Northern Ireland: Pay gap reporting limited to gender for now
Gender pay gap reporting will go ahead in Northern Ireland, but the threshold for employer size remains uncertain, and plans for mandatory reporting of pay gaps for ethnicity and disability have been paused for the time being.
In its response to a consultation that closed in February 2025, the Department for Communities said that while it "is broadly supportive of the principle of reporting on ethnicity and disability pay gaps", it does not believe that gender pay gap reporting regulations are "an appropriate vehicle to report" on their status.
DfC added that reporting on ethnicity and disability pay gaps would not be legally enforceable because:
- employers are not currently required to collect information on ethnic origin or disability
- disclosing a disability is voluntary
- while employers are encouraged to provide information to the Equality Commission, under section 75 of the Northern Ireland Act 1998, it is only mandatory to report on community background and gender
The department said it will "keep a watching brief" on the upcoming Equality (Race and Disability) Bill as it progresses through the UK Parliament.
Who will have to report their gender pay gap in NI?
Under the original proposals, the duty to report gender pay gaps would apply to all employers in the private, public and voluntary sectors, with 250 or more relevant employees.
However, the majority of consultation respondents (63%) did not think this threshold (which applies in Great Britain) was appropriate. In the Republic of Ireland, the threshold used to be 250 employees, but this was reduced to 150 in 2024, and to just 50 employees this year.
The DfC cited figures showing that a threshold of 250 employees would account for 53% of employees in Northern Ireland. Reducing this to 100 employees, would increase this to 63%.
It said: "We will give further consideration to reporting thresholds within the context of the Gender Pay Gap Reporting Regulations as we move forward, and in light of any further developments with the EU Pay Transparency Directive [PTD]."
Leeanne Armstrong, managing associate for law firm Lewis Silkin, wrote in blog post last week that the applicability of the PTD in Northern Ireland remains uncertain.
She said Northern Ireland's Equality Commission and Human Rights Commission consider that, under the Windsor Framework (the post-Brexit legal agreement between the UK and EU), most PTD obligations should apply and will need to be implemented.
Armstrong said: "Whether this is the case and how they will interact with this new gender pay gap reporting regime is still being considered. For now, it seems the Department is waiting to see how this will play out before committing Northern Ireland to a definitive threshold."
She added: "In the meantime, this leaves uncertainty for employers as to whether their businesses will be captured by the new NI reporting regime, leading to potential complications with budgeting and planning. We will be closely watching developments in this area."
When will GPG reporting happen in NI?
The Department has said it "aims to introduce the Regulations to give effect to Gender Pay Gap reporting as soon as possible after the Good Jobs Employment Rights Bill receives Royal Assent."
This could mean 2027 for the regulations coming into force, and 2028 for the first GPG reporting deadline, but nothing has been confirmed.
The Department for Communities confirmed that GPG reporting in Northern Ireland will apply across all sectors: public, private and voluntary. Action plans on how an employer's gender pay gap will be improved will be mandatory, bringing Northern Ireland in line with Great Britain's reforms in the Employment Rights Bill, where action plans will be voluntary from April 2026, and mandatory from 2027.
Affected employers will have to publish their GPG data on their own website, with a central government website under consideration. Methodology, snapshot dates, and frequency will align with Great Britain's framework, ensuring comparability. The Equality Commission for Northern Ireland will oversee enforcement.
