ADJUDICATION OFFICER DECISION

Adjudication Reference: ADJ-00060552

Parties:

	Complainant	Respondent
Parties	Elma De Laza	Shamrock Staffing Group Ltd

Representatives

Complaint(s):

Act	Complaint/Dispute Reference No.	Date of Receipt
Complaint seeking adjudication by the Workplace Relations Commission under section 6 of the Payment of Wages Act, 1991	CA-00073338-001	11/07/2025

Date of Adjudication Hearing: 17/02/2026

Workplace Relations Commission Adjudication Officer: Roger McGrath

Procedure:

In accordance with Section 41 of the Workplace Relations Act, 2015 following the referral of the complaint to me by the Director General, I inquired into the complaint and gave the parties an opportunity to be heard by me and to present to me any evidence relevant to the complaint.

In deference to the Supreme Court ruling, Zalewski v Ireland and the WRC [2021] IESC 24 on the 6th of April 2021 the Parties were informed in advance that the Hearing would normally be in Public, Testimony under Oath or Affirmation would be required and full cross examination of all witnesses would be provided for.

The required Affirmation / Oath was administered to all witnesses present. The legal perils of committing Perjury were explained to all parties.

The matter was heard by way of remote hearing on 17 February 2026, pursuant to the Civil Law and Criminal Law (Miscellaneous Provisions) Act 2020 and S.I. 359/2020, which designated the WRC as a body empowered to hold remote hearings. A previous hearing held on 11 December 2025 was adjourned at the outset due to lack of proper notification to the Respondent.

The correct name of the Respondent entity is Shamrock Staffing Group Limited. This was not the name entered on the complaint form by the Complainant. The Respondent was happy that the name be corrected in my decision.

Background:

The Complainant works as a locum nurse, placed by the Respondent.

Summary of Complainant’s Case:

In her complaint form, the Complainant submits that there are “always huge deductions” made on her payslip. The payslips do not indicate a breakdown of her pay, such as the number of hours she has worked, the rate of pay per hour, accommodation, and other deductions.

She has tried to bring this up with the Respondent and the consultant who looks after pay matters for the Respondent, but she has not received a satisfactory answer.

The Complainant gave evidence on oath at the hearing.

The Complainant stated that her payslip does no show the hours she worked; there is no explanation for deductions made; no agreed rate is included. The Complainant works for other agencies and they give a proper breakdown of items on the payslips she gets from them.

The Complainant is concerned about the lack of information contained on her payslips and the amount of the deductions being made from her wages.

Summary of Respondent’s Case:

An accountant who works for the consultancy that looks after pay matters for the Respondent gave evidence on Affirmation at the hearing.

The witness stated that he looks after the pay and pay slips for the Respondent. He stated that, “we have checked and doubled checked and everything is 100%” [in regard to the Complainant’s pay].

The witness stated that he had checked every payslip from February 2025 to April 2025, and all the deductions were correct. The tax and PRSI deductions are correct on the Complainant’s payslip and from her pay.

A Mr Aaron Doyle gave evidence on Affirmation at the hearing on behalf of the Respondent.

Mr Doyle stated that whilst there had been some omissions, for example, the hours worked, the agreed rate of pay and a €20 charge, on the payslips which had been issued to the Complainant previously these omissions had now been addressed or were being addressed.

Findings and Conclusions:

Section 5 of the 1991 Act states:

Regulation of certain deductions made and payments received by employers.

5.—(1) An employer shall not make a deduction from the wages of an employee (or receive any payment from an employee) unless—

(a) the deduction (or payment) is required or authorised to be made by virtue of any statute or any instrument made under statute,

(b) the deduction (or payment) is required or authorised to be made by virtue of a term of the employee's contract of employment included in the contract before, and in force at the time of, the deduction or payment, or

(c) in the case of a deduction, the employee has given his prior consent in writing to it.

From the evidence adduced I am satisfied that there were no illegal deductions made from the Complainant’s pay.

Section 4 of the Act states:

Statements of wages and deductions from wages.

4.—(1) An employer shall give or cause to be given to an employee a statement in writing specifying clearly the gross amount of the wages payable to the employee and the nature and amount of any deduction therefrom and the employer shall take such reasonable steps as are necessary to ensure that both the matter to which the statement relates and the statement are treated confidentially by the employer and his agents and by any other employees.

(2) A statement under this section shall be given to the employee concerned—

(a) if the relevant payment is made by a mode specified in section 2 (1) (f), as soon as may be thereafter,

(b) if the payment is made by a mode of payment specified in regulations under section 2 (1) (h), at such time as may be specified in the regulations,

(c) if the payment is made by any other mode of payment, at the time of the payment.

(3) Where a statement under this section contains an error or omission, the statement shall be regarded as complying with the provisions of this section if it is shown that the error or omission was made by way of a clerical mistake or was otherwise made accidentally and in good faith.

(4) An employer who contravenes subsection (1) or (2) shall be guilty of an offence and shall be liable on summary conviction to a fine not exceeding £1,000.

It was clear that it were a repeated omissions in the payslips given to the Complainant previously. I note they have been or are being addressed. It behoves an employer to ensure that the payslips issued on his/her behalf are complete and transparent, containing all the elements required by statute. In this instant case the employer failed in its responsibilities. However, an Adjudication Officer does not have jurisdiction for where “An employer who contravenes subsection (1) or (2) shall be guilty of an offence and shall be liable on summary conviction to a fine not exceeding £1,000” and therefore while I understand the upset caused to the Complainant by the lack of required information on her payslip, I do not have jurisdiction to hear this complaint.

Decision:

Section 41 of the Workplace Relations Act 2015 requires that I make a decision in relation to the complaint(s)/dispute(s) in accordance with the relevant redress provisions under Schedule 6 of that Act.

The complaint is not well founded.

Dated: 13-04-26

Workplace Relations Commission Adjudication Officer: Roger McGrath

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