Smaller employers completing gender pay gap reports for the first time in 2025 have a wealth of information to draw on but much work ahead, write Aoife Newton and Andrew Egan A lot can be learned from the first three years of gender pay gap reporting in Ireland, which means those employers new to this reporting in 2025 have a wealth of valuable data to learn from.  Many large employers are already producing in-depth and illustrative annual gender pay gap reports. Although primarily focused on statutory reporting requirements, they also reflect best practice approaches to tackling gender pay gaps and outline clear, insightful ways to explain these gaps.  For employers preparing to report for the first time, these reports are worth reading, if only to give you a sense of the approach others have already taken. As much as you can learn from this, however, you should not underestimate the volume of HR, payroll and other data required for gender pay gap reporting, the complexity involved in merging this data, the calculations required and the scrutiny you can expect to face when communicating your findings to stakeholders internally and externally.  Gender pay gap results published in 2025 will be based on data collected over 12 months, typically from July 2024 to June 2025, though the exact dates will depend on each employer’s chosen snapshot date.  This means employers not already focusing on gender representation across their organisation may find themselves having to explain sizable gender pay gaps. With Irish employers employing as little as 50 people in scope for reporting next year, we expect to see a lot more focus on this area from the media, employees and other stakeholders.  Smaller employers are subject to the same legislative requirements as their larger counterparts; there are no exemptions for employers with limited resources. This means they will be required to produce a report reflecting accurate results aligned with 11 statistical gender pay gap metrics along with a narrative detailing the reasons for existing gaps and measures (both existing and planned) to reduce or eliminate these gaps.  New 2024 regulations – new results? The Employment Equality Act 1998 (section 20A) (Gender Pay Gap Information) (Amendment) Regulations 2024 were introduced last May and it will be interesting to see what impact they have on this year’s gender pay gap reporting results. Under the 2024 Regulations, social welfare payments relating to certain periods of protective leave can now be included in gender pay gap calculations. This is a welcome development as it may help reflect parity of payment in line with notional hours worked.  Prior to this, the regulations have only included ‘top-up’ payment made by employers as relevant pay for gender pay calculations, providing that social welfare payments should be excluded (notwithstanding that full hours have been included).  The impact of this approach has been to reflect a lower hourly rate of pay for employees in receipt of certain welfare payments.  For 2024 reporting and beyond, employers will need to include both maternity leave benefit along with a maternity ‘top-up’ payment (i.e. 100% pay) matched with 100 percent hours.  This should reflect a notional increase in pay for women, thus helping to ‘reduce’ an employer’s gender pay gap compared to last year’s reporting. The 2024 Regulations also adjust the treatment of share options and interests in shares. These are now considered benefit-in-kind rather than forming part of bonus payments.   This could have a significant impact on the gender pay results of in-scope employers as benefit-in-kind is not included in either overall gender pay calculations or separate bonus calculations. Previously, share options and interests in shares were included in both.   The issue of actual shares (to be valued on the date of issue) continue to be part of the bonus calculation. So far in 2024, we are seeing steady results in completed reports compared to reports in the two years prior.  Typically, any significant variations in results can be explained by reference to changes in personnel at a senior level or due to business restructures. Both will continue to impact annual reporting.  Comparison is key An important aspect of reporting for many employers is how favourably, or otherwise, they compare with their peers operating in the same sector or industry. For example, if an employer operates in a sector that is traditionally male dominated (e.g. engineering), this will clearly influence their gender pay gap results.  In certain sectors, such as professional services, where employers are recruiting in the same talent pool as their competitors, how their organisation compares to their peers really matters.  Ideally, employers will want to see results that are either “similar to” or “more favourable than” their competitors.  If their results are not, boards and management should query why they are out of line with competitors with a similar resourcing structure recruiting from the same talent pool. In particular, it is worth examining whether there are discriminatory practices behind any results revealing a wide gender pay gap as this could be affecting female representation at the higher levels of the organisation – or perhaps the organisation’s pay and bonus structure is weighted in favour of men?  Ultimately, gender pay gap results serve to root out any embedded issues that may be impeding more equitable pay across the board. New developments in 2025 The biggest change in 2025 will be the extension of the gender pay gap reporting obligation to employers with just 50 employees. In addition to this development, we expect to see some changes to how the gender pay gap reporting process is carried out.  