Belfast closed its first full Salary Transparency Month cycle inside a regulatory framework that still, as of August 2026, generates zero mandatory gender pay gap reports from Northern Ireland-domiciled employers. That is not the same position the city held twelve months ago. On 7 October 2025, the Department for Communities published its response to the gender pay gap reporting consultation that closed on 14 February 2025 — marking the first substantive Executive-level indication that Section 19 of the Employment Act (Northern Ireland) 2016 will proceed toward commencement.[^1][^2][^3] The response does not commence Section 19. It does not lay draft regulations. But it establishes the DfC's published position that mandatory gender pay gap reporting should be introduced in Northern Ireland, and it sets the terms on which draft regulations will be developed. That shift from consultation to published response matters for Belfast's AI hiring market because the anchor employers that define the city's technology labour supply — Citi's 4,000-strong Titanic Quarter campus, Kainos Group plc's Belfast headquarters, Allstate Northern Ireland's 1,800-person operation, Liberty IT, and BT Group's Riverside Tower — currently sit across three legally distinct compliance regimes. None of that fragmentation is resolved by the October 2025 response. Belfast AI salaries in 2026 — from £38K at junior ML engineer entry to £120K at principal level, per ENTRA's Q2 Northern Ireland AI Compensation Survey — remain opaque because no mandatory pay disclosure standard applies across any of the city's anchor employers. But the direction of travel is now on the record.
The Legislative Position: Section 19 and the DfC Response
Great Britain has required statutory gender pay gap reports from employers above 250 employees since April 2018, under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017. Those regulations do not extend to Northern Ireland, where the Equality Act 2010 does not apply. Employment law in Northern Ireland remains devolved to the Stormont Assembly and operates under a distinct legislative framework, including the Sex Discrimination (Northern Ireland) Order 1976 and the Fair Employment and Treatment (Northern Ireland) Order 1998. Section 19 of the Employment Act (Northern Ireland) 2016 was drafted precisely to create a power for the Executive Office to introduce mandatory gender pay gap reporting by regulation. The Act left the threshold, the required disclosures, and the enforcement mechanism to secondary legislation.[^1]
Through the Assembly's 2017 collapse, the two-year 2022 hiatus, and the restoration of the Executive in February 2024, no commencement order was ever issued. The Equality Commission for Northern Ireland renewed its call for action in successive policy statements, most recently in its January 2025 submission to the DfC consultation.[^4] The DfC consultation, which ran from autumn 2024 and closed 14 February 2025, sought views on the design of a Northern Ireland gender pay gap reporting regime — the reporting threshold, snapshot date, required metrics, and enforcement approach.[^2]
The DfC published its consultation response on 7 October 2025.[^3] The response confirmed that the majority of consultation respondents supported the introduction of mandatory gender pay gap reporting in Northern Ireland, and indicated the Department's intention to develop draft Section 19 regulations. As of August 2026, those draft regulations have not been laid before the Assembly, and no commencement date has been announced. The Equality Commission for Northern Ireland's 2026 workplan identifies Section 19 commencement as its top statutory reform priority for the current Assembly term.
EU Directive 2023/970/EU: The Instrument That Does Not Apply
One clarification is essential for Belfast employers benchmarking their disclosure obligations against continental European peers. EU Directive 2023/970/EU on pay transparency — which requires EU Member States to introduce binding pay transparency rules by 7 June 2026, including mandatory salary range disclosure in job advertisements and the right for employees to request information about pay levels across comparable roles — does not apply to the United Kingdom.[^5] Post-Brexit, the UK is not subject to EU Directives. Northern Ireland's position under the Windsor Framework creates specific alignment obligations for goods trade, but employment law is not within scope of the Framework's provisions. Belfast employers are therefore not subject to the Directive's pay disclosure requirements, the Directive's equal pay audit obligations (triggered when a pay gap of five percent or more cannot be justified), or the Directive's remediation and reporting timelines. The relevant instruments for Belfast AI employers are entirely domestic: the GB gender pay gap regulations (for those reporting entities where the parent is Great Britain-headquartered), Section 19 of the Employment Act (NI) 2016 (for when it commences), and the Employment Rights Act 2025's equality action plan provisions (for Great Britain operations only, effective April 2027).[^6]
How Belfast AI Employers Report Pay Transparency Data
The three-tier compliance structure is the practical reality of Belfast's technology labour market in August 2026.
