RDJ Employment Law Round-Up

RDJ Employment Law Round-Up – August 2026

This month, we are examining several significant developments affecting employers, including key WRC decisions concerning family-related rights, pregnancy discrimination, reasonable accommodation, working time compliance, minimum wage obligations and unfair dismissal. We also consider the Government's proposal to introduce statutory paid leave for pregnancy loss, a potentially significant development in the evolution of workplace rights and employee supports. Together, these developments provide valuable insight into emerging trends and areas of focus for employers as the employment law landscape continues to evolve.

Parent's Leave Protections: WRC Awards Over €51,000 to Employee Following Return from Parent’s Leave

Case: Tommi Wong v Deel Ireland EOR Limited (ADJ-00064133, 30 June 2026)

This decision, arising out of a complaint taken by the Head of Sales for the Nordic region of Deel Ireland EOR Limited, resulted in a substantial award of €51,004.20 across several successful complaints. 

The Complainant was employed from 7 May 2025 until 4 December 2025. He alleged that throughout June 2025, he was required to work every day, including weekends, without compensation or time off in lieu, and that he was denied the statutory rest periods to which he was entitled under the Organisation of Working Time Act 1997 (the "1997 Act"). Separately, he claimed that after he was approved for parent's leave in July 2025, he was informed that there may be no role available to him on his return, or that he may return to a worse role. The Complainant interpreted this as a threat connected to his decision to avail of that leave. 

The Complainant took parent's leave from 18 August to 20 October 2025. On his return, he submitted that his role had been fundamentally altered, his duties reassigned, his reporting line changed, and his position left unclearly defined. He further alleged that he was excluded from workplace communications, subjected to unjustified performance and disciplinary measures, and had his probationary period extended in circumstances he regarded as punitive and unrelated to his performance. He also raised a complaint concerning pension contributions totalling €2,029.60 which, he contended, had been deducted from his salary but never added to his pension fund. 

The Respondent denied these contentions. It maintained that the Complainant was not required to work on Sundays, that the probation extension lawfully mirrored his statutory leave absence, and that it had sought to engage with him upon his return. It produced no direct evidence to rebut the allegations concerning role changes, exclusion, or disciplinary measures. As regards the pension deductions, the Respondent relied on the contract of employment and argued that deductions were permissible where an employee had opted into a PRSA arrangement. 

Decision

In respect of the Sundays worked in June 2025, the Adjudication Officer awarded €1,500 as the Respondent presented no evidence that the Complainant was neither required nor instructed to work Sundays during June 2025. 

In respect of rest periods, the Respondent failed to produce any working time records capable of establishing that the Complainant was afforded the statutory rest periods as required by p 13 of the 1997 Act during June 2025. An award of €2,000 was made in respect of this complaint. 

On considering an issue in relation to p 17 of the 1997 Act, the Adjudication Officer did not accept that the p imposed an obligation on the Respondent to provide the Complainant with 24 hours’ notice for a meeting in circumstances where there the contract of employment already specified the Complainants normal working hours, highlighting that the statutory requirement is concerned with the provision of information where working hours are not otherwise specified. 

The Adjudication Officer determined that, in accordance with p 6D of the Terms of Employment (Information) Act 1994, the extension of the Complainant’s probation mirrored the Complainants statutory leave and remained within the statutory maximum and therefore the complaint was not well founded. 

The Adjudication Officer found that the Complainant was subject to discrimination on the family status ground. A reasonable comparator would not expect to be informed that their role might not exist due to taking statutory leave. Three months' remuneration totalling €31,114.20 was awarded in respect of the effects of this discrimination. 

In the absence of any direct evidence from the Respondent capable of rebutting the Complainant’s evidence, the Adjudication Officer found that the Complainant was penalised within the meaning of the Parent’s Leave and Benefit Act 2019. This was manifested through a combination of changes to his working conditions: role uncertainty, an altered reporting structure, exclusion from communications, and the application of disciplinary and performance measures. The penalisation was found to be directly connected to the Complainant's exercise of his statutory right to parent's leave. The Adjudication Officer awarded €14,360.40 in respect of the effects of the penalisation. 

The Adjudication Officer awarded €2,029.60 in respect of the pension contribution deductions. While the Complainant’s contract provided for an optional PRSA arrangement, the Respondent failed to adduce any evidence that the Complainant had authorised, or given prior written consent to, the deductions.