As it stands, employers must include their gender pay gap data and statement of information on their website – or have it available for public inspection.  We understand the Government has issued a tender for the development of an online gender pay gap portal, with development due to start in the coming weeks and testing earmarked for the new year.  It is expected that the portal will have similar functionality to an online gender pay gap portal already in operation in the UK.  If this is the case, the portal will allow employers and other interested parties to compare and contrast results with ease, rather than having to rely on the current, more laborious, manual process.  This new system of reporting is also expected to result in the reporting deadline being brought forward to the end of November 2025.  Employers – both those already reporting and new to the regime – will therefore have a five-month window in which to report, slightly shorter than the current six-month timeframe.  All employers in scope for reporting next year must thus be vigilant and ensure they are up to date at all times with the portal requirements and potential new deadline.  The EU Pay Transparency Directive Looking further ahead, as the EU Pay Transparency Directive (the Directive) is due to be transposed by June 2026, we expect to see many more changes to the reporting regime in the coming years.  The implementation of the new rules under the Directive will not only change the amount of data required but will also align gender pay gap reporting more closely with the employee engagement agenda.   Further, gender pay gap reporting under this Directive will not simply be about producing an annual report of results and narrative; it could also open up data results to scrutiny from trade unions and other employee representatives.  Where there are gaps of more than five percent in any category of worker (these categories are yet to be defined), which cannot be objectively justified and cannot be rectified within a six-month period, the employer may have to engage in a joint pay assessment.  Such joint pay assessments are expected to involve trade unions or other employee representatives.  Employers and all relevant stakeholders should, therefore, be more concerned about how the Directive will shine a light on their organisation’s gender pay gaps, bringing current reporting closer to the principle of equal pay and overall pay transparency.   Acknowledge the gaps Given the additional layer of data scrutiny under the EU Pay Transparency Directive, we are encouraging all employers with gender pay gaps in favour of male employees to commit to deeper analysis.  By better understanding the causes of such gaps at every level of their business, they will find these discrepancies easier to explain (based on objective criteria), and also potentially easier to rectify.  And while not all gaps may be fixable in the short-term, a deep analysis can give employers a good starting point to devise a longer-term solution, as well as greater scope to explain these gaps to legislators with reference to objective criteria. Ultimately, employers who are not focused on gender parity, closing gaps or preparing for the impending new regime, may be exposed to time-consuming and potentially contentious joint pay assessments.  Aoife Newton is Head of Employment and Immigration Law, KPMG Law LLP  Andrew Egan is a Director with KPMG, leading the firm’s tax data and analytics service offering

Maria Johnson, Head of Finance for Capital Investments at Iarnród Éireann, talks to Liz Riley about her journey to becoming a Chartered Accountant, the value of balance, and the lessons learned from a diverse and rewarding career Starting out, my journey to accounting was somewhat convoluted.  First, a late change to my CAO form brought me to the University of Limerick where I did a degree in Business Studies and French at the University of Limerick, ultimately choosing to major in Economics and Finance and minor in French.  I undertook the Professional Diploma in Accounting at Dublin City University (DCU) and I am now a Fellow of Chartered Accountants Ireland and Head of Finance for Capital Investments at Iarnród Éireann.  I am also lucky enough to be a mother, a stepmother, a daughter, a wife, a sister and a friend.  Capable business advisor I participated in the “milk round” while studying at DCU and decided that training in audit with BDO should be my next step.  The firm proved the ideal choice to commence my career as a Chartered Accountant.  As the audit department was not split into sector-specific teams, I was exposed to numerous sectors, including pharmaceuticals, financial services, professional services and manufacturing, during my training contract.  I also completed two client-based secondments, which gave me valuable real-world experience early in my career.  The BDO philosophy was to ensure the firm’s graduates would become capable business advisors as well as confident accountants through consistent exposure to partners and senior managers, genuine dealings with clients, attendance at relevant meetings and opportunities to present findings and solutions.  This philosophy has benefited me throughout my career, enabling me to work across sectors undaunted and ensuring that I can have valuable conversations with clients and colleagues as required without reservation.  I learned not to be pigeonholed either through education or early career choices. Up-and-coming accountants should aim for a degree and graduate programme that is established and will give them maximum exposure to sectors and professions in their chosen field.  Trading in facts I completed my graduate programme in October 2008, just as the Celtic Tiger was waning and the recession approached.  