Equality Act 1998 (EEA) from 6 months to 12 months. A further 6-month extension for valid reasons is also proposed.

Currently, the EEA provides at section 82(4), that the maximum amount which may be ordered by the Workplace Relations Commission (WRC) by way of compensation is:

“(a) in any case where the complainant was in receipt of remuneration at the date of the reference of the case, or if it was earlier, the date of dismissal, an amount equal to the greatest of
104 times the amount of that remuneration, determined on a weekly basis,104 times the amount, determined on a weekly basis, which the complainant would have received at that date but for the act of discrimination or victimisation concerned, or €40,000, or in any other case, €13,000.”

Currently, as noted in the recent case of Jasmine Olaru v Remo Foods Limited t/a Domino’s Pizza[1], a complainant who has left their employment prior to the date of reference of an EEA case to the WRC, without necessarily being dismissed, like in the event of a resignation, is entitled only to a limited award of €13,000. Head 11 of the Equality (Miscellaneous Provisions) Bill 2024 proposes to rectify this by extending the maximum compensation of €40,000 to employees who have resigned prior to bringing a claim.

Extension of time limits and changes to compensation amounts under Equal Status Act

Head 16 of the Bill provides for an extension of time limits to apply for redress for discrimination. These extensions apply at different stages of the process under the Equal Status Act 2000. Head 17 raises the compensation limits that can be awarded under the Equal Status Act. The current limit of the District Court, which is €15,000, will be increased to match the limit of the Circuit Court. This is currently set at €75,000.

The Bill was renamed as the Equality and Family Leaves (Miscellaneous Provisions) Bill in Legislative Programmes for spring, summer and autumn 2025. The General Scheme was subjected to pre-legislative scrutiny by the Joint Committee on Children and Equality in July 2025. The recommendations are to be passed on to the Minister for consideration. Read the full report

Prospective legislation

Significant legislative work has also been carried out in 2025, including the enaction of the Social Welfare (Bereaved Partner’s Pension and Miscellaneous Provisions) Act 2025 Act, and the publication of both the Employment (Contractual Retirement Ages) Bill 2025 and the Protection of Employees (Employers' Insolvency) (Amendment) Bill 2025.

The spring, summer and autumn Legislative Programmes for 2025 have also highlighted a number of upcoming Bills, which will be keenly anticipated. These include:

• Legislation for priority drafting
• Equality and Family Leaves (Miscellaneous Provisions) Bill
• The Regulation of Artificial Intelligence and Non-Personal Data Bill

Other Legislation

• Gender Pay Gap Information (Amendment) Bill - A Bill to clarify the legislative basis for employers to report their gender pay gap to the Minister via a central online portal. Heads are currently in preparation.
• Standards for Equality Bodies Bill - A Bill to transpose Council Directive (EU) 2024/1499 on standards for equality bodies into national law. Heads are currently in preparation.
• Pay Transparency Bill - A Bill to transpose the EU Pay Transparency Directive into national law. Heads are currently in preparation.
• Registration of Trade Unions Bill - The purpose of the Bill is to modernise and consolidate the existing legislation regarding the registration requirements for trade unions. Heads are currently in preparation.
• Freedom of Information (Amendment) Bill - Update to the Freedom of Information legislation arising from the review of the current Act. Work is ongoing.
• Occupation Pensions (Amendment) Bill - The Department of Social Protection is currently working, in conjunction with the Pensions Authority, to develop detailed policy and legislative proposals relating to the regulation and supervision of Master Trust pension schemes and to ensure the appropriate statutory protections are provided for these schemes. Work is ongoing.

What to look out for in 2026

• Implementation: Looking ahead, 2026 is set to be a year of major implementation as the groundwork laid in 2025 comes to fruition, most notably the official launch of the ‘My Future Fund’ on 1 January.
• Transposition of Pay Transparency Directive: The Pay Transparency Directive is due to be transposed by 7 June 2026. The Government seems to be adopting a two-bill approach to transposition: The Equality and Family Leaves (Miscellaneous Provisions) Bill which is earmarked to transpose Article 5 of the Directive only and the Pay Transparency Bill, the Heads of which are yet to be drafted.
• Transposition Platform Work Directive: The Platform Work Directive is due to be transposed by 2 December 2026. The Directive is aimed at improving working conditions and the protection of personal data in platform work.
• Revenue disclosure opportunity: Recently, the Revenue Commissioners has announced that employers can correct payroll tax issues for 2024 and 2025 arising from bona fide classification errors, on a favourable tax basis and without imposition of interest and penalty. Disclosures must be submitted by 30 January 2026, and all liabilities must be paid in full.

For specific advice as to how these changes might affect your organisation, contact our Employment Law & Benefits team.

The content of this article is provided for information purposes only and does not constitute legal or other advice.

[1] ADJ-00044923.