How to Prepare for Gender Pay Gap Reporting

If you’re a HR leader working in a business operating in the EU, the looming June 7, 2026 deadline for the EU Pay Transparency Directive (EUPTD) coming into force is likely top of mind.

As a reminder, the Directive aims to improve pay transparency and redress access for workers who are impacted by gender-based pay discrimination. For this, it requires employers to report on their gender pay gap for both basic and variable pay.

So, what should HR leaders know about preparing over the next month or so and ensuring a smooth rollout from June? We hosted a panel last week with three HR leaders from McCann Fitzgerald, Amach and Org Group to ask exactly that.

Here’s Helen Gallagher Beirne, Chief People Officer of Org Group’s advice for businesses on how to prepare ahead of that all-important June deadline:

1. Equip Managers for Payment Explanation Conversations

For Helen, pay transparency isn’t really about transparency – it’s about accountability: “Once you start sharing more information, you also have to be able to stand over the decisions behind it”. The biggest thing that organisations are underestimating, says Helen, is that this isn’t a compliance exercise – it’s a leadership capability shift.

Helen explains: “Historically, pay has lived in a lot of grey areas: manager discretion, legacy decisions, market pressures. This has meant that organisations have been able to operate with a degree of ambiguity and transparency removes that: “We are now asking leaders to explain, justify and stand over their decisions.”

The advice here:

• Prepare your managers to justify pay decisions to their direct reports
• Ensure these conversations are clear and credible
• Be proactive on how clear pay gaps will be addressed: transparency will amplify issues, rather than solve them

2. Avoid the "Data Dump": Build Trust Through Clarity and Context

For SMEs especially, the real risk isn’t over-complicating things – it’s actually underexplaining, says Helen. Or indeed, creating noise by sharing information without enough context. “Transparency only builds trust if it’s paired with clarity and context”, she says.

You’ll need to be really clear on these three questions:

• How pay is structured (bands and ranges).
• What drives movement (skills, performance, market).
• What "good" looks like at every level.

“Transparency on its own doesn’t build trust. It’s transparency plus understanding”, says Helen. She warns that if you just publish salary ranges or data, people will naturally start comparing but without context, they’ll often draw the wrong conclusions.

The advice here:

• You don’t need a perfect or complex framework. What matters is having simple, consistent principles that leaders can explain in plain language.
• Remember that trust is built when employees feel decisions are fair and can be explained - not just when information is shared.

3. Be Aware of the Limits of Gender Pay Data

Although the EUPTD is a really important step forward, it’s not a silver bullet, says Helen. While we have been required to report on gender pay gaps since 2022 for organisations of 250+, from 2027 that entry point will reduce to 150 employees. By then, we will need to report gender pay gaps by worker category, not just at an aggregate level.

The Directive also requires companies to conduct a joint pay assessment with worker representatives if it has a gap of over 5% that is not explainable on gender neutral criteria. “The average gender pay gap in Ireland from 2025 data sits at around 3-4% falling from 9.6% in 2022 which is a significant change”, says Helen.

The advice here:

Helen reminds that while gender pay gap reporting is a useful high-level indicator of differences, it doesn’t compare like-for-like roles, explain causes or other factors. Instead it reflects:

• More men in higher-paid roles
• More women in lower-paid or part-time roles
• Seniority and sector differences

4. But Be Proactive About Addressing Influences on Pay

It’s a little more complex than just salary differences, says Helen: “The reality is that many barriers to women’s progression are structural and behavioural, not just pay-related. They sit earlier in the pipeline.

The organisations that will really move the dial on gender inequality are the ones that use this transparency as a starting point, and then take a much more intentional look at how talent is developed and progressed, explains Helen.

The advice here:

Instead of just looking at the numbers, focus on things like:

• Access to stretch opportunities for women and other minority groups
• How performance is assessed in your organisation
• How promotion decisions are made
• Identifying the more subtle biases that may exist in these processes

5. Run a 30-Day ‘Can We Explain It’ Test

The best way to quickly assess your pay equality? Run a ‘can we explain it?’ test, says Helen: “Take a sample of employees and ask: could a manager clearly and confidently explain (without defensiveness) why this person is paid what they’re paid, relative to peers?” This will immediately give you areas to work on: “If the answer is no, that’s your starting point, not the reporting template.”

Over the next 30 days, you’ll also want to invest in manager guidance and talking points on pay. Helen urges not to look at this time as an exercise in compliance, but an opportunity to build credibility in how organisations make decisions about reward, progression and fairness. “But it will only land if leadership capability keeps pace with regulation.”