Question 1

Does our company actually need to report this year?

Accepted Answer

If you have 50 or more employees across Irish entities, yes, the 2025 amendment brought you into scope. Reporting is now in November, not December. The snapshot date is in June. The EU Directive adds employers in other member states based on their own thresholds (typically 100 or 250). Employers in companies of 250+ employees must provide an EU report every year from June 2027. Employers in companies between 50 - 249 employees must report every 3 years from June 2027. The threshold for each country is decided by individual country legislation.

Question 2

What is the Joint Pay Assessment and will we trigger it?

Accepted Answer

Under Article 10 of the Directive, if your unexplained gap exceeds 5% in any category and you don't correct it within six months, you must run a formal Joint Pay Assessment with worker representatives. PayAlign tells you whether you're at risk before anyone else sees the report and if you are, we will provide you with the required documentation and direction to complete the JPA.

Question 3

What happens if an employee requests their pay information?

Accepted Answer

Article 7 gives every worker the right to request the average pay level for their category, broken down by sex. PayAlign administrators can draft a compliant response from your existing data and flags any response that might expose you to an equal-pay claim so you can review before sending.

Question 4

Does this apply if our payroll is run from outside the EU?

Accepted Answer

Yes. The Directive applies to anyone employing workers in the EU, regardless of where the parent company is headquartered. A US or UK group with Irish employees still has to report on its Irish workforce.

Question 5

What happens if our gap is above 5%?

Accepted Answer

A gap above 5% in any worker category triggers a Joint Pay Assessment under Article 10 if the gap is not remediated within 6 months, unless you can document objective, gender-neutral grounds for it. PayAlign flags the at-risk categories before publication. We assist with gap justification and guidance through a joint pay assessment if required.

Question 6

We have multiple legal entities in Ireland. Do we report separately?

Accepted Answer

Each legal entity with 50 or more employees reports separately under Irish law. Group-level consolidation is optional.

Question 7

How long does the first EUPTD/GPG report take to produce?

Accepted Answer

For a single Irish entity using a standard payroll export, most customers can go from data upload to finished draft report in one day. The longer time investment is in reviewing the explanatory narrative and signing off internally, not in the calculation.

Question 8

What about part-time, fixed-term and agency workers?

Accepted Answer

Part-time and fixed-term employees count toward your headcount and are included in the gap calculation, with hourly pay normalised. Agency workers placed by a third party are reported by the agency, not by you.

Question 9

How is PayAlign different from running this in Excel?

Accepted Answer

Excel will calculate a mean and median for you. It won't run regression-based gap decomposition, won't produce a regulator-format report, won't track changes year on year and won't tell you whether your unexplained gap survives an Article 10 challenge. Most teams using Excel rebuild the file from scratch every year.

Question 10

Is our data stored in the EU?

Accepted Answer

Yes. PayAlign is hosted in EU data centres. We process data under GDPR and sign a data processing agreement with every customer. We never share, sell or train models on your payroll data.

The PayAlign blog

Multi-Entity Structures for EUPTD Compliance

Data Hygiene: Passing The First Pay Audit

The Hidden Cost of Doing Nothing: EUPTD

Worker Representatives: Establishing The Relationship

Pay Bands vs Pay Ranges vs Salary Bands: A Compensation Glossary for 2026

Pay Transparency in Northern Ireland: The UK's Most Complex Post-Brexit Compliance Landscape

What "Objective and Gender-Neutral Criteria" Actually Means

From Job Ad to Offer Letter: A Compliant Hiring Workflow Under Article 5

Multi-Speed Europe: Who Missed the Pay Transparency Deadline