As 2025 draws to a close, we’ve seen a range of significant developments in employment law and workplace regulation.
From gender pay gap reporting to AI regulation and the upcoming introduction of automatic pension enrolment, employers have navigated a variety of changes this year.
Here’s a snapshot of the key highlights that have shaped the employment landscape during 2025.
EU Artificial Intelligence Act – First Provisions in Force
In August 2024, the European Parliament approved the EU AI Act, the world’s first comprehensive regulatory framework for artificial intelligence.
A notable milestone came into effect in February 2025, namely, the ban on AI practices considered an ‘unacceptable risk,‘ including those that pose safety concerns or discriminatory outcomes.
Additional rules relating to high-risk uses of AI, which will apply to most employers intending to deploy AI based solutions, had been scheduled to apply from August 2026. However, this is now likely to be postponed for a year, or longer, as part of the Digital Omnibus package.
Employers should therefore monitor developments carefully and take the opportunity now to begin to prepare for the implementation of the remaining provisions of the legislation governing the use of AI systems in the workplace. This includes employers who use AI systems for recruitment, task distribution, or employee monitoring and those providing AI systems for employees to use in their daily work.
Guidance on AI in Employment Matters
In the recent highly publicised case of Fernando Oliveira v Ryanair DAC (reported here), the Workplace Relations Commission emphasised the duty that each party to the proceedings has to “…ensure that their submissions are relevant and accurate and do not set out to mislead either the other party or the Adjudication Officer.”
The complainant in this case appeared to have utilised an AI tool to draft his submissions and this led to inclusion of citations that were “not relevant, mis-quoted and in many instances, non-existent.”
Following the Oliveira case, the Workplace Relations Commission has now published guidance on the use of AI tools in preparing written submissions or documents for use as evidence in employment law cases. This highlights the risks of over-reliance on AI and encourages parties to adopt best practices when using AI for employment purposes.
Employment Status
Following the 2023 Supreme Court decision in Revenue Commissioners v Karshan Ltd t/a Domino’s Pizza, the Government revised the Code of Practice on Determining Employment Status. This update clarifies how employment status should be assessed for tax, social insurance, and employment rights purposes, helping employers manage classification risks.
In addition, guidance has also recently been published by Revenue to assist employers with correcting payroll tax issues in 2024 and 2025. Corrections may be made to Revenue on or before 30 January 2026.
Auto-Enrolment Retirement Savings Scheme
The State’s automatic retirement savings system, My Future Fund, will begin on 1 January 2026, instead of the planned commencement date of 30 September 2025.
The scheme will automatically enrol employees aged 23–60 earning at least €20,000 into a State-run pension system, unless they are in exempt employment. National Automatic Enrolment Retirement Savings Authority (‘NAERSA‘) will assess income reported through payroll and provide a notification to employers if an employee is to be enrolled in My Future Fund.
Employers must be compliant by 1 January 2026 so would be well advised to make any necessary changes to existing pension arrangements and employment contracts to take account of the Automatic Enrolment Retirement Savings System Act 2024, in advance of this fast-approaching deadline.
Gender Pay Gap Reporting
Since June 2025, employers with 50+ employees must publish a gender pay gap report within five months of their snapshot date in June.
The new gender pay gap reporting portal launched in Autumn 2025, however, only those who are a ‘relevant partner organisation’ are currently required to report via this portal.
Regulations are expected in early 2026, which will require all employers to report on the portal.
Pay Transparency
The Government, in January 2025, published the heads of the Equality (Miscellaneous Provisions) Bill 2024 which proposes to make significant changes, in advance of the Pay Transparency Directive (‘PTD‘) being transposed into national law by 7 June 2026.
These include enforcing certain pay transparency obligations, such as providing information about salary levels at recruitment stage and ensuring applicants are not asked to disclose their current or former salary.
As the scheme progresses through the legislative process, it may include more elements of the PTD, for instance, a ban on pay secrecy, a pay progression policy and the right to information for certain workers. Alternatively, these outstanding aspects may be addressed in a separate Pay Transparency Act, as referenced in the Government Legislation Programme for Autumn 2025, which was recently published.
You can keep up to date with these developments through our Littler global tracker available here.
Statutory Sick Pay
Contrary to earlier indications, statutory sick pay remains capped at five days for 2025.
Under the Sick Leave Act 2022, employees are entitled to up to five days’ paid sick leave per year, paid at 70 % of gross salary, capped at €110 per day.
Although the original plan foresaw an increase to seven days in 2025 and 10 days in 2026, the Government has deferred the increase, citing employer cost pressures.
National Minimum Wage / Living Wage
On 1 January 2025, the national minimum wage rose by €0.80, from €12.70 to €13.50 per hour. The national minimum wage is set to rise further from 1 January 2026, to €14.15 per hour.
While the Government had pledged to replace the minimum wage with a national living wage, set at 60% of the median wage by 2026, this reform has now been postponed until 2029.
Employment Permits Online System (‘EPOS’) Goes Live
In April 2025, the Department of Enterprise, Trade and Employment launched the EPOS, streamlining the submission, processing, and issuance of employment permits. Employers are advised to familiarise themselves with the portal and update internal procedures accordingly.
Key Takeaways for Employers
- Review AI systems now to avoid prohibited practices and prepare for upcoming AI rules
- Prepare for pensions auto-enrolment starting January 2026
- Ensure gender pay gap data is ready and processes are in place for reporting
- Train employees on the new EPOS for employment permits
- Check HR and payroll practices for potential misclassification issues
- Stay informed on upcoming legislative changes regarding pay transparency
Looking Ahead to 2026
As you can see, 2025 has been a busy year for employment law – and 2026 promises even more change!
We’ll be back with an update on the key issues ahead for 2026, early in the new year.
In the meantime, if you’d like any further information on these issues, please reach out to your usual Littler contact.