Employer Takeaways

• Protect employees taking family leave: Ensure employees are not disadvantaged, threatened or treated less favourably because they exercise statutory leave rights.
• Maintain role continuity: Employees returning from parent's leave should, wherever possible, return to the same role and reporting structure, with any changes clearly justified and documented.
• Train managers: Managers should understand the legal protections attaching to parent's leave and avoid comments that could be interpreted as discouraging or penalising employees from taking leave.
• Keep comprehensive records: Maintain working time records demonstrating compliance with statutory rest break requirements and any evidence supporting performance management decisions.
• Review communication practices: Ensure employees on family leave remain appropriately informed and are not excluded from relevant workplace communications.
• Verify payroll deductions: Employers should retain clear evidence of employee consent for pension or other salary deductions and ensure monies deducted are remitted appropriately.

Why This Matters

This decision highlights the significant financial exposure that can arise where an employer cannot demonstrate that an employee's treatment following a period of statutory leave was unrelated to that leave. It also reinforces the importance of documentary evidence. In the absence of evidence rebutting allegations of adverse treatment, the WRC was prepared to infer discrimination and penalisation, resulting in awards exceeding €45,000 for those breaches alone.

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Government Approves Proposal to Draft Leave for Pregnancy Loss Bill

The Government has approved a proposal by Minister for Enterprise, Tourism and Employment, Peter Burke TD, to draft a Leave for Pregnancy Loss Bill (the “Bill”), a significant development for Irish employment law that would, for the first time, provide a statutory entitlement to paid leave for those who experience pregnancy loss prior to 23 weeks' gestation. 

Under existing legislation, maternity leave entitlements apply only where a pregnancy loss occurs from 23 weeks' gestation onwards. The current legislative framework therefore creates a significant gap in statutory protection. 

The General Scheme of the Bill was informed by a government-commissioned study "PLACES | Pregnancy Loss (under 24 weeks) in Workplaces: Informing policymakers on support mechanisms" which was carried out by the Pregnancy Loss Research Group at University College Cork. 

The study highlighted the need for statutory paid leave in cases of pre-viability pregnancy loss and found that such losses are frequently treated as private events attracting little formal workplace acknowledgement. 

The proposed Bill also responds to the policy ambitions of earlier Private Members' Bills, including the Organisation of Working Time (Reproductive Health Related Leave) Bill 2021 and the Pregnancy Loss (Miscellaneous Provisions) Bill 2025. 

Minister Burke stated that “Our labour laws must reflect the realities of modern working life, including the impact that pregnancy loss can have”. He added that a statutory entitlement to leave would strengthen workers' rights and ensure that employees are supported and treated with dignity at what is, undoubtedly, a very difficult time. 

The Bill would introduce five days of paid leave per year for inpiduals who experience pregnancy loss prior to 23 weeks gestation. The proposed rate of pay is 70% of the employees’ daily rate, capped at €110 a day, consistent with the applicable rate for statutory sick leave. Medical certification will be required. 

 The entitlement to leave will arise from day one of employment, though the entitlement to payment will be conditional on 13 weeks prior service. The Bill will not apply where an employer operates a pregnancy loss scheme that is, taken as a whole, more favourable to employees.

In Northern Ireland, two weeks leave is available for pregnancy losses before 24 weeks, with payment set at £194.32 per week or 90% of the employee’s weekly earnings, whichever is the lower figure.

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WRC Awards €50,000 Following Dismissal of Pregnant Employee

Case: Dikeledi Nkele Mushapho v Rose Finlay Pharmacy (Tullamore) Ltd (ADJ-00058797, 6 July 2026)

This case serves as a stark reminder of the legal and financial risks associated with the treatment of pregnant employees, particularly where an employer fails to engage with WRC proceedings. 

The Complainant brought complaints under p 77 of the Employment Equality Act 1998. She worked as a supervising pharmacist and disclosed her pregnancy to her employer on 18 February 2025. She alleged that from that point, her treatment deteriorated sharply, including heightened scrutiny and micromanagement constituting discriminatory treatment on gender grounds. The Complainant also alleged discriminatory dismissal five weeks after disclosing that she was pregnant. 

On 28 February, the Complainant attended a prenatal appointment and did not return in time for a medication ordering deadline. She alleged that this was used against her as a point of incompetence. 