I was asked to join the Corporate Advisory and Recovery Team at BDO. I worked on this team until June 2014, moving from manager to senior manager during this tenure.  It was an unimaginably busy but rewarding time. All insolvency processes involve an investigation and an evaluation of how the company ultimately failed. These investigations involve forensic reviews of the books and records of the company and meetings and interviews with the officers of the company.  I learned to always remain resolutely professional, treating everyone I meet respectfully and equally – never make assumptions, trade only in facts and always back up all conclusions with evidence. Managing “the juggle” In July 2014, I moved to London with Mazars to work on an engagement for the Financial Conduct Authority. From there, I came back to the Dublin office to work in the financial consulting and decision-making support team. Our team specialised in financial modelling, data analysis and capital business cases. I became a Director on this team in September 2019.  During my time at Mazars, I became a proud dog owner, got married and became both a stepmother and a mother. We also moved from the highly convenient Harold’s Cross to a more family-friendly Portmarnock.  So, I became very well acquainted with “the juggle”.  When I returned from maternity leave, I received some timely advice suggesting I should become very aware that my time was no longer ‘elastic’, meaning I needed to set strict boundaries and stick to them.  This advice has always stuck with me and helps me to set my priorities for the day or week and allocate focus time to achieve those priorities. While it is always good to be flexible, this can no longer be a constant when crèche closing times are set in stone.  Making a different to Ireland’s future In March 2020, I joined Iarnród Éireann as Head of Finance for the newly formed Capital Investment Division. Capital Investments is tasked with building the “railway of the future”.  The Capital Investments team is currently delivering the DART+ Programme, the Cork Area Commuter Rail Programme, the reopening of the Foynes Line in County Limerick and many more projects across the island of Ireland.  I always loved practice. My move was not planned. It was simply that a role I was truly interested in pursuing crossed my path and I couldn’t resist exploring it further.  I have seen many colleagues and friends take roles specifically based on monetary rewards. While this is, of course, important, it rarely results in long-term career success.  I am enjoying working on a multidisciplinary team that is making a real and enduring difference to the Ireland of the future. This role allows me to leverage all the lessons learned in my career to make a real contribution to a busy senior management team. Don’t rush and take time to learn from and enjoy the many opportunities that come your way. I have held many different roles within the accountancy profession.  The work I have undertaken and the professionals I have had the privilege to work with along the way have shaped how I interact with colleagues, approach the work I do and represent my team at an organisational level today.  I’ve learned several things over my career that has influenced my work at Iarnród Éireann: Where possible, always work for companies that have a culture and strategy you are comfortable with.  Real flexibility and respect for work-life balance are lived experiences rather than buzzwords in graduate brochures and company websites.  Organisation is key. I have a great team who are highly committed to their work. I am grateful to them for all that they do, but I also respect that they all have competing priorities. Everyone has competing priorities in life irrespective of their gender, age or stage of life. We try to identify additional priorities and ad hoc tasks well in advance and plan for them around business-as-usual responsibilities to ensure everything is done in a timely and professional manner Balance in teams is essential. I have been a manager in one guise or another since I was 25. I have always happily gotten to know each of my teams. Impromptu coffees and lunches and, most of all, genuine interest are much more valuable than expensive annual outings, etc. Respect, organisation, a shared goal and camaraderie must be a constant in any successful team. Striving for balance Life is a balancing act. I have always worked for organisations that respect diversity and inclusion. I have had colleagues from all backgrounds and across many nationalities. I don’t believe being female has strongly influenced my career and I have been awarded opportunities on merit where deserved.  Where the juxtaposition of gender roles does come into play is in the mid-career juggle between career and family. Society’s expectations are enormous and growing, and the pressure to be the best at everything is real.  I am lucky to have a husband and life partner who also holds a demanding role and who is committed to working with me to do our “best” with life’s challenges and professional obligations in a given week – not “be the best”, but do our best.  I once heard at an International Women’s Day event in London that in any relationship there is an ebb and flow as to whose “time” it is. This is how we run our household every week. It is not always any one person’s “time”, but rather everyone gets their “time” when they need it.  In reflecting on my journey, I recognise that every step – whether carefully planned or serendipitous – has contributed to the professional and personal life I lead today.  To those beginning their own journeys, I would say this: remain open to change, stay true to your values and strive to balance ambition with the things that truly matter in life. The path may be winding, but it’s the experiences and people along the way that make it rewarding.