Citi. Citi's Belfast operation at the Titanic Quarter campus — a 4,000-plus headcount across technology, operations and risk confirmed by successive Citi UK regional disclosures — is a branch of Citigroup Global Markets Limited, a Great Britain-registered entity.[^7] Citi's Belfast headcount therefore rolls into the Citigroup Global Markets Limited UK-wide gender pay gap filing, consolidated with London, rather than filing as a standalone Northern Ireland employer. The consolidated UK filing does not disaggregate Belfast from London or any other UK site. Citi's 2024 UK Gender Pay Gap Report (Citigroup Global Markets Limited, snapshot date April 2024, published April 2025 on the gov.uk gender pay gap service) is the most recent verified filing for the covered entity.[^8] Belfast-specific figures are not published. ENTRA Q2 2026 tracking of Citi Belfast AI and data engineering postings shows a salary band of £70K to £115K base (~$89K to ~$146K at the £1.27 canonical rate), with financial crime detection, quantitative model validation, and machine learning infrastructure roles clearing the upper end.[^9]
Kainos. Kainos Group plc is the anomaly in Belfast's tech employer stack: Belfast-headquartered, LSE-listed, and one of the few Northern Ireland-domiciled technology employers of sufficient scale to generate voluntary UK GPG disclosure. Kainos files no mandatory Northern Ireland gender pay gap report — none is required. It does publish an annual UK gender pay gap report voluntarily, covering Kainos Software Limited on a UK-wide consolidated basis. The Companies (Miscellaneous Reporting) Regulations 2018 require CEO pay ratio disclosure from premium-listed companies; Kainos has elected to accompany that obligation with GPG data. Kainos's most recent GPG filing on the gov.uk gender pay gap service records a mean pay gap of 19.9 percent and a median pay gap of 22.4 percent across its UK workforce.[^10] Both metrics include the Belfast headcount inside the UK consolidation; Belfast-specific breakdowns are not published. Kainos's Workday practice and its Digital Services division are the dominant Northern Ireland hiring engines for applied ML, generative AI implementation, and digital government delivery talent, at Belfast base ranges of £60K to £95K (~$76K to ~$121K) for senior engineers, per ENTRA recruiter-side tracking through Q2 2026.[^9]
Allstate Northern Ireland. Allstate Northern Ireland Limited (Companies House Northern Ireland: NI045492) is a Northern Ireland-domiciled company. Its US-listed parent publishes human capital disclosures under SEC requirements, but Allstate NI files no UK or Northern Ireland gender pay gap report because no such obligation exists for a Northern Ireland-domiciled employer — Section 19 has not been commenced.[^11] ENTRA H1 2026 signal analysis places Allstate NI ML engineer bases at £65K to £88K and data science leads at £78K to £95K, comfortably above the £38,700 Skilled Worker visa annual salary floor that applies uniformly across the UK, including Northern Ireland.[^9][^12]
BT Group. BT Group's Riverside Tower Belfast operation is included in BT Group plc's GB-consolidated gender pay gap report, since BT Group plc is Great Britain-headquartered. Like Citi, BT publishes no Belfast-disaggregated data within the consolidated filing. BT's AI and network automation engineering roles at Riverside Tower sit at £65K to £90K base in ENTRA's Q2 2026 Belfast tracking.[^9]
Liberty IT (Chichester Street, approximately 550 technology staff) reports through parent-level US disclosures from Liberty Mutual. Deloitte Belfast, part of Deloitte MCS Limited (GB-registered), falls inside Deloitte UK's GPG filing. Of the six largest Belfast tech and AI employers, only Kainos publishes any figure that could be described as Belfast-proximate — and even that is a UK consolidation with Belfast weighting undisclosed.
ENTRA Belfast AI Compensation Estimates, Q2 2026
The Belfast proposition for AI engineers is structurally distinct from London's. ENTRA's Q2 2026 Northern Ireland AI Compensation Survey, covering 120 postings across Belfast, Derry/Londonderry, and cross-border Newry catchments, benchmarks as follows:[^9]
- Junior ML engineer (0–2 years): £38K–£52K (~$48K–$66K)
- Mid-level ML/data science (2–5 years): £58K–£80K (~$74K–$102K)
- Senior IC ML engineer: £75K–£105K (~$95K–$133K)
- Principal/staff ML engineer: £95K–£120K (~$121K–$152K)
Mid-level Belfast roles comfortably clear the Skilled Worker visa annual salary floor of £38,700, effective since 4 April 2024 and unchanged by the July 2025 Statement of Changes. The Global Talent route — no minimum salary floor, endorsement from the Alan Turing Institute or the Royal Academy of Engineering required — is the relevant visa instrument for internationally recognised Belfast AI researchers. It is the same route DeepMind and ARM Cambridge use for exceptional talent.[^12] Northern Ireland employers accessing the Global Talent route face no additional visa complexity relative to their GB counterparts, since immigration is a reserved matter unaffected by devolution.
Three Northern Ireland Pay Transparency Signals to Watch
First, whether the DfC lays draft Section 19 regulations before the Assembly by year-end 2026. The October 2025 consultation response establishes intent; draft regulations are the next legislative step. A draft laid in autumn 2026 could plausibly reach commencement by April 2027, aligning Northern Ireland with the GB Employment Rights Act 2025 equality action plan timeline for the first coordinated reporting cycle. Absent that, Belfast enters April 2027 with no mandatory baseline data.
