CateAI Pay Transparency™

Mean Gender Pay Gap

12.4%

Women earn 12.4% less on average · Above 5% threshold

Median Gender Pay Gap

9.8%

Middle earner comparison · Irish avg ~11%

Mean Bonus Pay Gap

28.3%

Significant gap · Requires narrative explanation

EU Directive Readiness

61%

7 of 11 requirements met · Action needed

Executive summary

What the data shows

ACME Group has a mean gender pay gap of 12.4% — placing it above the 5% threshold that triggers a mandatory joint pay assessment under the EU Directive. The gap is driven primarily by the underrepresentation of women in senior and Grade 5 roles. The bonus pay gap of 28.3% requires a clear written narrative in the statutory report.

What requires action

EU Directive compliance is 61% — salary ranges are not yet included in job advertisements and pay history questions have not been removed from recruitment. Both are required from 7 June 2026. The written GPG narrative for the December report must address the grade-level concentration of the gap.

What is working

Within-band pay equality is strong — where women and men hold the same grade, the pay difference is less than 2% across all bands. The gap is structural (grade distribution) not discriminatory (equal pay for equal work). This is an important distinction for the statutory narrative.

Pay quartile distribution — gender representation

Gender split by pay quartile — June 2026

Mean pay gap trend

Statutory metrics at a glance

Metric	Result	RAG	Statutory requirement
Mean hourly pay gap	12.4%	Amber	Must report. Gap > 5% triggers joint pay assessment.
Median hourly pay gap	9.8%	Amber	Must report.
Mean bonus pay gap	28.3%	Red	Must report. Requires written explanation.
Median bonus pay gap	19.1%	Red	Must report.
% receiving bonus — female	72%	Amber	Must report.
% receiving bonus — male	89%	Amber	Must report. 17pp gap requires narrative.
Mean BIK pay gap	8.2%	Amber	Must report.
Median BIK pay gap	5.6%	Green	Must report.

CateAI Recommendation: The mean pay gap of 12.4% is above the 5% threshold for mandatory joint pay assessment under the EU Directive. Before December, we recommend: (1) A written narrative explaining the grade-level concentration of the gap; (2) An action plan targeting improved representation of women at Grade 4 and Grade 5; (3) A review of the bonus scheme eligibility criteria, which currently disadvantages part-time staff — 73% of whom are female.

Total employees

Snapshot date: 17 June 2026

Female employees

54 (58.7%)

Majority workforce is female

Male employees

38 (41.3%)

Part-time employees

18 (19.6%)

73% of part-time staff are female

All 8 statutory metrics — Gender Pay Gap Information Act 2021

🟡 Mean hourly pay gap

12.4%

Women earn €0.876 for every €1 earned by men (hourly)

🟡 Median hourly pay gap

9.8%

Middle female earner vs middle male earner

🔴 Mean bonus pay gap

28.3%

Largest gap — driven by senior bonus pool composition

🔴 Median bonus pay gap

19.1%

Consistent with mean — structural not outlier-driven

🟡 % women receiving bonus

72%

vs 89% of male employees — 17 percentage point gap

🟡 % men receiving bonus

89%

Scheme eligibility criteria under review

🟡 Mean benefits-in-kind gap

8.2%

Health insurance and car allowances skew to senior roles

🟢 Median benefits-in-kind gap

5.6%

Below 5% threshold at median level

Pay quartile — gender breakdown

Quartile	Pay range	Female	Male	% Female	Analysis
Lower quartileQ1 — lowest paid 25%	€22k–€32k	18	5	78%	Women significantly over-represented
Lower-middle quartileQ2	€32k–€42k	14	9	61%	Closer to workforce average
Upper-middle quartileQ3	€42k–€55k	14	9	61%	Close to workforce average
Upper quartileQ4 — highest paid 25%	€55k–€95k	8	15	35%	Women significantly under-represented at senior level
All employees	—	54	38	58.7%	Female majority overall but not in upper quartile

Part-time and temporary employee analysis

Part-time workforce — gender split

Part-time — female

72% of part-time workforce

Part-time — male

28% of part-time workforce

Part-time pay gap

4.2%

Below 5% — within acceptable range

Part-time female concentration contributes significantly to the overall mean pay gap. Bonus scheme eligibility for part-time staff should be reviewed.

Temporary and fixed-term employees

Temporary — female

78% of temporary workforce

Temporary — male

22% of temporary workforce

Temporary pay gap

2.1%

Within acceptable range

Temporary staff pay gap is low. However, the gender concentration in temporary roles contributes to structural inequality.

Key narrative point for statutory report: ACME Group's gender pay gap is structural rather than discriminatory. Where women and men hold the same grade, the pay difference is less than 2%. The gap is driven by the under-representation of women at Grade 4 and Grade 5 — the highest paid roles. The organisation commits to targeted action on senior female representation as part of its People & Culture Strategy 2026.

