Upcoming publication deadline for gender balance on boards data
The publication deadline of 30 November 2026 is fast approaching for relevant listed companies to reveal their gender balance on boards information both to the Minister for Children, Disability and Equality (Minister) and on their websites.
This article follows up on our earlier publication: New gender balance targets for Irish listed companies | A&L Goodbody LLP
By 30 June 2026 relevant listed companies were required to have set individual quantitative objectives with a view to improving the gender balance among executive directors and to have specified in writing the steps taken or being taken to achieve these objectives.
30 June 2026 was also the target date for relevant listed companies to meet the target of 40% of non-executive directors’ positions to be held by members of the underrepresented sex.
For all relevant listed companies
A. They must provide details of the gender representation of the board – distinguishing executive and non executive directors (to be uploaded to the Gender Pay Gap Portal, according to a response by the Minister).
B. Additionally, they must furnish information on:
- measures taken to achieve the 40% non-executive directors’ target
- measures taken to achieve improved gender balance among executive directors, the individual quantitative objectives for improving the gender balance among executive directors and the steps taken or being taken to achieve these objectives
C. Where the objectives have not been achieved, the information must include the reasons why they were not achieved as well as a comprehensive description of the measures taken, or to be taken, to achieve the objectives.
This information must also be made available on the company’s website and as part of the company’s next Corporate Governance Statement, a copy of which must be submitted to the Minister.
Failure to meet 40% non-executive director threshold
For companies that did not meet the target of 40% non-executive directors’ to be members of the underrepresented sex by 30 June 2026, they must disclose the following information by 30 November 2026 (and annually thereafter) to the Minister:
A. How they have complied with their statutory obligations by demonstrating that they have:
- established written clear, neutrally formulated and unambiguous criteria in advance of the selection process
- selected candidates based on a comparative assessment of their qualifications
- applied the selection criteria in a non-discriminatory manner throughout the entire selection process
B. Where shareholders or employees vote on appointments of non-executive directors, the company must also provide evidence of compliance with the information requirements set out in the legislation.
C. The company must document in writing its compliance with the obligation to prioritise the underrepresented sex and provide this information. If the priority was overridden, the company must provide a list of the reasons of greater legal weight it applied to override the priority.
Consequences of failing to meet the requirements within the deadline
Failure to meet the requirements may mean that the company will be included in a public list for non-compliance.
What entities do these obligations apply to?
Relevant listed companies have an Irish registered office and shares admitted to trading on an EU regulated market (and not micro, small, medium-sized enterprises, or SMEs).
A micro, small and medium-sized enterprise or SME is a company that employs less than 250 persons and has an annual turnover not exceeding €50,000,000 or an annual balance sheet total not exceeding €43,000,000.
Applicable law: S.I. No. 215/2025 - European Union (Gender Balance on Boards of Certain Companies) Regulations 2025.
The Department of Children, Disability and Equality has been designated as the monitoring authority, and the Irish Human Rights and Equality Commission has been designated as a body to support companies in achieving the objectives.
Key Takeaway
Boards should act now and ensure that the necessary company information is submitted to the Minister and published on the company’s website by 30 November 2026.
For further information on these requirements please contact any member of A&L Goodbody’s Corporate Advisory team, Michelle McLoughlin, Senior Practice Development Consultant or Rebecca Clark, Senior Practice Development Lawyer.