Second, whether Kainos sustains voluntary GPG publication post-commencement. If Section 19 regulations are made with a 250-employee threshold, Kainos becomes a mandatory reporter. But the shift from voluntary to statutory could also create pressure to limit disclosure to the statutory minimum, removing the voluntary UK-wide consolidated data that is currently the only Belfast-proximate GPG figure available. The Kainos board's posture on publication breadth post-commencement will be the most consequential disclosure decision any Belfast-domiciled tech employer makes in the next eighteen months.
Third, whether the Belfast Region City Deal's AI-facing programmes — including the Global Innovation Institute at Queen's University Belfast and the Advanced Manufacturing Innovation Centre at Ulster University — introduce pay band publication as a condition of participation for private-sector partners. The City Deal committed £850M over fifteen years from December 2021, with match funding from participating employers.[^13] Conditioning co-funding on salary range disclosure would be an instrument Stormont could pull without waiting for Section 19 commencement, and would land directly on the Citi, Kainos, and Liberty IT anchors expanding their Belfast AI functions fastest in 2026.
Belfast's AI labour market case — London-rate remote contracting paired with Belfast's cost base, a spread ENTRA estimates at approximately £13,000–£15,000 in annual residential savings against London Zone 2 — depends on legible salary data from Belfast employers. The October 2025 DfC response means the regulatory architecture for that legibility is in development. The draft regulations are not yet written. The data does not yet exist. But the direction of travel is, for the first time since Section 19 reached the statute book, on the record.
[^1]: Section 19, Employment Act (Northern Ireland) 2016, per Department for Communities. The section confers a power on the Executive Office to make regulations requiring employers to publish gender pay gap information; it is not self-executing and requires commencement regulations separately made.
[^2]: Department for Communities (Northern Ireland) gender pay gap reporting consultation. Consultation closed 14 February 2025. Consultation document published at www.communities-ni.gov.uk.
[^3]: Department for Communities (Northern Ireland), consultation response on gender pay gap reporting, published 7 October 2025, per DfC publications index at www.communities-ni.gov.uk. The response indicated broad respondent support for mandatory reporting and the Department's intention to proceed with draft Section 19 regulations; as of August 2026, draft regulations have not been laid before the Assembly.
[^4]: Equality Commission for Northern Ireland, submission to the DfC gender pay gap consultation, January 2025, and ECNI 2026 workplan, per published ECNI policy statements at www.equalityni.org.
[^5]: EU Directive 2023/970/EU of the European Parliament and of the Council on strengthening the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms, OJ L 132, 17 May 2023. Directive obligations apply to EU Member States only; transposition deadline 7 June 2026. The United Kingdom, having left the EU, is not subject to the Directive. Northern Ireland's obligations under the Windsor Framework (goods alignment) do not extend to employment law.
[^6]: Employment Rights Act 2025, Royal Assent 18 December 2025. Equality action plan provisions amend the Equality Act 2010; applicable to England, Scotland and Wales. The Equality Act 2010 does not extend to Northern Ireland.
[^7]: Citi Belfast headcount (over 4,000 across technology, operations and risk at Titanic Quarter) per Citi UK regional site disclosures and successive Citi annual reports referencing Belfast as a principal European technology hub.
[^8]: Citi 2024 UK Gender Pay Gap Report — Citigroup Global Markets Limited, snapshot date April 2024, published April 2025. Available via the gov.uk gender pay gap service at gender-pay-gap.service.gov.uk. Belfast-specific disaggregation not published within the consolidated filing.
[^9]: ENTRA Q2 2026 Northern Ireland AI Compensation Survey, 120 postings across Belfast, Derry/Londonderry, and Newry catchments, supplemented by recruiter-side confirmation from four Belfast technology recruitment practices; figures are ENTRA estimates and employers named did not confirm. GBP/USD conversions at ENTRA August 2026 canonical rate of £1 = $1.27.
[^10]: Kainos Group plc UK Gender Pay Gap filing — Kainos Software Limited — on the gov.uk gender pay gap service. Most recent filing records mean pay gap of 19.9 percent and median pay gap of 22.4 percent across the UK-consolidated workforce. Belfast headcount is included in the UK consolidation; Belfast-specific breakdowns are not published. Available at gender-pay-gap.service.gov.uk.
[^11]: Allstate Northern Ireland Limited, Companies House Northern Ireland registration NI045492. Most recent average UK employee figure (approximately 1,800) per Companies House NI filing. No UK or Northern Ireland gender pay gap report is filed by Allstate NI as a Northern Ireland-domiciled employer; parent-level human capital disclosures filed with the US SEC under Regulation S-K Item 101(c).
[^12]: Skilled Worker visa annual salary floor (£38,700) per Home Office Statement of Changes in Immigration Rules, HC 590, effective 4 April 2024; unchanged in the July 2025 Statement of Changes. Global Talent visa route: no minimum salary threshold; endorsement via the Alan Turing Institute, the Royal Academy of Engineering, or another designated endorsing body.
[^13]: Belfast Region City Deal, Heads of Terms signed December 2021, £850M committed over fifteen years per HM Treasury and Northern Ireland Executive Office published documentation. Match funding obligations on participating private-sector partners per individual investment agreements.
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