Pay grades

Grades 1–5 across all departments

Equal pay risk

Low

Within-band gaps all below 2%

Senior female representation

35%

Grade 4 & 5 — below workforce average

Largest within-band gap

1.8%

Grade 3 — within acceptable range

Gender representation by pay band

Female representation by grade

Within-band mean pay gap %

Pay band detail — June 2026

Grade	Pay range	Total staff	Female	Male	% Female	Within-band gap	Equal pay risk
Grade 1Entry / Administrative	€22k–€28k	14	11	3	79%	0.8%	Low
Grade 2Professional / Specialist	€28k–€38k	22	14	8	64%	1.2%	Low
Grade 3Senior Professional	€38k–€48k	28	16	12	57%	1.8%	Low
Grade 4Manager / Department Head	€48k–€68k	18	9	9	50%	1.1%	Low
Grade 5Senior Manager / Director	€68k–€95k	10	4	6	40%	0.9%	Low
All grades	€22k–€95k	92	54	38	58.7%	0.4% (FTE adj)	Low

Within-band pay gaps below 2% are considered within normal pay variation range. The key finding is the gender distribution imbalance at Grade 4 and 5 — not unequal pay for equal work.

Equal pay risk is low across all grades. No grade shows a within-band gap above 2%. This is the most defensible finding in the statutory report and should be stated clearly in the narrative.

Grade 5 female representation is 40% — well below the 58.7% workforce average. With only 10 people at this grade, even one senior hire or promotion would materially improve this figure. An action plan is recommended.

Grade 1 is 79% female. The concentration of women in the lowest paid grade is the primary driver of the mean pay gap. Career progression pathways from Grade 1 to Grade 2 should be reviewed for accessibility and equity.

Overall readiness

61%

7 of 11 requirements met · Action needed

Pre-employment

33%

1 of 3 requirements met · Urgent

Employee rights

67%

2 of 3 met · Process needed

Pay reporting

80%

4 of 5 requirements met

Pre-employment transparency — from 7 June 2026

⚠️ Action RequiredSalary ranges not yet included in job advertisements. All job advertisements from 7 June 2026 must include the salary range or starting pay for the role. Current job ads on LinkedIn and your website do not include this information. HR must update all live job postings before the deadline.

⚠️ Action RequiredPay history questions still in recruitment process. Asking candidates about current or previous salary is prohibited from 7 June 2026. Interview guides and application forms must be reviewed and updated. This applies to all stages of recruitment — including informal conversations.

✅ CompletePay information provided before salary negotiation. ACME Group's current practice of issuing written salary offers before any negotiation meets this requirement.

Employee rights — information access

⚠️ Process NeededNo formal process for employees to request pay comparator information. Employees have the right to request data on average pay levels for colleagues doing the same or equivalent work, broken down by gender. A documented process and responsible contact must be established before June 2026.

✅ CompletePolicy prohibiting penalisation for pay discussions is in place. The updated Employment Policy (April 2026) includes an explicit statement that employees will not be penalised for discussing or disclosing their remuneration.

✅ CompletePay differences can be objectively justified. Pay-setting methodology is documented in the HR Operations Manual. Grade criteria are defined and applied consistently.

Pay reporting obligations

✅ CompleteGender pay gap data collected on snapshot date. All 92 employee pay records captured for 17 June 2026 snapshot. Data is complete and ready for analysis.

✅ CompleteAll 8 statutory metrics calculated. Full GPG report available in the Gender Pay Gap tab. All metrics are correctly calculated in line with Irish GPG Information Act 2021 definitions.

⚠️ In ProgressWritten narrative being prepared. The statutory narrative explaining the gap and actions being taken is currently in draft. Must be completed and signed off before December 2026 publication deadline.

✅ CompletePay band documentation complete. All five pay grades are documented with salary ranges and role criteria. This satisfies the pay structure transparency requirement.

⚠️ Action NeededReport not yet published on company website. The annual GPG report must be published on the company website by December 2026. A dedicated page should be created in advance.

Readiness summary

EU Directive readiness by category

Priority actions before 7 June 2026

🔴

Update all job advertisements to include salary rangesHR Manager · Deadline: 6 June 2026

🔴

Remove pay history questions from all recruitment materialsHR Manager · Deadline: 6 June 2026

🟡

Establish formal process for pay information requestsHR Manager · Deadline: 30 June 2026

🟡

Complete statutory GPG narrativeHR Manager + CEO · Deadline: 30 November 2026

🟡

Create GPG report page on company websiteHR Manager · Deadline: 1 December 2026

Current status

Preparing

June 2026 deadline imminent · Action underway

Next key deadline

7 June 2026

EU Pay Transparency Directive transposition

Legislative timeline — Gender Pay Gap & EU Directive

December 2022

✅ GPG Reporting began — 250+ employees

Irish Gender Pay Gap Information Act 2021 came into effect for the first cohort. ACME Group was not in scope at this stage.

