As 2025 comes to a close, we wanted to flag some recent developments in the employment law space as follows:
Auto enrolment
Despite the fact that auto-enrolment is due to commence on 1 January 2026 with employer registrations online from 1 December 2025 the Minister for Social Protection, intends to rush through legislation to close a loophole in auto enrolment legislation to ensure that any occupational pension scheme offered to workers matches the state scheme. Under the Automatic Enrolment Retirement Savings System Act 2024 it is an offence to hinder or attempt to hinder an employee from participating in the My Future Fund auto-enrolment scheme.
Remote working
Under the Work Life Balance Act 2023, a review of the operation of the remote working provisions was required after the first year of operation. The government has announced a public consultation seeking the views of members of the public, employers and other interested parties on the right to request remote working. The consultation commenced on 18 November 2025 and closed on 9 December 2025. The media has reported that over 3,400 submissions were received in the first 3 days with the bulk coming from employees who remain unsatisfied with the inability of the Workplace Relations Commission to reverse unsuccessful applications for remote work.
AI Act
The EC recently proposed a "Digital Omnibus" package that includes targeted simplification measures and adjustments to the AI Act, which are yet to be agreed upon by the European Parliament and Council. These proposed changes are driven by pressure from big tech companies and the US government. It now remains to be seen whether the following implementation dates within the AI will remain in place or whether these deadlines will be pushed out:
- February 2026 - The EC is scheduled to issue comprehensive guidelines to assist in classifying high-risk AI systems.
- 2 August 2026: End of 24-month transition period obligations for high-risk AI systems comes into effect and rules on AI transparency.
In the meantime, Ireland continues to make progress in implementing the Act by becoming one of the first six Member States to designate their competent authorities. A National AI Office is also due to be established by 2 August 2026 to act as the central coordinating authority for the AI Act in Ireland.
Retirement
The Employment (Contractual Retirement Ages) Bill 2025 has been passed by all of the Houses of the Oireachtas and is due to be signed into law by the President. This bill will allow employees with a contractual retirement age clauses below the state pension age (currently 66 years old) to request an extension to their contract of employment. An employer who has received notification from an employee must not enforce their retirement age unless the retirement can be objectively and reasonably justified by a legitimate aim and the means of achieving that aim are appropriate and necessary. Where an employer has received a notification but proposes to enforce their retirement age, the employer must, within one month of the notification, provide a reasoned written reply setting out the justification to the employee. An employer who, without reasonable cause, fails to provide an employee with a reasoned written reply will be guilty of an offence.
Pay Transparency Directive
The Pay Transparency Directive will impose additional reporting obligations on employers in relation to categories of workers and obligations to address information requests from employees. It will also require employers to publish salary scales when advertising roles and will prohibit employers from restricting employees from disclosing their salaries to colleagues. The General Scheme of the Equality (Miscellaneous Provisions) Bill 2024, has been published (and is currently under pre-legislative scrutiny) and includes provisions for recruitment transparency, such as mandatory salary ranges in job ads and a ban on asking about salary history. The government is preparing a separate Pay Transparency Bill addressing other issues covered by the Directive. Despite the fact that the Directive is due to be implemented by June 2026 many European countries have made limited progress in its implementation.
Collective bargaining
The government published their Action Plan on Competitiveness and Productivity in September 2025. There are five pillars for action to include research, innovation and skills, international openness, creating and scaling SMEs regulation and increasing the state's capacity to deliver infrastructure. Despite pressures in this space, there appears to be no intention to remove the voluntarist nature of collective bargaining in this jurisdiction which is welcome news for business.
