Article 8 of Directive (EU) 2023/970 requires employers to provide information shared with workers or job applicants under Articles 5, 6 and 7 in a format that is accessible to persons with disabilities and that takes their particular needs into account. This applies to recruitment-stage pay information, pay-setting and pay-progression criteria, and responses to worker pay-information requests. Accessibility therefore needs to be part of the employer's pay-transparency process itself, not an optional extra added only after a worker reports difficulty using the information.
Jurisdiction: European Union
Article 8 Applies to More Than Employee Pay Requests
Article 8 is broader than a single HR-response process. It applies to information shared with workers or applicants under Articles 5, 6 and 7. That means accessibility matters when an employer provides initial pay or pay-range information to applicants, when workers are given access to the criteria used to determine pay and pay progression, and when an employer responds to a worker's request for individual and comparative pay information. Employers should therefore map accessibility across the full pay-transparency lifecycle instead of treating it as a one-off accommodation for Article 7 requests.
The Directive Requires an Accessible Format
Article 8 does not prescribe one universal document type, software product or technical standard. It states the legal outcome: the information must be provided in a format accessible to persons with disabilities. The suitable format can depend on how the information is delivered and on the recipient's needs. An accessible digital document may be appropriate in one situation, while another worker may require a different presentation or communication method. Employers should therefore avoid assuming that sending the same PDF or portal link to every person automatically satisfies the accessibility requirement.
Particular Needs Must Be Taken Into Account
The second part of Article 8 is important because accessibility is not framed only as a generic technical requirement. Employers must take the particular needs of persons with disabilities into account. In practice, this means the communication process should be capable of adapting when a worker or applicant needs a different format or method to understand the information. HR and recruitment teams should know how to receive accessibility requests, where to escalate them and how to provide the required pay information without unnecessary delay or loss of substance.
Accessibility Should Be Designed Into the Pay-Information Workflow
A reactive approach can create avoidable delays. If salary-range notices, pay-setting criteria and Article 7 response templates are created only in formats that are difficult to adapt, HR may struggle to meet the Directive's substantive deadlines while also producing an accessible version. A better approach is to choose document templates, portals and communication channels with accessibility in mind from the beginning. The team responsible for the information should know which alternative formats are available and how to preserve the accuracy of tables, figures, headings and explanatory notes when the information is converted.
Accessibility Does Not Reduce the Substance of the Information
Providing an accessible format should not mean simplifying away legally relevant detail. A worker exercising Article 7 rights still needs the information required by that provision, including their individual pay level and the relevant sex-disaggregated average pay levels. An accessible version should communicate the same substantive information in a form the recipient can use. Employers should also ensure that explanations, category definitions and clarification responses remain understandable. Accessibility is about effective access to the information, not replacing a complete response with a shorter or less precise summary.
Employers Should Keep Evidence of the Accessibility Process
Article 8 does not create a detailed recordkeeping checklist, but employers benefit from documenting how accessibility is handled. Useful evidence can include the standard formats used, available alternatives, the date a particular need was raised, what format was provided and when the information was delivered. This is especially important where an Article 7 response also has a timing requirement. A clear record helps the employer show that accessibility and timeliness were managed together rather than one obligation being used as a reason to delay the other.
National Accessibility Rules May Go Further
Directive (EU) 2023/970 sets the pay-transparency accessibility baseline, but it does not replace national disability, accessibility or employment law. Member States may already impose broader requirements concerning reasonable accommodation, digital accessibility, workplace communication or discrimination. Employers should therefore treat Article 8 as one layer of the compliance framework. Multi-country organisations should identify the EU minimum centrally and then document any additional country-specific duties that affect how pay information must be prepared or delivered.
Frequently Asked Questions
Which pay information must be accessible?
Article 8 applies to information shared under Articles 5, 6 and 7, including applicant pay information, pay-setting and progression criteria, and worker pay-information responses.
Does Article 8 require one specific file format?
No. The Directive requires an accessible format and requires employers to take the person's particular needs into account, but it does not prescribe one universal technical format.
Can an employer provide a shorter version as an accessibility measure?
Accessibility should preserve the substance of the information the worker or applicant is entitled to receive. A different format should not remove legally relevant content.
Related Guides
Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.