On 3 March her employer communicated dissatisfaction with her performance. On 7 March a consultant was engaged to assess her performance. The Complainant noted that the consultant’s language included expressions of personal disappointment, which was notably more personal than professional. 

On 21 March, the Complainant was summoned, without prior notice, to a meeting with the owner during her scheduled break. The owner indicated ongoing dissatisfaction with her progress and proposed that she move to a support pharmacist role, a clear demotion. The Complainant was unable to take her break because of the meeting and was required to return to work immediately afterwards. 

When she sought reasons for the proposed change, she received an email to the effect that refusal to accept the demotion would result in dismissal. 

Upon declining the demotion, she was dismissed with four weeks' notice and no fair process. Critically, she submitted that no performance concerns had been raised prior to her pregnancy disclosure. 

The Complainant submitted that, while the right to appeal was referenced in the handbook and her dismissal letter, the handbook directed employees to appeal to either the floor manager or the supervising pharmacist. The floor manager was on maternity leave and the Complainant herself held the supervising pharmacist role. Therefore, the only inpidual available to receive the appeal was the same person who issued the dismissal and attempted to demote her after she indicated that she was pregnant. 

Decision

The Adjudication Officer observed that, to shift the burden of proof to the Respondent, the Complainant was required only to establish that she was pregnant and that a dismissal had occurred. The Respondent did not attend the hearing and made no submission to the WRC. In those circumstances, the Adjudication Officer found that the Complainant had been discriminatorily dismissed in circumstances directly connected to her pregnancy and awarded her €50,000. 

Employer Takeaways

• Exercise caution when managing performance concerns involving pregnant employees: Ensure any concerns are genuine, documented and capable of being objectively justified.
• Avoid pregnancy-related assumptions: Decisions regarding role changes, promotions, demotions or dismissals should be clearly separated from an employee's pregnancy.
• Follow fair procedures: Employees should be given notice of meetings, an opportunity to respond to concerns and access to a meaningful appeal process.
• Maintain comprehensive records: Employers should be able to demonstrate the rationale for performance management decisions and disciplinary action.
• Engage with WRC proceedings: Failure to attend or defend a claim can leave allegations uncontested and significantly increase legal exposure.

Why This Matters

This decision reinforces the enhanced protections afforded to pregnant employees under Irish employment equality legislation. It also demonstrates how difficult it can be for an employer to defend a pregnancy-related dismissal where concerns arise shortly after a pregnancy disclosure and where there is insufficient evidence to establish a legitimate, non-discriminatory basis for the employer's actions. The case is a reminder that failing to engage with WRC proceedings can have significant financial consequences.

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€14,257 Award for Minimum Wage and Annual Leave Breaches Following Failure to Keep Records

Case: Dongming Hou v Buildify Construction and Technology Limited (ADJ-00064191, 30 June 2026)

The Complainant, a Chinese national, brought a claim against the Respondent, a construction company, for underpayment of wages under the National Minimum Wage Act 2000 (the “2000 Act”). 

The Complainant worked for the Respondent on a probationary basis from July 2024 until the termination of his contract on 26 March 2025. The Complainant was hired as a construction engineer with the understanding that the Respondent would assist him in obtaining an employment permit. The Complainant was paid €1,600 per month (€800 cash and €800 bank transfer) and was provided with accommodation during the employment. The Complainant’s understanding was that his monthly wage would subsequently increase following successful completion of the probationary period. 

However, a preliminary issue arose regarding the period for submission of complaints. p 41, subp 6 of the Workplace Relations Act 2015 provides a 6-month duration post expiration of the period referred to in the complaint in which such complaints may be entertained. Though, this provision could be rebutted if a reasonable cause existed which affected the Complainant’s complaint. 

The Adjudicator considered multiple factors in his decision:

• Following the termination of his employment, the Complainant found himself in an exceptionally vulnerable position; 
• He was told to vacate his accommodation upon termination; 
• Limited English language skills; 
• Unfamiliarity with Irish employment rights legislation and procedures; 
• Uncertainty regarding immigration/employment permit status; and 
• He initially sought to recover losses directly from his employer. 

 The Adjudicator found that these circumstances, taken in conjunction, constituted reasonable cause in a delay in presenting the complaint. 

