At Gallagher Keane, we are committed to keeping our network informed on key developments in employment law and HR. In this update, we are sharing insights from our client, Rosanne of Edger HR Consulting, covering the Pay Transparency Directive, the EU AI Act, and other important employment matters.

Pay Transparency Directive – Relevant to All Employers

The Pay Transparency Directive represents a significant shift in pay governance.  While delays have been announced,  it should be transposed into Irish legislation in June 2026. It is now expected to happen on a phased basis. While timelines may be extended, employers should begin preparing now.

It is likely that the first elements to be introduced will include:

• Providing salary bandings to candidates
• Banning pay history questions
• Prohibiting pay secrecy clauses/ mandates

Additional obligations will include:

• Employees’ right to pay information to include their pay levels, as well as average pay levels by gender for those doing the same work or work of equal value
• Make accessible transparent, objective and gender-neutral pay criteria
• Expanded gender pay gap reporting to include breakdown by worker categories 
• Potential joint pay assessments where a gap of at least 5% s remains that cannot be objectively justified

While this will be confirmed in legislation, these final three points are likely to apply to employers with 50+ employees.

Employers should begin reviewing pay structures, job roles and internal processes now, as well as preparing managers for more transparent pay discussions.

EU AI Act – Relevant to All Employers

The EU AI Act, in force since 2024, introduces a risk-based framework for organisations using AI, with full implementation by August 2026.

Organisations should:

• Identify where AI is used
• Categorise risk levels and take required actions 
• Ensure appropriate employee training and AI literacy

Additional Updates:

Statutory Sick Pay (SSP)
SSP remains at 5 days per year, with planned increases currently deferred.

Work Permit Salary Levels
From 1 March 2026:

• General Employment Permit: €36,605 per annum
• Critical Skills Employment Permit: €40,904 per annum

Employers should account for these increases at renewal stage.

Data Subject Access Requests (DSARs)
DSARs are increasing.  Employers are required to respond within 30 days, unless certain specific reasons apply to provide for an extension (max 2 additional months). Data subjects e.g. employees may request access to all personal data, including emails where they are the data subject. Prompt action and careful handling, including potential redactions, are essential.

Please note that this article does not form legal advice.  It was written for informational purposes only. 

Contact Rosanne Edger:

The above insights are provided by Rosanne Edger, MCIPD from Edger HR Consulting. If you would like to discuss how these updates may impact your organisation, please contact Rosanne Edger:

Email: rosanne@edgerhr.ie
LinkedIn: Rosanne Edger | Edger HR Consulting Ltd