For Jaimie Dower, having a supportive work environment has played a critical role in helping her to navigate her gender transition positively and proactively When Jaimie Dower made the decision to transition in May 2022, she knew how important it would be to take a proactive approach to communicating her experience, not just in her personal life but also at work to her colleagues and clients at EY Ireland. For Dower, who is an Executive Director in EY’s Audit Quality Programme, her transition marked a watershed moment in her life. She was, she says, finally ready to “stand up in front of the world and say, ‘this is me’.”   “This is something that has been with me my whole life and something I had up until that point struggled with and hid,” Dower explains.  “There was always a disconnect – the person I knew I was inside and the person I was on the outside were not the same.  “It impacted my life in so many ways because there was always this noise in my head – this static – and the way I dealt with it for many years was to mentally compartmentalise and throw myself into things and say to that noise, ‘go away; I’ll deal with you another time.’” For Dower, who lives in Waterford and works at EY’s southeastern hub in the city centre, it was the onset of the COVID-19 pandemic in early 2020 that proved the catalyst for her transition. Working long hours at home and surrounded by the uncertainty that had engulfed the world as the pandemic took hold, she found she was no longer able to rely on life-long coping strategies. “I think this will resonate with a lot of people for their own reasons, but that first COVID lockdown in March 2020 really brought things to a head for me,” she says. “Out of everyone in our family, I was the one working alone from home the most. I had a lot of time to myself and, suddenly, I couldn’t manage those boxes I’d compartmentalised everything into anymore.  “Looking at what was happening in the world around me at that time, there was also this really strong sense of, ‘life’s too short.’  “It wasn’t just that I didn’t want to hide who I was anymore; I wanted to celebrate it. I wanted to stand up in front of the world and say, ‘this is who I am.’ That really came home to me during COVID.” First steps and early conversations Dower’s first step was to seek professional help. Working with a therapist helped her to ‘clarify’ her thoughts and begin to plan the practicalities of managing her transition.  “Talking to someone at that stage was very important – to have that help and support in coming out to myself, really, and the sheer relief of being able to say it out loud. It was powerful,” she says. By mid-2023, having begun hormone treatment, she was ready to start thinking about how to communicate her transition at work. “The hormone treatment changed my life. I can only describe it as coming into full focus for the first time. The dissonance I had felt all my life faded away. Now, I had to think about how to start telling people about my transition – to put a plan in place I was comfortable with.”  Initially, Dower decided to get involved in Unity, EY’s global LGBTQ+ network. “I took things slowly at first, getting involved in things like helping to organise Pride events. I got to know colleagues in the network and had one or two small conversations – really just to begin to gather my own thoughts on how to approach this.” By late 2023, Dower was ready to take more formal steps, and she reached out to EY’s HR team for support. “Their support was incredible. I was able to work directly with a colleague on the HR team I knew I could trust to work out a plan. That trust was immense for me.  “We talked about when I would start speaking to people, who I needed to speak to and when, and about what I wanted to say.” Intentional communication Dower began communicating with her colleagues in mid-February 2024 in advance of presenting at work as her authentic self. “There was a lot of anxiety for me initially around those conversations. Having worked at EY for 30 years, I did feel a lot of pressure because I have long-standing relationships with colleagues within the firm and clients externally and they trust me.  “I had faith that there would be a positive response, but in the back of your mind, there is always the worry that someone might not react well. “I will never forget that first call we set up for 2pm on a Friday afternoon with all the Assurance Partners across EY in Ireland – that was our starting point. “I work with EY people all around the country, but primarily in our Dublin office, and I needed to communicate to everyone.  “So, once I had that call with our Assurance Partners, I set up another group call with everyone on my team and then I sat down face to face with everyone in our Waterford office.” Although intense and, at times, overwhelming, the process also proved to be “empowering” for Dower who welcomed the positive feedback and support offered by colleagues.   “It was the support that came afterwards that really meant so much to me – people reaching out to say, ‘I’m delighted you were able to come to me and tell me this. I am with you – I support you.’  “Just knowing I could come to work as myself and it would be okay was incredible, because not everyone has that experience. Not everyone has that support.” While not easy, the process held great value for Dower, who felt empowered by being able to work proactively with her colleagues at EY to communicate her transition. “Every one of those conversations was difficult, no matter how many times I did it. Effectively, it was just me having to strip away all my defences to tell my story in different ways to different people depending on the nature of our working relationship and how well we knew each other.” “In some ways, it is a never-ending journey, but all I am fundamentally saying is, ‘I am still me, but I am the authentic me – a better version of me’.” Meaningful support and guidance In supporting employees at work as they transition, Dower sees enormous value in collaborative diversity, equity and inclusion initiatives, such as EY’s Unity network, which can help to foster a sense of community and act as a crucial conduit for support and communication. “Through