The Complainant, who was represented by Pretty Ndawo of the Migrant Rights Centre Ireland, submitted that throughout the course of his employment, duties extended beyond the normal duties of a construction engineer. These duties included a range of tasks such as painting, electrical installation and plumbing. 

The Complainant submitted that he worked a weekly average of 56.76 hours. This was substantiated by photographic evidence through a WeChat work group, which was used by the Respondent to monitor attendance. Employees were required to upload photographs when commencing and finishing work. These photographs included time stamps. The Complainant analysed a period from 2 September 2024 to 7 December 2024 to find the average working week. This was the period where the most complete records were available. 

A request for a statement of average hourly pay had been issued to the Respondent pursuant to p 23 of the 2000 Act. No response from the Respondent was received by theComplainant. It was submitted that the Respondent failed to provide statutory information sought. 

The Complainant analysed his total hours worked against the applicable statutory minimum wage rates. An underpayment of €12,151.34 was calculated. In addition, no annual leave was taken throughout his employment. The Complainant calculated the value of accrued annual leave to be €2,106.02. This figure was reached by using the hours worked and the statutory formula contained in p 19 of the Organisation of Working Time Act 1997 (the “1997 Act”). 

It is important to note that the Respondent did not attend the hearing. The evidence submitted by the Complainant was therefore entirely uncontested. 

Authorities such as Sue Ryder Foundation Ireland Ltd v Maureen Meenagh MWD051 and Imtiaz Ahmed Ranjha Sky Solicitors v Imtiaz Khan MWD212 were relied upon by the Complainant to seek arrears for the entirety of the period. This was accepted by the Adjudicator. 

Decision

The Adjudicator accepted the Complainant’s evidence supporting his average weekly hours. The photographic evidence taken from the WeChat software was contemporaneous in nature, it recorded commencement and finishing times and were maintained at the direction of the Respondent. The Adjudicator stated that in situations where an employee presents detailed records of hours and the employer, who is obliged to maintain records, produces none, it is appropriate to attach significant weight to those records. Therefore, the Adjudicator accepted that the Complainant worked an average of 56.76 hours per week during the relevant period. He further accepted the calculated figure of remuneration owed to the Complainant. 

The Adjudicator found that arrears of remuneration in the sum of €12,151 was due. 

The Respondent failed to provide any evidence to rebut the claims made by the Complainant that no annual leave was taken and no payment in respect of annual leave entitlement was made. The 1997 Act mandates that employers both provide annual leave and maintain records of compliance. The Adjudicator stated that the Respondent failed to discharge either obligation. Subsequently, the Adjudicator accepted the calculation of €2,106 covering the annual leave owed. 

The total amount awarded to the Complainant was €14,257.

Employer Takeaways

• Maintain accurate records: Ensure comprehensive records of hours worked, pay, annual leave and rest periods are maintained and readily accessible.
• Respond to statutory information requests: Requests for information relating to pay and working hours should be dealt with promptly and in accordance with statutory requirements.
• Monitor working hours carefully: Where employees work extended hours, employers should regularly review compliance with minimum wage and working time obligations.
• Document accommodation and remuneration arrangements: Any deductions, benefits in kind or accommodation arrangements should be clearly documented and compliant with relevant legislation.
• Engage with WRC proceedings: Failure to participate in proceedings may result in an employee's evidence being accepted without challenge.

Why This Matters

This decision demonstrates the crucial role employment records play in defending wage and working time claims. It also illustrates the willingness of the WRC to rely on alternative forms of evidence, including digital attendance records and employee-generated documentation, where employers fail to maintain statutory records. For employers, the case serves as a reminder that robust record-keeping and active engagement with workplace disputes are essential to managing legal and financial risk.

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€60,230 Award Highlights Importance of Fair Procedures and Communicating the Reason for Dismissal

Case: Helen Nason v Horizon Controls Limited (ADJ-00052475, 20 May 2026)

The Complainant brought a claim against the Respondent under the Unfair Dismissals Acts 1977–2015, alleging that she had been unfairly dismissed from her position as Chief Financial Officer. 

The Complainant was employed by the Respondent from 5 December 2022 until 30 April 2024. She submitted that throughout her employment there had been no concerns regarding her performance. 

