What counts as “pay” under the EU Directive?

The EU Pay Transparency Directive takes a broad view of “pay”. Base salary is only one part: reporting should also cover bonuses, allowances and in-kind benefits (e.g., company car, stock options).  

In short: report the full package that employees actually receive. 

The aim is to compare like for like by reflecting total compensation, not just headline salaries. 

Included in the definition of pay: 

• Base salary (adjust FTE if needed)
• Bonuses and commissions
• Allowances, e.g. travel, meals, hardship or relocation pay
• Non-cash benefits, e.g. BIK such as company car, stock options, housing support, private healthcare
• Overtime pay
• Other financial benefits linked to performance or role 

May vary by national implementation: 

• Expense reimbursements
• Redundancy or severance payments
• One-off discretionary or “goodwill” bonuses 

In Ireland, expense reimbursements are not currently included in gender pay gap reporting, along with redundancy and severance payments. In Ireland, discretionary bonuses are included if paid during the reporting period. These grey areas are still being clarified at country level, so be sure to keep track of local updates. 

Earned vs contractual pay: Should you report contractual salary or actual pay earned (which can be affected by leave/absence)? Many experts favour contractual pay for consistency, but always follow your country’s rules. Ireland requires reporting based on actual pay earned during the snapshot period, not contractual salary. 

Build a complete internal picture of reward - not just base salary but also variable pay and in-kind benefits. 

Producing meaningful comparisons will require: 

• A single source of truth for all reward components.
• Consistent treatment of “grey areas” (e.g. expenses, discretionary bonuses).
• Transparency around which elements are included, and why. 

See also: How should companies calculate gender pay gaps? 

See also: What’s the minimum sample size for pay gap reporting, and what if we don’t meet it?

“Pay” is more than a payslip. Using the Directive’s broader definition helps your reporting reflect the real value of reward, and avoids disputes over what has or hasn’t been counted. 

Clear, consistent rules don’t just support compliance - they build trust by showing everyone is measured against the same transparent standards. 

Pay in Ireland 

In Ireland, the definition of “pay” under the Gender Pay Gap Information Act 2021 is broad and aligns closely with the EU Directive. Employers must report not only base salary, but also bonuses, benefits in kind (such as company cars or private healthcare), and overtime pay. Discretionary bonuses are included if paid during the reporting period, while expense reimbursements and severance payments are excluded. Importantly, Ireland requires reporting based on actual pay earned during the snapshot period in June, rather than contractual salary. This ensures that the data reflects real-world compensation and supports meaningful comparisons across roles and genders.  

Learn more about Gender Pay Gap Reporting in Ireland here.