Q1 2025 Employment Law Update

Our Employment Law & Benefits team reviews the key changes in the area of employment law for Q1 2025. In addition, they provide an overview of what employers need to know.

Executive summary

• National minimum wage increase: The national minimum hourly rate of pay increased to €13.50.
• No increase in paid statutory sick leave: The Minister for Enterprise, Trade and Employment has announced that the entitlement to paid statutory sick leave will remain at five days per calendar year.
• New legislation: The General Scheme of Equality (Miscellaneous Provisions) Bill 2024 was published. The Employment Permits Act 2024 was commenced. In addition, the Employment (Contractual Retirement Ages) Bill 2025 was published.
• Spring Legislative Programme: A number of important legislative developments are listed for priority publication and drafting.
• Artificial Intelligence Act: The rules on prohibited AI practices under the Artificial Intelligence Act came into effect.
• Gender Pay Gap Reporting Portal: The Minister for Children, Equality, Disability, Integration and Youth has announced the introduction of a new gender pay reporting portal.

National minimum wage increase

The National Minimum Wage Order came into operation on 1 January 2025. This Order increased the national minimum hourly rate of pay for the purposes of the National Minimum Wage Acts 2000 and 2015 to €13.50 for those aged 20 years and above. A breakdown of the new minimum hourly rates of pay is set out below:

The national minimum hourly rate of pay may also include the following maximum allowances:

For board only €1.21 per hour worked.

For lodgings only €31.89 per week, or €4.55 per day.

No increase in paid statutory sick leave

The Sick Leave Act 2022 provides for paid statutory sick leave entitlements. Statutory sick pay is paid by an employee’s employer at 70% of their normal pay, up to a maximum of €110 a day. While the employer can offer a more generous sick pay scheme, they cannot provide less than the statutory amount.

The 2022 Act initially provided employees with an entitlement to 3 days of paid statutory sick leave per year. This was increased to 5 days in January 2024 with a further increase expected in January 2025, to 7 days per year. However, no increase occurred. A review of the scheme was carried out to consider the broader economic and competitiveness context of increasing costs on a multi-annual basis. Following this, it was announced, on 8 April 2025, that there will be no increase in paid statutory sick leave and the entitlement will remain at the 2024 rate of 5 days.

For more information on paid statutory sick leave, see:

Sick Leave Act 2022 Legislation Hub

Statutory Sick Pay in the Spotlight

Equality (Miscellaneous Provisions) Bill 2024

The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024 was published on 15 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 things:

Pay transparency

A proposal that employers provide information about salary levels or salary ranges in a job advertisement, 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 by 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 from 6 months to 12 months. A further 6-month extension for valid reasons is also proposed.

It also proposes that the maximum compensation which the Workplace Relations Commission (WRC) can award under the Employment Equality Act 1998, being €40,000, be extended to employees who have resigned prior to bringing a claim. Currently, the rules cap redress in these cases at €13,000.

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

The Bill provides for extension of time limits to apply for redress for discrimination at different stages of the process under the Equal Status Act 2000. It also raises the compensation limits that can be awarded under the Equal Status Act, from that of the District Court (€15,000) to the limit of the Circuit Court which is currently €75,000.

Spring Legislative Programme

The Irish Government’s Spring Legislative Programme was published on 18 February 2025. This set out the legislation for priority publication and drafting along with other legislation that has been tabled for this year. The list includes:

• Protection of Employees (Employers’ Insolvency) (Amendment) Bill
• Equality and Family Leaves (Miscellaneous Provisions) Bill
• Pay Transparency Bill
• Registration of Trade Unions Bill
• Regulation of Artificial Intelligence Bill
• Freedom of Information (Amendment) Bill

Employment Permits Act 2024

The Employment Permits Act 2024 is now in force, following the commencement order of 19 February 2025. The Seasonal Employment Regulations 2025 have also been published to facilitate the roll-out of the Seasonal Employment Permit Pilot Scheme.

The Employment Permits Act 2024 consolidates the existing employment permits legislation and introduces some significant changes to the law.

The new employment permits system, Employment Permits Online (EPOS), will launch on Monday, 28 April 2025. The new platform will require all users, including employers, employees and agents, to set up a portal account in order to access the system and to submit future employment permit applications.

For more information about the Employment Permits Act 2024:

Employment Permits Online Goes Live: 28 April 2025

Key Changes in the Employment Permits Act 2024

The Artificial Intelligence Act

The rules on prohibited AI practices under the EU Artificial Intelligence Act came into effect on 2 February 2025. Providers and deployers must ensure that their staff have a sufficient level of AI literacy.

Employment (Contractual Retirement Ages) Bill 2025

The Employment (Contractual Retirement Ages) Bill 2025 was published on 1 April 2025.

The Bill allows an employee to notify their employer if they do not agree to retire at the mandatory retirement age set out in their contract. Instead, the employee can request to continue working until the State Pension Age of 66. This applies in cases where the contractual retirement age is lower than 66. In order to avail of the right, certain notification requirements are proposed. If an employee notifies their employer that they do not agree to retire at the contractual retirement age, the employer cannot enforce the contractual retirement age without first providing a reasoned written reply, within one month of receiving the notification . This reply must set out the justification for the contractual retirement age. Retirement at this contractual age must be objectively and reasonably justified by a legitimate aim by the employer. In addition, the means of achieving the aim must be appropriate and necessary. If the employer does not provide this reasoned written reply, they cannot proceed with retiring the employee. In that case, the employee can continue working until either a date they agree to or the State Pension Age, whichever comes first.

The Bill provides for recourse to the WRC where the employee alleges a breach of its provisions. The Bill also prohibits penalisation or the threat of penalisation of an employee for proposing to exercise or having exercised their right to notify. A number of criminal offences are set out in the Bill for non-compliance.

The Bill has completed Dáil Éireann, First Stage.

For more information, see:

Employment (Contractual Retirement Ages) Bill 2025

Gender pay gap reporting portal

The Minister for Children, Equality, Disability, Integration and Youth has announced the introduction of a new gender pay reporting portal. The new online portal will simplify the process of gender pay gap reporting by consolidating reports from all private and public sector organisations onto one accessible database. The portal is intended to replace the requirement for organisations to publish reports on their own websites. However, the option will remain for employers to upload reports, with more information, to their own websites should they wish. The portal is intended to be launched in autumn 2025 and updated regulations will be required to facilitate this change ahead of this year’s reporting deadline of the end of November.

For more information, see:

New Gender Pay Reporting Portal

Conclusion

There have been a number of important changes to the law in Q1 2025. For specific advice as to how these changes might affect you, contact a member of our Employment Law & Benefits.

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