Your completion checklist for gender pay gap reporting

Gender pay gap reporting in Ireland is finally upon us. All Irish companies with 250 or more employees must publish their reports on their websites by December 2022.

In the UK, which introduced gender pay gap reporting in 2017, the first reports generated significant interest among employees and the media. Overnight, the gender pay gap became a headline story.

In this update, we outline the five key actions to consider as you approach your publication date.

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1. Complete your calculations

The Gender Pay Gap Information Act 2021 outlines 11 specific data points that must be included in reports. Companies should ensure that:

  • they understand what is required;

  • they have gathered all relevant data; and

  • calculations are complete or substantially complete at this stage.

If not already done, the focus should now shift to conducting any additional analysis you may need to contextualise the numbers.

2. Document the approach taken

Your calculations will need to be re-run annually and your 2022 gender pay gap number will be the baseline against which annual progress will be measured.

You should ensure that your approach is well documented so that you compare like-for-like each year. And as some aspects of the legislation are unclear, judgement may be needed. In this context, documenting the rationale will be important.

3. Finalise your report

In addition to the reporting of certain data points, the legislation requires that companies:

  • explain the reason for the gap; and
  • outline the measures taken, or proposed, to close the gap.

Ensure that any reasons for the gap are evidence-based. Do the numbers support the reasons? Also, proposed actions to close the gap will need to be implementable.

In finalising your report, consider:

  • whether you need branding support to ensure that the report aligns with other company publications;
  • who in the organisation will do a final review. With so much detail involved in preparing the analysis, it may be useful to seek a fresh pair of eyes;
  • who will provide the final sign-off; and
  • who will be responsible for uploading the report to your website. Are they aware of the deadline?

4. Lock down your communications strategy

With a sensitive, technical topic like gender pay gap reporting, effective communications will be essential.

  • Ensure that you are prepared to execute your communications strategy.
  • Confirm that all senior stakeholders are briefed on the key messages for both internal and external audiences.
  • Consider whether you should nominate a team member to be responsible for responding to media queries and/or social media comments.

5. Start to prepare for year two

There will be a very short window between reporting in December 2022 and the next snapshot date in June 2023. To ensure that you can demonstrate progress in closing your gender pay gap, you must drive ongoing Diversity, Equity and Inclusion (DE&I) plans and consider whether new initiatives are required.


Gender pay gap legislation was first initiated in Ireland in April 2019. It was signed into law in July 2021 and we are fast approaching the first reporting deadline.

The steps companies take now in the run-up to publishing their reports will largely determine how their gender pay gap number will be received and understood, both internally and externally.

Our advice to employers is to prepare their completion checklist—and check it twice.

We are here to help you

For those organisations embracing DE&I, gender pay gap reporting presents a positive opportunity to strengthen their brand by promoting their efforts publicly. For those that are yet to embrace the topic, it provides a chance to understand the reality in their organisation, why a gender pay gap exists and the key contributors. They can then begin to make data-informed decisions. Our team is here to help you as you work through the process. Contact us today.

Contact us

Doone O'Doherty

Partner, PwC Ireland (Republic of)

Tel: +353 87 276 8112

Gerard McDonough

Partner, PwC Ireland (Republic of)

Tel: +353 87 224 1517

Anna Kinsella

Director, PwC Ireland (Republic of)

Tel: +353 87 967 0910

John Haran

Director, PwC Ireland (Republic of)

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