How to answer an employee pay information request
Under Article 7 of Directive (EU) 2023/970, a worker can ask for their own pay level and the average pay levels, by sex, for workers doing the same work or work of equal value. You answer in writing, within a reasonable period and at most two months [1][2][3]. This guide gives you the steps, a worked example and a reply you can copy.
What the worker can ask for
- Their individual pay level.
- The average pay levels, broken down by sex, for the category of workers doing the same work or work of equal value [2][4].
The request can come from the worker directly, or through their workers' representatives or the national equality body [4]. The right applies regardless of company size. The reporting thresholds of Article 9 do not limit it. Countries had to put the directive into national law by 7 June 2026 [5], so check how your country words the right and the deadline.
Step by step
- Log the request. Note the date you received it. Your deadline runs from there. Two months is the outer limit [2][3]; your national law may set a shorter one.
- Confirm who is asking and through whom. If a representative or the equality body asks on the worker's behalf, reply through the same route unless the worker asks otherwise.
- Identify the category. Use the same categories of workers as in your pay structure and your pay gap report. The category must be based on objective, gender-neutral criteria [6]. Write down which category you used and why.
- Pull the data. Take the pay for everyone in that category over the same period. Use the same pay elements for everyone: base pay, and variable pay if you include it. Use hourly or full-time-equivalent figures so part-time work does not distort the averages.
- Calculate the averages. Average pay for women and for men in the category, plus the worker's own pay on the same basis.
- Check for small groups. If a group has only one or two people, an average can reveal a colleague's pay. Check how your national law handles this before you send it.
- Write and send the answer. In writing, with the method explained in one or two lines.
- Look at the result yourself. If the answer shows a gap, the worker will see it too. Find out now whether an objective reason explains it, or whether you need to correct pay.
Worked example
On 3 March, Sanne, a worker in "Customer support, level 2", sends HR an email asking for her pay level and the average pay by sex in her category. HR logs the date. The latest answer date is 3 May.
The category has six full-time workers. Annual base pay:
| Group | Workers | Average annual base pay |
|---|---|---|
| Women | 3 | EUR 43,000 |
| Men | 3 | EUR 46,000 |
| Sanne | 1 | EUR 42,000 |
No one in the category gets variable pay, so the answer covers base pay only and says so. The averages show women earning less on average than men in this category. Before sending, HR checks the pay policy: men in the category have on average more years in the role, and the policy pays a step per year for everyone. HR notes this for the file. The answer itself only gives the figures that were asked for.
Copyable reply
Subject: Your request for pay information Dear [name], On [date received] you asked for information about your pay and the average pay in your category of workers. Here it is. Your category: [category name] This category groups work of equal value, based on [criteria, e.g. skills, effort, responsibility, working conditions]. Reference period: [period] Pay included: [annual base pay / hourly pay; variable pay yes or no] Figures are [full-time equivalent / hourly]. Your pay level: EUR [amount] Average pay, women: EUR [amount] Average pay, men: EUR [amount] If you have questions about these figures or how they were calculated, you can contact [name, role]. Kind regards, [name] [role] Date sent: [date, no later than two months after the request]
Mistakes to avoid
- Missing the deadline. Put the two-month date in a calendar the day the request comes in.
- Choosing the category to fit the answer. Use the category you would use for anyone in that role. A category built after the fact is hard to defend.
- Mixing bases. Do not compare one person's annual pay with an hourly average. Use the same unit throughout.
- Treating the request as a complaint. Asking is a right. Answer it like any other routine HR request, and do not let it affect how the worker is treated.
- Sending only text. A short table is clearer than a paragraph of numbers.
Prepare before the first request arrives
The work behind one answer is the same as the work behind a pay gap report: clear categories, clean pay data per worker, and a consistent method. If you set this up once, each answer takes minutes. Larger employers also need the same categories for the per-category gap in their Article 9 report [1][6].
Related guides
- Gender pay gap report template
- Salary ranges in job ads under the EU Pay Transparency Directive
- Spreadsheet, tool or consultant: which way to prepare
Sources
- Directive (EU) 2023/970, Articles 7 and 9 (EUR-Lex)
- Legalink, Summary of the EU Equal Pay and Pay Transparency Directive (Article 7)
- Innovires, Right to pay information under the EU Directive (two-month deadline)
- GGI, Strengthening gender pay equality: the 2023/970 Directive (Article 7 request routes)
- Clifford Chance, Pay transparency directive (transposition date 7 June 2026)
- Orbiq, Pay transparency gap analysis template (Article 4 criteria, Article 9 categories)
This guide explains the rules in plain language. It is not legal advice. Check your own country's law and, when in doubt, ask a qualified adviser.