As 2025 ends, we reflect on the significant Irish employment and pensions law developments of this year.

From the fallout of global tariffs to auto-enrolment, we wrap up key events for employers over the last 12 months.

January

Adequate Minimum Wages Directive: AG’s Opinion proposes annulment

While 2024 ended with Ireland’s transposition of the EU Adequate Minimum Wages Directive (AMWD), 2025 kicked off with the future of the Directive in doubt.

In response to an application by Denmark to the Court of Justice of the European Union (CJEU), the Advocate General of the Court recommended the annulment of the AMWD in full on the basis that it directly interfered with areas explicitly excluded from the scope of EU competence in social policy directives. However, a further development in November is outlined below.

February

Rules on prohibited AI practices come into effect

Prohibitions on eight AI practices, including the use of AI systems designed to infer emotions in workplace and educational settings (unless for medical or safety reasons), took effect on 2 February 2025.

Penalties for breaches involving prohibited practices took effect from 2 August 2025, with employers facing fines of up to €35 million or up to 7% of total worldwide annual turnover, whichever is higher.

Our article on how AI is re-shaping employment law gives further insight into the topic.

March

Amcor High Court decision

In a decision that benefits sponsoring employers of certain defined benefit schemes, the High Court upheld an employer’s right to “walk away” from its obligations as a sponsor of a defined benefit scheme on immediate notice. The Court refused to insert an implied term into a pension deed requiring an employer to provide reasonable notice of termination of their contributions to the scheme.

For further information, please see our article on this decision .

April

Impact of Global Tariffs on Government Support for Employees

On 2 April 2025, President Trump announced a 20% tariff rate to be applied to goods imported from the EU into the US.

While businesses braced for the impact of these increased costs, the Government confirmed that statutory sick pay leave entitlements would remain unchanged at five days per calendar year. The Government also delayed the implementation of a National Living Wage from 2026 to 2029, citing the need to protect employers and competitiveness.

May

Changes to Gender Pay Gap Reporting

New Regulations were introduced that reduced the period within which a relevant employer must publish their gender pay gap report to no later than five months from the June snapshot date. This means that gender pay gap reports must now be made available by November in each year, rather than December.

Employers with not less than 50 employees are also now required to publish gender pay gap reports.

June

Protected Disclosures: High Court grants order of interim relief on appeal

In Breban v Catch Security Systems Limited, the High Court examined the statutory exception to the definition of a “relevant wrongdoing” where it is a matter which it is the function of the worker or their employer to detect, investigate or prosecute, and which does not consist of or involve an act or omission on the part of the employer.

The High Court held that the above exception did not apply where an Installation/Security Systems Engineer, employed by a company which commissions and installs alarm systems, identified and reported a potential fire safety issue for the apartment above a pub where he was sent for work.

In overturning the Circuit Court’s decision, granting the appeal, and issuing an order for interim relief, Phelan J held that the relevant wrongdoing in this case fell under the general duties of the appellant’s role, and did not arise out of a contractual obligation to identify wrongdoings in relation to fire safety hazards.

July

Changes to access to social welfare payments for bereaved families were introduced

Prompted by the Supreme Court decision in John O’Meara & Ors v The Minister for Social Protection Ireland and the Attorney General, applicable legislation was extended to encompass eligibility for the payment of Widow’s, Widower’s and Surviving Civil Partner’s (Contributory) Pension to unmarried couples who live together for at least five years, or at least two years where they have dependent children together.

August

Labour Court applies Mallon

In An Garda Síochána v Tom Ronan, the Labour Court overturned the decision of the Workplace Relations Commission (WRC) and held that An Garda Síochána did not discriminate on age grounds in compulsorily retiring a civilian driver at 70.

The WRC had found in favour of Mr. Ronan and ordered his re-engagement by An Garda Síochána. In its decision, the Labour Court relied on the Supreme Court’s recent decision in Mallon v Minister for Justice, which held that the State’s decision to apply a mandatory retirement age of 70 to most public servants was objectively justified under equality law.

September

Karshan: disclosure opportunity to regularise misclassification of self-employment

Following the landmark 2024 Supreme Court decision in Revenue Commissioners v Karshan (Midlands) Ltd t/a Domino’s Pizza, which found that delivery drivers for Domino’s Pizza were incorrectly classified as contractors, Revenue provided employers with the opportunity to correct payroll taxes for 2024 and 2025, without imposition of interest and penalties.

This opportunity is only available to employers who acted in good faith and misclassified employees as contractors prior to the Supreme Court’s judgment in Karshan. Disclosures should be submitted no later than 30 January 2026.

October

European Parliament adopts the Revised European Works Council (EWC) Directive

The revised Directive proposes to amend the current EWC regime by:

• widening the scope of transnational matters, which will trigger an obligation to inform and consult an EWC;
• strengthening EWCs’ access to judicial and administrative proceedings; and
• introducing sufficiently dissuasive financial penalties for companies that fail to comply with the revised Directive.

Member States will have until 2027 to transpose the new Directive, with most changes expected to take effect from 2028.

November

Action Plan to Promote Collective Bargaining

In accordance with Ireland’s obligations under the AMWD, the plan contains 22 action items which seek to promote collective bargaining in Ireland.

Separately, in November, the CJEU issued its long-awaited decision on the case put forward by Denmark to annul the AMWD in full. The Court annulled Article 5(2) and part of Article 5(3) of the AMWD as they interfered with pay determination in the EU but dismissed Denmark’s request to annul the AMWD in full, confirming the validity of the remaining provisions of the Directive.

Please see our article for more information on what these developments mean for employers.

December

Anticipated Minimum Pension Contributions Regulations

In advance of the launch of auto-enrolment on 1 January 2026, the Department of Social Protection has indicated that it intends to implement regulations introducing a minimum contribution rate of 3.5% of gross pay to pension schemes (with at least 1.5% paid by the employer) to qualify as exempt from auto-enrolment. These regulations are expected to take effect from 1 January 2026, but at the time of writing this has not been confirmed.

Please refer to our article for additional relevant information.

Please reach out to your usual contact in the Employment & Benefits team if you would like to discuss any of these developments in more detail.

Contributed by Roisin O’Donoghue and Chris McMahon