Our Employment & Benefits team reviews the key changes in the area of employment law for Q3 2025. They also provide an overview of what employers need to know.
What you need to know
- GPG reporting: New Regulations provide that employers with 50 or more employees are subject to gender pay reporting obligations. The Regulations also provide for an earlier reporting date than previous years, being November 2025.
- Corporate Sustainability Reporting: The Irish Government enacted a Statutory Instrument implementing the Stop-the-Clock Directive. The European Financial Reporting Advisory Group published revised European Sustainability Reporting Standards for public consultation.
- Social Welfare (Bereaved Partners and Miscellaneous Provisions) Act 2025: The Act was signed into law in July 2025.
- Equality (Miscellaneous Provisions) Bill 2024: The Bill is to be renamed and is currently subject to pre-legislative scrutiny.
- Prospective legislation: The Government has published its Legislative Programme for autumn 2025.
- Revenue disclosure opportunity for misclassification of employees: Revenue launches a disclosure opportunity relating to the Karshan judgment.
Key updates
Employment Equality Act 1998 (Section 20A) (Gender Pay Gap Information) (Amendment) Regulations 2025
The Regulations provide that employers with 50 or more employees, reduced from 150 or more employees, are subject to gender pay reporting obligations as set out in section 20A of the Employment Equality Act 1998 (as amended). The Regulations provide for an earlier reporting date than previous years, that being November 2025.
Corporate Sustainability Reporting
Over the past year, there have been a number of developments relating to the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD) both nationally and at EU level. For more information, read an insight from our ESG team.
The Irish Government enacted a Statutory Instrument implementing the EU’s Stop-the-Clock Directive: the European Union (Corporate Sustainability Reporting) Regulations 2025. Among other changes, the Stop-The-Clock Directive brings in a two-year reporting deferral for so-called “wave 2” and “wave 3” companies.
The European Commission adopted “quick fix” amendments to the first set of European Sustainability Reporting Standards (ESRS) in July 2025. The aim of the amendments was to reduce the burden for “wave 1” companies that had to start reporting for the 2024 financial year.
The European Financial Reporting Advisory Group published revised ESRS for public consultation in July 2025. This public consultation survey closes on 29 September 2025 and the Group will provide its final technical advice to the European Commission by the end of November 2025.
Social Welfare (Bereaved Partner’s Pension and Miscellaneous Provisions) Act 2025
The Social Welfare (Bereaved Partner’s Pension and Miscellaneous Provisions) Act 2025 was signed into law on 21 July 2025. For more information, see our recent insight.
Equality (Miscellaneous Provisions) Bill 2024
The General Scheme of the Bill was published in January 2025. It contains proposals to amend a number of Acts, including:
- The Employment Equality Act 1998
- The Equal Status Act 2000
- The Intoxicating Liquor Act 2003, and
- The Workplace Relations Act 2015
The Bill was recently renamed as the Equality and Family Leaves (Miscellaneous Provisions) Bill in Legislative Programmes for spring, summer and autumn 2025. The General Scheme is currently undergoing pre-legislative scrutiny before the Joint Committee on Children and Equality.
Government’s Legislative Programme for Autumn 2025
The Government has published its Legislative Programme for autumn 2025. The plan is divided into Legislation for Priority Publication, Legislation for Priority Drafting and all Other Legislation.
Legislation for priority drafting
- Equality and Family Leaves (Miscellaneous Provisions) Bill A Bill providing for amendments to the Employment Equality and Equal Status Acts, arising from a review of the Equality legislation. This Bill will also provide for Surrogacy Leave and leave for pregnancy loss. Revised Heads are in preparation and pre-legislative scrutiny is underway.
- The Regulation of Artificial Intelligence and Non-Personal Data Bill The overarching purpose of this Bill is to support innovation and economic growth. It creates a harmonised framework on fair access and use of data. In addition, it clarifies who can create value from data and under which conditions. It will also implement the EU Regulation on Artificial Intelligence into national law, including the establishment of the national AI central office. Heads are currently in preparation.
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.
Revenue launches a disclosure opportunity
The Revenue Commissioners have announced that employers can correct payroll tax issues for 2024 and 2025 arising from genuine classification errors, without the imposition of interest and penalty. Employers who acted in good faith relying on case law and guidance available prior to the judgment in The Revenue Commissioners v Karshan (Midlands) Ltd. t/a Domino’s Pizza[1] and who misclassified employees as contractors as a result, have been encouraged to use this disclosure opportunity to correct their tax affairs.
Disclosures must be submitted by 30 January 2026 and all liabilities must be paid in full. Where an employer fails to make a disclosure by this date, and liabilities from misclassification subsequently are discovered, tax, interest and penalties will be applied in full.
Comment
There have been a number of important changes to the law in Q3 2025. For specific advice as to how these changes might affect you, contact our Employment & Benefits team.
The content of this article is provided for information purposes only and does not constitute legal or other advice.
[1] [2023] IESC 24.
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