December 2024

✅ GPG extended to 150+ employees

Second phase of mandatory gender pay gap reporting. ACME Group (92 staff) was not yet in scope.

December 2025

✅ GPG extended to 50+ employees — ACME Group now in scope

All organisations with 50 or more employees are now legally required to report their gender pay gap annually. ACME Group (92 staff) became subject to mandatory reporting from this point.

⚠️ 7 June 2026 — Transposition Deadline (Ireland delayed)

EU Pay Transparency Directive — Ireland missed transposition deadline

Ireland's Department of Equality confirmed in March 2026 that it would miss the June 7 transposition deadline. However, the ICTU has warned that employees with valid pay equity claims may seek compensation backdated to this date once enabling legislation is enacted. Liabilities are accumulating. Organisations should act now rather than wait for full transposition.

December 2026

🟡 Annual GPG Report due — snapshot date 17 June 2026

ACME Group must publish its full gender pay gap report on the company website. Report covers the 8 statutory metrics based on the June snapshot, plus a written narrative explaining the gap and actions being taken. CateAI will deliver the complete report with narrative by November 2026.

2027

📅 Enhanced EU Directive reporting — 250+ employees

First annual pay gap reports under the full EU Directive framework for organisations with 250+ employees. ACME Group will not be in this initial cohort but should begin preparing for enhanced requirements.

2031

📅 Joint Pay Assessment deadline

If an unjustified gender pay gap of 5% or more persists after reporting obligations begin, a joint pay assessment with employee representatives is required. ACME Group's current 12.4% gap puts it at risk — proactive action now reduces this risk significantly.

CateAI Note: Ireland has signalled a phased approach to implementing the EU Pay Transparency Directive. While some elements may be delayed, employers who act now will be better positioned than those who wait. The pre-employment obligations (salary ranges in job ads, no pay history questions) are the most immediate and straightforward to implement.

🔴 Critical — action required before 7 June 2026

HR ManagerUpdate all live job advertisements to include salary ranges. All current job postings on the company website, LinkedIn and any other platforms must be updated to include the salary range before 7 June 2026. This is a direct legal requirement of the EU Pay Transparency Directive.

HR ManagerRemove pay history questions from all recruitment materials. Review all application forms, interview guides, offer letter templates and recruiter briefings. Any reference to current or previous salary must be removed. Issue updated guidance to all hiring managers immediately.

HR Manager + CEOCommunicate pay transparency changes to all hiring managers. Brief all managers involved in recruitment on the new requirements before they conduct any interviews in June 2026. A short briefing note or 15-minute session is sufficient.

🟡 Important — action by end of June 2026

HR ManagerEstablish a formal process for employee pay information requests. Employees now have the right to request data on average pay levels for colleagues doing equivalent work, broken down by gender. Designate a contact person, establish a response timeframe (recommended: 10 working days) and document the process.

HR ManagerReview bonus scheme eligibility for part-time staff. Currently 73% of part-time staff are female and they are disproportionately excluded from bonus eligibility. Review the criteria and assess whether eligibility can be extended on a pro-rata basis. This will directly reduce the bonus pay gap for next year's report.

HR Manager + Finance DirectorComplete the written narrative for the December GPG report. The statutory narrative must explain: why the gap exists, what actions are being taken, and what the organisation's commitment is to reducing it. CateAI will provide a draft narrative for review. Final sign-off required from CEO.

🟢 Strategic — action before December 2026

HR Manager + CEODevelop a senior female representation plan. The Grade 4 and Grade 5 under-representation of women is the primary driver of the pay gap. A targeted plan — including succession planning, flexible working for senior roles and structured mentoring — should be in place before the December report.

HR ManagerCreate GPG report page on the company website. The annual report must be published publicly. Create a dedicated page in advance. CateAI will provide the report in a publication-ready format by November 2026.

HR ManagerReview Grade 1 career progression pathways. Grade 1 is 79% female and is the lowest paid grade. Accessible and clear progression routes from Grade 1 to Grade 2 will improve long-term gender pay equality and should be included in the action plan within the statutory narrative.

CateAI Overall Assessment: ACME Group is in a strong position compared to peers — equal pay for equal work is good, data collection is complete and the gap is well understood. The two immediate priorities are the EU Directive pre-employment requirements (salary ranges in job ads, no pay history questions) and the statutory narrative for December. The structural gap at senior grades is the medium-term strategic priority. CateAI will support delivery of all of these.

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