Prior to her dismissal, she had repeatedly warned the Chief Executive Officer of the financial risks associated with investment in an unprofitable technology project and had expressed concerns regarding the company's financial direction. Approximately two to three months before her dismissal, one of the Respondent's companies lost a multimillion-euro contract. On 3 April 2024, the Complainant was informed that her employment was to be terminated. She was given no reason for her dismissal, no opportunity to appeal the decision, and her access to the company's IT systems was revoked shortly afterwards. Following her dismissal, the Complainant made a statutory request under p 14 of the Unfair Dismissals Act 1977 (the “1977 Act”) seeking written reasons for her dismissal. The Respondent failed to provide any response. 

The Respondent accepted that the dismissal procedure was flawed but maintained that the dismissal arose by reason of a genuine redundancy. It submitted that the company had experienced significant financial difficulties, including substantial budget shortfalls and the loss of a major contract. Prior to the Complainant's dismissal, she had herself managed eleven redundancies. Following her departure, the Respondent made a further seventeen employees redundant and did not replace twenty employees who left voluntarily. The Respondent argued that the position of Chief Financial Officer no longer existed and therefore reinstatement was not an appropriate remedy. It further contended that the Complainant had failed to adequately mitigate her financial loss by not applying for lower-paid positions. 

The principal issue for determination before the Adjudication Officer was whether the dismissal was unfair and, if so, the extent to which the Complainant had mitigated her financial loss. 

The Adjudication Officer considered several factors in reaching her decision 

• The Respondent conceded during the hearing that the procedure adopted in dismissing the Complainant was unfair; 
• No reason for dismissal was provided at the time of termination or following the statutory request under p 14 of the 1977 Act; 
• Although redundancy was relied upon during the hearing, it had not been communicated to the Complainant at the time of her dismissal; 
• The Respondent failed to discharge the statutory burden of proving that the dismissal fell within one of the grounds contained in p 6(4) of the 1977 Act; and 
• The Complainant had undertaken extensive efforts to secure alternative employment following her dismissal. 

The Complainant submitted that she commenced searching for employment immediately following her dismissal. She gave evidence that she spent several hours each day applying for new roles and ultimately submitted applications for 146 positions. As a qualified Chartered Accountant, she widened her search beyond Chief Financial Officer roles to include Financial Controller and Director positions and was willing to relocate if necessary. Although she eventually secured alternative employment in October 2024, it was at a significantly reduced salary with fewer benefits. She calculated her financial loss at €60,230, which included loss of salary and superannuation. 

The Respondent argued that the Complainant's efforts to mitigate her losses were insufficient. It submitted that, given her senior qualifications and experience, she should have secured alternative employment sooner and should have applied for lower-paid roles with a view to negotiating salary. It was further suggested that she had reduced her job-search efforts during the summer months. 

The Adjudication Officer considered the provisions of ps 6, 7 and 14 of the 1977 Act together with the principles governing an employee's duty to mitigate loss. Particular reliance was placed upon Sheehan v Continental Administration Company Ltd UD858/1999, in which it was held that an employee must devote a reasonable amount of time each weekday to seeking alternative employment. 

Decision

The Adjudication Officer found that the Respondent had failed to establish a valid ground for dismissal within p 6(4) of the 1977 Act. While redundancy was advanced during the hearing, it had not been relied upon at the time of dismissal, nor had any explanation been provided to the Complainant despite her statutory request. The Adjudication Officer held that the failure to provide any reason for dismissal was itself unreasonable and likely hindered the Complainant's ability to obtain alternative employment. Accordingly, the dismissal was found to be unfair on both substantive and procedural grounds. 

Having considered the evidence, the Adjudication Officer accepted that the Complainant had made reasonable efforts to mitigate her losses. Her evidence that she spent several hours each day applying for employment was accepted, together with the fact that she had applied for a substantial number of positions before securing employment at a lower salary. The Adjudication Officer therefore concluded that compensation, rather than reinstatement, was the appropriate remedy. 

The Adjudication Officer found that the Complainant had been unfairly dismissed and awarded €60,230 by way of compensation. 

