Last year saw a number of changes in employment law. In Northern Ireland, the return of the Assembly was followed by the Good Jobs Employment Rights Bill Consultation. Labour returned to power in the UK general election and introduced a significant package of reforms in its Employment Rights Bill (ERB) that could fundamentally change employment law in GB. In Ireland, sick pay was introduced and employers started preparing for pension autoenrollment.

 

Tughans Employment team look ahead at the key developments to expect in 2025 across NI, GB and Ireland.

 

“Good Jobs” Employment Rights Bill

Consultation closed back in September 2024, before the publication of the ERB in GB. Our assessment of the Good Jobs consultation and how it compares with the ERB proposals is here

 

The draft Bill is expected in March 2025. Once published, there will be further detailed consultation. It may be the case that further changes will be introduced within the draft bill that were not covered in the initial consultation. Employers should carefully monitor the proposals as they progress through the Assembly.

 

Gender Pay gap reporting in NI

Legislation for gender pay gap reporting (GPGR) was passed in NI in 2016, with the requirement that implementing regulations would be made by 30 June 2017, and that the Department would publish a strategy to eliminate gender pay gaps by 22 October 2017. These deadlines were not achieved and GPGR was never implemented.

 

In November 2024, the Department for Communities launched a consultation on implementing regulations for gender pay gap reporting. Consultation closes on 14 February.

 

The draft proposals would largely bring NI in line with the GB equivalent requirement for employers with 250 or more employees to publish GPGRs each year.

 

The 2016 legislation included then unique requirements for employers to publish GPG action plans and include statistics on the ethnicity and disability status of workers within each pay band in their GPGR.

 

In GB, the ERB will make equality action plans compulsory, and the forthcoming Equality (Race and Disability) Bill will go further than the 2016 NI legislation, by making full ethnicity and disability gap reporting compulsory for employers with 250 or more employees.

 

The Department has indicated that it will take around 18 months to amend the 2016 legislation, and that the implementing regulations will be made as soon as possible after that. This will likely be in 2027, with the first reports being made in 2028.

 

However, the Department’s consultation response may be published in 2025, with the main point of interest being whether the 250 employee threshold will be maintained or reduced (for example, to match the much lower 50+ threshold from 2025 in Ireland).

 

National Minimum Wage UK

Increased minimum hourly rates will apply from 1 April 2025:

 

These increases are significant and will apply alongside the changes to Employer National Insurance Contributions announced in the recent autumn budget. The UK government’s stated aim is to eventually remove the 18-20 age bracket and achieve a unified adult minimum wage.

 

Statutory leave payment rates

The payment rates for statutory maternity, adoption, paternity, shared parental, and parental bereavement pay will increase slightly, from £184.03 to £187.18 per week.

 

Statutory Sick Pay

The SSP payment rate will increase slightly from £116.75 per week to £118.75.

 

The ERB would make SSP more accessible by removing the three qualifying days and creating a tapered SSP entitlement for workers paid less than the lower earnings limit. Consultation on these changes closed on 4 December 2024 and could theoretically be made in 2025. However, the government may be reluctant to make these changes in the short-term given the rise of other employer costs in the autumn budget.

 

Although the ERB only applies in GB, changes to SSP rules have customarily been immediately followed in NI, and NI employers were encouraged to participate in the GB consultation.

 

Paid neonatal leave in GB

Legislation for up to 12 weeks paid statutory neonatal leave has already been passed in GB and this entitlement is expected to become effective in April 2025, though the exact timing will depend on implementing regulations.

 

Equivalent proposals are part of the Good Jobs consultation in NI and may develop in 2025.

 

Paternity bereavement leave in GB

Immediately before the general election, the previous UK government passed legislation which would extend paternity leave for the partners of mothers or primary adopters who die in the first year following the child’s birth or adoption, to up to 52 weeks. Regulations to implement this legislation were originally intended for 2025.

 

The legislation received cross party support and during the elections, Labour committed to passing the necessary regulations. They are yet to be published and may not be ready in time for April 2025. There are no equivalent proposals in NI at the moment.

 

ERB progress in GB

The ERB is currently going through the “committee stage” of its progress through the House of Commons. It is expected to become law in the summer of 2025. Once it passes, there will need to be further regulations to actually implement each reform.

 

The government has already completed four consultations on specific ERB reforms, and its responses to these, plus further consultations for other ERB proposals, will follow throughout 2025.

 

This means that the direct impact of the ERB should be limited in 2025, but given the nature and scope of the proposed reforms, employers should follow its progress closely, with the view to major change in 2026. This includes, for example, the new “day one” right to unfair dismissal protection, which will not be in place before Autumn 2026.

 

What about Ireland?

A number of changes are coming in Ireland this year.

 

The threshold for GPGR has been reduced to employers with 50 or more employees. It is also intended that the reporting deadline will move to November, meaning that employers will have 5 months from their snapshot date in June to report on their gender pay gap.

 

Increased minimum hourly rates apply from 1 January 2025:

 

The national living wage will replace the national minimum wage from 2026. The living wage will be set at 60% of the median wage in any given year.

 

The payment rates for statutory maternity, adoption, paternity, and parent’s benefit will also increase to €289 per week. Jobseekers allowance (aged over 25) will increase to €249 per week.

 

It was anticipated that employees’ paid sick leave entitlement would increase to 7 days in 2025. The Irish Government is reviewing the impact of statutory sick leave before deciding on any further increases for 2025 and 2026. The current entitlement remains at 5 days, payable at 70% of normal weekly pay, up to a maximum €110 a day.

 

Pension auto-enrolment will start on 30 September 2025 with the introduction of the Auto-Enrolment Retirement Savings Scheme, called My Future Fund. Employees aged between 23 and 60, earning €20,000 or more per year, who aren’t already part of a pension scheme are eligible and will be automatically enrolled.

 

Contribution rates will increase gradually:

Employer and government contributions are capped at €80,000 gross annual salary.

 

For legal guidance and advice regarding Employment Law queries, please contact our Employment Team for more information.

While great care has been taken in the preparation of the content of this article, it does not purport to be a comprehensive statement of the relevant law and full professional advice should be taken before any action is taken in reliance on any item covered.