Is it legal to record a meeting in Ireland?

The Interception of Postal Packets and Telecommunications Messages (Regulation) Act 1993 is an authorisation framework for state interception, not a general recording offence. Its s.2(1) provides that "The Minister may give an authorisation, but only for the purpose of criminal investigation or in the interests of the security of the State."

The offence itself sits in s.98 of the Postal and Telecommunications Services Act 1983, as amended, which reaches a person who intercepts telecommunications messages "being transmitted by the company". The substituted s.98(6) is the operative definition: "'intercept' means listen to, or record by any means, in the course of its transmission, a telecommunications message but does not include such listening or recording where either the person on whose behalf the message is transmitted or the person intended to receive the message has consented".

Nothing else fills the gap. The Criminal Justice (Surveillance) Act 2009 applies by its own s.2(1) to surveillance carried out by members of the Garda Síochána, the Defence Forces and Revenue officers, and s.2(2) says nothing in it renders unlawful any activity that would otherwise be lawful. It does not bind private persons. No Irish statutory offence of covert recording by a private participant was found, and that is a negative from three statutes read closely rather than a sweep of the statute book.

On citation: the Law Reform Commission's revised 1993 Act carries the s.98(6) definition in the words above as of April 2025, but the 1983 Act itself is not in the LRC's revised set, so no consolidated s.98 exists to cite. Irish practice cites the 1983 enacted text plus the revised 1993 amending section.

Yes, for two independent textual reasons. A participant is "the person intended to receive the message" and consents, which is the express carve-out in s.98(6) and in the 1993 Act's own definition. And a participant capturing sound at the endpoint is not recording anything "in the course of its transmission" at all.

Nothing, by criminal law. The obligation is a data protection one, and the Data Protection Commission frames it as processing rather than as an announcement: "As a starting point, any person or organisation using recording equipment should remember that simply recording and/or storing video and audio data could be considered 'processing', even if no further use is made of that data."

Once the household exemption is out of reach, the recorder is a controller and GDPR Arts. 13 and 14 apply. Ireland enacted no national specification of that duty for recording.

Quick note before we start: I'm recording this so I can write my notes up afterwards. It transcribes on my laptop, nothing goes to the cloud, and I only keep the text. Say so now if you'd rather I didn't.

On whether implied consent from continuing to speak suffices, or a calendar-invite line, no authority was found.

GDPR applies as well, and the analysis is the ordinary European one: a meeting recording is personal data about every identifiable speaker, a transcript without speaker labels is still personal data, the household exemption is read narrowly and a work meeting has a direct connection to a professional activity, you need a lawful basis, and Art. 13 wants the information at the time the data are obtained, which for an always-on recorder means before the substance of the meeting. The European framework covers all of that once rather than on every country page.

No automatic works council, and this is the structural difference from Austria, Belgium and Luxembourg. The Employees (Provision of Information and Consultation) Act 2006 applies by s.4(1)(c) to undertakings with at least 50 employees, and s.7(1) makes the machinery employer-initiated or triggered by the written request of at least 10 per cent of employees, capped by s.7(2) at the lesser of 10 per cent (minimum 15) or 100 employees. So below 50 employees there is no body at all, and above it there is one only if someone asks for it. An Irish rollout has no equivalent of the Austrian veto.

No employee-monitoring provision in the Data Protection Act 2018. Ireland did not use the GDPR Art. 88 opening clause for monitoring; the only employment provision is s.46, on special categories processed for rights or obligations under employment or social welfare law.

One thing not to reach for: s.43, the freedom-of-expression and journalism exemption, switches off large parts of the GDPR for journalistic, academic, artistic or literary purposes. It is purpose-gated and does not reach an ordinary professional's meeting notes.

The Data Protection Commission's video-recording guidance is the page that speaks to audio at all: EU data protection legislation "may apply to people or organisations … who record ('process') video and/or audio information about identifiable persons", and it puts the household exemption squarely in issue: "If the recording does not fall within this category, then it is possible that the person making the recording has a number of obligations as a 'data controller'."

On the workplace, the DPC's CCTV guidance says "staff monitoring in the workplace is highly intrusive and would need to be justified by reference to special circumstances". Worth knowing that this document contains no occurrence of the word audio at all: it is video-only, and quoting it for an audio claim is a stretch that should be flagged as one.

No DPC guidance specific to covert audio recording of conversations was found.

Because the binding layer in Ireland is data protection rather than criminal law, this is where the product's architecture does real work. Transcription runs on your own device, the audio is never written to disk, and nothing is sent anywhere. There is no cloud component, so on our reading we are not a processor under Art. 4(8), which processes personal data on behalf of a controller and presupposes receiving it. That means no Art. 28 data processing agreement to sign with us, no sub-processor list, no international transfer and no transfer impact assessment, because there is no transfer. We found no decision squarely holding that an on-device-only vendor is not a processor, so that is reasoning you can check rather than a settled point.

What it does not do is disclose anything. There is no bot in the participant list and no banner on anyone else's screen, so the transparency obligation rests entirely on you saying something. Earkeep does not make anyone compliant and could not: a tool cannot be compliant, only a processing operation can be lawful.

Where it helps in the room is that stopping is real and checkable. A pause from the live edge releases the microphone and the system audio stream, so your operating system's own recording indicator goes dark in front of the person who asked. A meeting on a connected calendar can be marked never-record. And a stretch of the day, or a saved meeting with its transcript, can be purged from the file on your own disk, with no server copy anywhere to reconcile against.

• Interception of Postal Packets and Telecommunications Messages (Regulation) Act 1993
• 1993 Act, Law Reform Commission revised text
• Postal and Telecommunications Services Act 1983, s.98
• Employees (Provision of Information and Consultation) Act 2006
• DPC, video recording guidance
• GDPR, EUR-Lex

• European recording laws: the four layers, the controller question, and all 32 countries.
• Telling people you're recording: the scripts, and the three ways to stop.
• Private by design: why the audio never leaves your computer.

This page is legal information, not legal advice. It summarises provisions and guidance rather than replacing them, and we are not lawyers. If the answer matters, ask someone who can be held to their answer.