my involvement with Unity, I had the privilege of being able to play a role in revising EY’s Transgender Identity, Expression and Transition Guidelines and I was also able to take part in a Transgender 101 Webcast for staff across the organisation.” As Dower sees it, such initiatives are vital in helping to foster a supportive environment for transgender employees and providing guidance and resources for the wider workforce. “From the employer’s perspective, education is so important. I’m not in a position myself to go around every day educating every person I meet. That’s where things like guidelines and webcasts can have real value. Even just a little bit of education can go a long way.” In particular, Dower sees value in establishing clear guidelines that are equally applicable to all and give everyone a simple and transparent baseline to work from. “I’ve had a sense sometimes that some colleagues may be a little nervous. It’s not that they are not supportive, it’s maybe that they are afraid that they might say the wrong thing or use the wrong terminology, and inadvertently cause offense or upset – and that is the last thing I want,” she says. EY’s Transgender Identity, Expression and Transition Guidelines include sections on gender identity and expression and the correct or inaccurate use of terms relating to gender expression, including pronouns. Guidance is also offered to managers on how to support transitioning employees and to individual employees who are transitioning. “I am very fortunate that EY as a firm, as an employer, has been so willing to work with and support me. When I reached out, the response wasn’t, ‘this is what we need from you,’ it was, ‘what do you need from us?’  “Now, I really want to communicate how important this is to the wider world, because I feel a responsibility to others who are transitioning and may not have the same support I have at work,” Dower says. “Because I have been with EY for 30 years, I have the privilege of a longstanding presence in the organisation and all the trust that comes with relationships built over that time. “Right from the outset I’ve thought, ‘if I can get this right, it might make it easier for someone who is younger and newer in the door who is going through the same thing.’  “Representation matters; visibility matters. Ultimately, I want to do what I can to help make this process easier for others in the future.” Interview by Elaine O’Regan Supporting employees transitioning at work For any person undergoing gender transition, the support of their employer, managers and colleagues will be crucial, and open, honest communication will play an important role in building trust and supporting a positive experience.  “At EY, we are committed to supporting individuals as they go through gender transition and working closely with them to provide personalised support, aid in establishing an action plan and setting expectations,” says Derarca Dennis, EY Ireland’s Assurance Partner and Sustainability Services Lead. “We value diversity and inclusion and the creation of a safe workplace in which everyone has the best opportunity to reach their full potential.” Based on EY Ireland’s own Transgender Identity, Expression and Transition Guidelines, Dennis shares seven key ‘best practice’ focus areas for all employers and managers seeking to support their own employees undergoing gender transition: Develop a transition plan When an individual approaches you with their intention to transition, it is imperative that you are supportive, open-minded and honest. Be prepared to discuss their aims and expectations, and what they intend your role to be in the transition. Make sure to consider stakeholders, colleagues, policies and procedures existing in the workplace. Ask your HR team for guidance and support as needed. Prioritise effective communication Clear, open and honest communication from managers, employees and the transitioning individual is essential. Communication will be different in all transitioning plans and dialogue can help alleviate any potential difficulties or issues. Hosting information and awareness sessions for team members and other stakeholders should be considered when developing this plan. Other fundamental communication areas to consider include what the transitioning individual is comfortable and willing to share.  Practise sensitivity and respect Be prepared to treat any employee who is transitioning with respect and an open-minded attitude. Be ready to ask questions, listen and understand their needs and concerns. All employees deserve to be treated with respect and sensitivity when related to their personal lives.  Use pronouns correctly Using the correct pronouns (he/she/they/ze etc) is extremely important. Simply ask the individual which pronoun they would like people to use and then ensure that everyone knows this. It may seem like a small thing, but it is incredibly important to get right as it demonstrates validation of the individual’s authentic self, which will go a long way towards helping them know they are fully accepted in their expression of their gender identity. Educate and raise awareness While everyone is expected to behave in accordance with policies, there should also be an opportunity for education and questions to be asked related to the transition process. It may be useful to host information sessions and forums to address concerns and educate employees who work in the team.  Guide on client conversations Should the individual be client-facing, they should be offered support (if required) in facilitating a conversation with any clients they work with. It is important to reinforce that their technical abilities will not have changed as a result of their expression of their gender identity and clients should be made to understand that all team members working with them must be treated with the same support and respect.  Respect confidentiality and privacy You should always maintain an appropriate level of confidentiality and privacy in relation to employee matters. Information should only be disclosed to those who need to know (such as HR, for example), those involved in the process, or those who have the consent of the transitioning employee.