Employer Takeaways

• Clearly communicate the reason for dismissal: Employees should be informed of the reason for any dismissal at the time the decision is made.
• Follow a fair dismissal process: Employees should be afforded appropriate consultation, an opportunity to respond and access to a meaningful appeal process.
• Respond to statutory requests: Requests for written reasons for dismissal should be addressed promptly and comprehensively.
• Document redundancy processes carefully: Where redundancy is relied upon, employers should ensure the rationale, consultation process and selection decisions are clearly documented.
• Avoid retrospective justification: The reason relied upon during litigation should be consistent with the reason communicated at the time of dismissal.

Why This Matters

This decision demonstrates that a potentially genuine business rationale for dismissal may not be sufficient where fair procedures are not followed. It also highlights the importance of clearly communicating the basis for dismissal and maintaining appropriate records throughout the process. For employers, the case serves as a reminder that procedural fairness remains a fundamental component of any dismissal and that a failure to comply with those obligations can result in substantial financial liability.

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€25,000 Disability Discrimination Award Highlights Importance of a Structured Reasonable Accommodation Process

Case: A Complainant v A Large Retail Store (ADJ-00064610, 10 July 2026)

The Complainant, who had been employed by the Respondent retailer since January 2005, brought claims under the Employment Equality Acts 1998–2015 and the Payment of Wages Act 1991. The Complainant, who had been diagnosed with Alzheimer's disease, alleged that the Respondent failed to provide reasonable accommodation for his disability, subjected him to harassment, discriminated against him by demoting him from Line Manager to Customer Assistant, and unlawfully withheld wages after his company sick pay entitlement expired. The Respondent denied all complaints. 

The Complainant, represented by his partner, submitted that despite repeated occupational health reports and specialist recommendations, the Respondent failed to implement key accommodations, including fixed daily shifts from the outset, written memory aids and planograms. It was further argued that the Respondent failed to engage with external disability support services or explore other available supports, contrary to its statutory obligations. The Complainant also claimed that he was pressured to produce an urgent medical report, which amounted to harassment, and that his wages ceased unfairly once company sick pay ended. 

The Respondent contended that it had provided reasonable accommodation by introducing fixed shifts, allocating familiar work areas, reducing workloads and providing daily assistance from colleagues. It argued that written instructions and planograms were not practical in the store environment and maintained that the decision to place the Complainant on sick leave was taken for health and safety reasons following conflicting medical evidence. The Respondent also submitted that the cessation of wages was in accordance with its contractual sick pay policy. 

Decision

The Adjudicator found that the claims of demotion and harassment were not well founded. The demotion complaint was outside the statutory time limit, while the evidence did not establish that the treatment complained of amounted to harassment on the disability ground. 

However, the Adjudicator held that the Respondent failed to provide reasonable accommodation. Although some adjustments had been made, the employer had not carried out a comprehensive assessment of the Complainant's needs or explored external supports, public funding or other reasonable measures as required by the Employment Equality Acts and the Supreme Court decision in Nano Nagle School v Daly [2019] IESC 63. The Adjudicator concluded that the Respondent had not discharged its statutory duty to make appropriate enquiries before deciding what accommodations were feasible. 

The complaint under the Payment of Wages Act 1991 was rejected, as the cessation of wages was found to be consistent with the Respondent's contractual sick pay policy. 

The Adjudicator upheld the complaint concerning the failure to provide reasonable accommodation and awarded the Complainant €25,000 in compensation. The Respondent was also directed to review its policies, in consultation with the relevant trade unions, regarding the accommodation and treatment of employees with disabilities.

Employer Takeaways

• Adopt a structured accommodation process: Establish a clear process for assessing, implementing and reviewing reasonable accommodation measures.
• Conduct a comprehensive assessment: Consider the employee's specific needs, medical advice and the practical adjustments that may assist them in performing their role. 
• Explore all available supports: Consider occupational health recommendations, external disability support services, assistive technologies and available public funding.
• Document decision-making carefully: Keep detailed records of consultations, medical advice obtained, accommodations considered and the reasons for decisions made.
• Review disability policies regularly: Ensure policies reflect current legal requirements and recent developments in reasonable accommodation obligations.

Why This Matters

This decision reinforces that the duty to provide reasonable accommodation is an active and ongoing obligation. Employers cannot simply implement a limited number of adjustments and assume their obligations have been discharged. They must engage meaningfully with the employee, assess available options and demonstrate that all reasonable measures have been considered before concluding that further accommodations are not possible. The case highlights the significant legal and financial risks that can arise where employers fail to follow a structured and well-documented accommodation process.