Pay transparency + gender pay gap reporting

Two regimes bear on Irish producers, one universal and one size-gated.

EU Pay Transparency Directive (2023/970)

Must be transposed into Irish law by 7 June 2026. Key duties:

• All employers, any size: the pay level or range must be given up front (job ad or before interview); the employer cannot ask a candidate's pay history; workers have a right to information on average pay levels broken down by sex for the same work or work of equal value.
• Reporting (size-gated): 250+ employees report annually from 7 June 2027; 150–249 and 100–149 every three years (2027 / 2031).
• Joint pay assessment: where a category of workers shows a gap of 5% or more that the employer can't justify on objective gender-neutral grounds and doesn't fix within six months, a joint pay assessment with worker representatives is required. The burden of proof shifts to the employer in equal-pay claims.

Irish Gender Pay Gap Information Act 2021

Already in force and tightening. The reporting threshold dropped to 50+ employees from 31 May 2025. In scope, an employer must publish ~20 metrics — mean and median hourly-pay gap (overall, part-time, temporary), mean and median bonus gap, the % of each sex receiving bonus and benefit-in-kind, and male/female proportions across four pay quartiles — plus a narrative on the causes and the remedial measures planned. Pick a snapshot date in June, use the preceding 12 months' remuneration, and publish by November through the central reporting portal.

Counting employees ("relevant employees"): a headcount of everyone employed under a contract of employment on the snapshot date — full-time, part-time, fixed-term and specific-purpose all count as 1 each, including those on leave or not rostered; exclude anyone on a career break longer than 12 months. Freelancers and loan-out companies are not employees. The screen sector's reliance on freelance/loan-out engagement means many production companies sit under 50, but a busy company or a large shoot can cross it on the June snapshot.

In Togra

Cúram → Pay transparency is the readiness surface (company-level). It counts employees (employees-only basis: a contract active on the snapshot date classified employee via PAYE payment type or a Karshan assessment outcome of employee, plus a producer-entered permanent-staff figure) and tells you whether you cross the 50-employee Irish threshold — while reminding you the EU hiring rules apply regardless of size from 7 June 2026. It also logs and answers right-to-information requests, surfaced in the approvals inbox.

Contracts also carry a gender-neutral pay range (min / max / basis) alongside the agreed fee — the range the EU directive requires up front. It's set in the contract editor and shown to the candidate on their onboarding link, with a note that pay history won't be asked.

Scope note: the published GPG metric calculation (the 20 metrics + quartiles) is not built yet — it requires identified gender + remuneration per employee over the reference period (the Tier 2 follow-up).

Related

• Fixed-term work — Protection of Employees (Fixed-Term Work) Act 2003 · Working time + compensatory rest — Organisation of Working Time Act 1997 · Safe to Create + Minding Creative Minds — the other people-compliance obligations in the Cúram pack
• Section 481 — the Irish scripted tax credit — already collects cast gender for Tab Z, the nearest existing demographic capture