Developing a Narrative Around Your Gender Pay Gap Data
This year, Organisations with 50 Employees or more fall under the scope of the gender pay gap reporting regulations. Organisations reporting for the first time this year will not only have to process the pay data, the regulations also require relevant Employers to set out:
i) in the Employer’s opinion, the reasons for any gender pay gaps in the Organisation, and
ii) the measures (if any) being taken, or proposed to be taken, by the Employer to eliminate or reduce such gender pay gaps.
The reason a gender pay gap exists varies widely and may be a sectoral issue in one Organisation, overrepresentation of one gender in more senior well-paid roles in another or a lack of family-friendly options for Employees in a separate Organisation. If the payroll data reveals a gender pay gap, Organisations therefore have an opportunity to provide objective reasons why the difference in pay has developed and identify proposed action points that will explain how they intend to reduce the gap.
The following steps provide a useful framework for Organisations reporting for the first time this November.
Step 1: Understand the Reasons for a Gender Pay Gap
Before you can effectively communicate a gender pay gap narrative, you must first ensure that the required data has been collated and understood. If there are patterns or discrepancies in the numbers that may suggest specific issues within your Organisation, it is important to analyse the data and identify credible reasons that explain why a gender pay gap has developed. Identifying the reasons for a gender pay gap and understanding the data is the first step in shaping your report’s narrative.
Step 2: Contextualise the Gap
A key part of developing a narrative around gender pay gap data is offering context. While the data itself is important, without an explanation of the factors contributing to the gap, it can easily be misinterpreted.
One of the most common factors contributing to the gender pay gap is the underrepresentation of women in senior or high-paying roles. In certain sectors, men are more likely to be in leadership positions, while women are more likely to be in lower-paying administrative or support roles.
By acknowledging these sectoral or socio-cultural factors in your narrative, you not only help stakeholders understand the causes of the gender pay gap but also demonstrate that your Organisation is aware of the broader societal and organisational dynamics that may be at play.
Step 3: Identify Steps to Reduce the Gap
Once you have understood the data and contextualised the gap, the next step is to outline the actions your Organisation will take to reduce the gap. A clear action plan with measurable goals can demonstrate your commitment to closing the gender pay gap. Each Organisation will need to respond to the specific issues identified in the pay data, but possible corrective steps could include:
• Regular pay audits: Committing to conduct pay audits regularly to monitor progress and ensure equal pay for equal work.
• Training and awareness programmes: Implementing training around unconscious bias, diversity, and inclusion to ensure that hiring, promotion, and pay decisions are made in a fair and equitable way.
• Flexible working policies: Expanding access to flexible working hours and remote working arrangements to support both men and women in balancing career and personal commitments.
Further Pay Transparency Measures under the EU Pay Transparency Directive
Gender pay gap reporting is just one of the pay transparency measures under the EU’s Pay Transparency Directive which must be fully transposed into domestic law by June 2026. Organisations face an increasing compliance burden next year under the Directive which includes provisions for:
Joint pay assessments: The Directive introduces a requirement to carry out a Joint Pay Assessment where there is:
• at least a 5% gender pay gap in any category of workers
• the gender pay gap has not been justified by objective and gender-neutral factors, and
• has not been remedied within six months of the gender pay gap report.
Ban on pay secrecy: Measures will be put in place to prohibit pay secrecy clauses and thereby allow Employees to share information about their pay.
Information rights for Employees: Employees will have a right to request information from their Employer on:
• their individual pay level; and
• on average pay levels, broken down by gender for Employees doing the same work or work of equal value.
Pay transparency for job applicants: Employers will be required to provide information about salary levels or ranges either in the job advertisement or in advance of the interview. The Directive also prohibits Employers from asking job applicants about their own pay history or their current rate of pay.
Conclusion
By creating a narrative around your gender pay gap data that is transparent, contextual, and action-oriented, you can not only comply with legal requirements but also demonstrate a genuine commitment to gender equality. With a clear narrative, a commitment to continuous improvement, and active engagement with stakeholders, your Organisation can play a crucial role in driving gender equality as well as being better positioned to align with the EU's Pay Transparency Directive which will require even greater efforts in ensuring that pay practices are fair, transparent, and equitable.
At Adare, we are working with clients across Ireland in navigating this transition. Our Reward and Pay Equity Services include:
• Gender Pay Gap Analytics and Reporting
• Salary and Benefits Benchmarking
• Pay Transparency Compliance Audits
• Pay Transparency Policy and Compliance Framework
• Pay Transparency Communication Strategy
For support with turning compliance into competitive advantage, get in touch today to start your Organisation’s pay transparency journey.
Email adarechambers@adarehrm.ie or phone (01) 561 3594.
Adare is a team of expert-led Employment Law, Industrial Relations and best practice Human Resource Management consultants. If your Organisation needs advice, support, or guidance about compliance requirements or any HR issues, please contact Adare by calling (01) 561 3594 or emailing info@adarehrm.ie to learn what services are available to support your business.