Gender pay gap portal: What it means for SMEs

Every Irish employer with 50 or more staff must now file its gender pay gap figures on a public Government portal. Reports are due in November, not December, a change many smaller firms may have missed. Crystel Robbins Rynne, CEO of HRLocker, sets out what SMEs need to do to get it right.

Until this year, a gender pay gap report could sit on a page of your website that few people ever found, let alone scrutinised. That’s changed.

Employers with 50 or more staff must now submit figures through the Government’s Gender Pay Gap Portal as well as publishing them on their own site. The portal is public and includes a one-click tool, allowing job candidates, customers or competitors to instantly compare your results with another firm’s.

The threshold dropped from 150 to 50 employees in 2025, so if you have staff numbers in that range, this is probably only your second report. If you’ve grown past 50 employees since last June, you’ll be doing this for the first time. As with most SMEs, you’re unlikely to have an HR team or a payroll analyst, meaning the workload usually lands on you, your finance lead or a single HR manager fitting it in around everything else.

It’s due five months after your June snapshot date, which means reports must be submitted in November. If this is your first time and you thought you had until December, that was the old rule, which also changed in 2025.

In a recent webinar on reporting at HRLocker, the questions we were asked showed exactly where smaller employers are getting stuck. In response, we’ve put together some general advice.

Register on the portal today

The portal asks you to enter figures into set fields, so it takes longer than uploading a finished PDF. Registering is a job in itself. If your accountant or payroll provider is helping, agree now who will register, who will enter the figures, and who will sign them off. Once filed, keep a printed copy on site too, as WRC inspectors have been asking to see one.

Work out who counts

Start with your headcount on your snapshot date, because it determines whether you’re required to report. If you had 50 or more employees that day, you’re in. Count everyone you employ, including full-time, part-time, permanent and temporary staff, people on leave and anyone not rostered to work that day.

The Government’s guidance also covers cases that catch smaller firms out. Staff who work abroad count if you still pay them. The same applies to someone who started just before your snapshot date, even if they haven’t been paid yet. However, you can leave them out of your pay figures, as there’s no pay to include yet. If you run several companies under one group, check whether to report for each company or for the group as a whole and be ready to explain your choice. WRC inspectors often ask about related entities and sites when assessing obligations.

Get the data right before you calculate anything

Once you know who counts, pull their pay for the 12 months before your snapshot date. This is where most mistakes start. Ordinary pay and bonus pay are separate figures, and both are taken before deductions. Bundling bonuses into salary is one of the most common errors, and it skews every metric that follows. If you outsource payroll, ask your provider for an export that keeps the two separate. Check that salaries are current before you run any numbers. A correction after publication is open to public scrutiny.

Watch for small groups

In a business of 60 people, your top pay quartile is 15 people, and your leadership team might be three. Your report shows percentages and never salaries. But if those three are all men, readers can work a lot out. Look at how each small group reads before you publish. If a pay quartile only contains a handful of employees, consider seeking advice on how best to provide context in your narrative while respecting privacy obligations.

Explain your gap in plain language

The calculations are usually straightforward. Explaining what underpins the figures is where many employers struggle. A reader should finish it knowing what causes your gap. Saying it comes mainly from having more men in senior roles gives them something concrete. It also highlights where action might be needed. In a smaller business, one senior hire or one departure can move your figures a long way from one year to the next. Explain this in your report so readers don’t mistake a swing for a trend.

We saw this first-hand in our own reporting. Our gap is under 5%, but the bonus figures showed a discrepancy. When we looked into it, the reason was that most of our sales team were men. Nobody had consciously set out to build the team that way. We had simply never stopped to ask why. Finding that kind of thing is the point of the exercise.

Commit to actions you can measure

An action plan that says “we will do better” won’t help you with next year’s report. Set targets you can check in 12 months. You don’t need a formal leadership programme to do that. Structured promotion criteria, standardised interview scoring, published pay bands, annual pay reviews and mentoring opportunities are all within reach.

Look at how you value skills as well. If your pay criteria rate financial skills above interpersonal ones, ask whether that’s a genuine business judgement or just a habit nobody’s questioned. Factors like these can contribute to pay gaps in sectors where women are more likely to work in caring or people-facing roles.

Know what your gap measures

Most Irish employers have a gender pay gap, and no law sets an acceptable size difference. Across the country, men earned 9.6% more the last time the CSO measured it. Much of that comes down to who holds the senior roles. In 2025, women held just 19.2% of CEO roles in large Irish companies, barely up from 19.0% in 2023.

Your gap measures who holds which roles across your organisation. Paying a woman less than a man for the same job is a separate question. If you can’t give an objective reason for a difference, it needs fixing, whether or not a report forces you to look. Female-led sectors need to take the same care. A gap in favour of women is still a gap.

The publication of gender pay gap data is no longer a compliance exercise carried out behind the scenes. Candidates, employees, customers and competitors can now compare organisations at the click of a button. The employers that benefit most won’t necessarily be those with the smallest gap, but those that understand what drives it, explain it honestly and demonstrate measurable progress over time.

That’s also valuable preparation for the EU Pay Transparency Directive. Organisations that understand their pay structures today will be in a much stronger position when employees begin asking questions about how pay is determined, how progression decisions are made and how their earnings compare with colleagues doing work of equal value.

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Image at top: Photo by Marek Studzinski on Unsplash