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Ireland - Employment law updates in Q3 2025

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By Sinead Morgan

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Published 09 October 2025

Overview

As we approaching the latter part of 2025, there have been no particularly significant moves from a legislative perspective, partly due to the summer vacation. Having said that, employers should be aware of the following employment law developments in the last quarter:

 

Organisation of Working Time (Leave for health screening purposes) Bill 2025

This Bill will entitle an employee to three days leave with pay in order to avail of (a) a cervical, breast or colon cancer screening programme provided by the Health Service Executive for the benefit of persons of the employee’s age, gender and general health status, or (b) any other screening programme recommended to the employee by his or her medical practitioner, having regard to the employee’s age, gender and general health status. The bill addresses issues such as confidentiality, and provides protections against penalisation or unfair dismissal if employees avail of this leave. The Workplace Relations Commission can award compensation (of up to two weeks remuneration) for breach of the legislation or direct the granting of leave. The Bill is currently at the second stage of the legislative process.

 

Sectoral Employment Order (Construction Sector) 2024 (S.I. 620 of 2024)

This Sectoral Employment Order increased minimum rates of pay and other conditions (sick pay and pension entitlements) for persons employed in the construction sector from 1 August 2025, with further increases due to come into effect on 1 August 2026.

 

Employment Regulation Order for Contract Cleaning Industry 2025 (S.I. No. 430 of 2025)

This Employment Regulation Order ("ERO") will come into effect 17 October 2025 revoking the previous ERO and increasing minimum rates of pay and other conditions (sick pay and pension entitlements) for persons employed in the contract cleaning sector.

 

Pension auto enrolment update

Further milestones have been reached in the implementation of ‘My Future Fund’ – the automatic enrolment retirement savings system due to launch in January 2026. The positions of Chief Executive of NAERSA - the new National Automatic Enrolment Retirement Savings Authority and its Board Members have been appointed. Despite previous delays, the scheme appears to be on track to launch on 1 January 2026. Employers should clearly communicate the impact of auto-enrolment to their employees in advance of that date.

 

Revenue payroll tax disclosure opportunity for employee misclassification

On 11 September 2025, the Revenue Commissioners published guidance permitting employers to disclose bona fide errors in employee classification which would allow those employers to avail of more favourable revenue settlement terms. Any such disclosure must be made before 30 January 2026.

 

Concerns regarding use of digital sick certificates in Ireland

Concerns were raised by the Medical Council in July 2025 regarding the use of digital sick certificates in Ireland which can be acquired for as little as €25, without seeing a doctor. Apparently certificates are being issued to users who complete an online form without the necessity for a call or appointment with a registered practitioner. However, to avail of statutory sick pay employees must produce a sick certificate issued by a registered medical practitioner in Ireland.

 

AI Act

Ireland has become one of the first six Member States to designate competent authorities which will be responsible for enforcement of the Act. The first key date for employers was 2 February 2025 when the AI literacy obligation was triggered. The next key date will be on 2 August 2026 when the Rules on Annex III High-Risk AI systems and establishment of regulatory sandboxes will come into effect, which is likely to have a significant impact on the use of AI tools in HR services.

 

Labour Court

The Labour Court, the Court of Appeal for employment disputes in Ireland announced in September 2025 that operations will be reduced from four operating divisions to one operating division, which will cause significant delays in listing cases for hearings.

 

Employment Equality Act 1998 (Section 20A) (Gender Pay Gap Information) (Amendment) Regulations 2025

By way of reminder, companies with more than 50 employees must lodge their gender pay gap report with the new online portal in November 2025.

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