Employers must inform all workers every year about their right to receive the pay information described in Article 7 and about the steps they need to take to exercise that right. The annual notification should therefore do more than mention the Directive in a policy. It should tell workers that the right exists and explain the practical request route, such as the HR channel, form or representative-based process used under national law. Employers should issue the notice on a repeatable annual cycle and retain evidence that it was provided to the covered workforce.
Jurisdiction: European Union
Article 7 Requires Employers to Inform All Workers Every Year
Article 7(3) states that employers must inform all workers, on an annual basis, of their right to receive the information described in Article 7(1) and of the steps the worker must take to exercise that right. This is a recurring duty rather than a one-off implementation communication. The employer should therefore build the notice into an annual compliance calendar. The audience is all workers covered by the obligation, not only employees who have previously raised a pay concern or used the information-right process.
The Notice Must Explain Both the Right and the Steps to Use It
A notice that merely says workers have pay-transparency rights would not reflect the full wording of Article 7(3). The Directive also requires employers to explain the steps the worker should take to exercise the right. The communication should therefore identify the practical request route used by the employer, such as an HR contact point, portal, form or another process established under national law. Workers should be able to understand where to send a request and what information they need to provide without having to find a legal specialist first.
The Annual Notice Should Connect to a Working Request Process
The notification duty is useful only if the process behind it works. If the notice directs workers to a mailbox that is not monitored, an intranet page that is out of date or a manager who has no guidance, the organisation has created operational risk. HR should test the request route before the annual notice is sent, confirm who owns incoming requests, and verify that compensation and payroll teams can produce the information required by Article 7. The notice should describe the current process rather than an aspirational process that has not been implemented.
Employers Can Choose a Delivery Method Subject to National Rules
The Directive establishes the annual information duty but does not prescribe one universal communication channel for every employer. Organisations may use email, an HR portal, an employee app, written notices or another method that reliably reaches workers, subject to national implementation requirements. Large or multinational employers may use several channels to improve reach. What matters is that the communication is actually provided to the relevant workforce, is understandable and gives workers the practical steps for using their right. Local law may require additional language, delivery or evidence controls.
Accessibility Should Be Built Into the Communication
Article 8 requires information shared with workers or applicants under Articles 5, 6 and 7 to be provided in a format accessible to persons with disabilities and taking account of their particular needs. Employers should therefore consider accessibility when designing the annual notice and the request instructions. A notice that is technically distributed to everyone but cannot be meaningfully accessed by part of the workforce may undermine the effectiveness of the right. Accessibility should be treated as part of the communication workflow rather than as a separate afterthought.
Keep Evidence That the Annual Notice Was Issued
The Directive does not require one specific evidence file, but employers should be able to demonstrate how the annual duty was carried out. Useful records can include the final notice text, issue date, delivery channel, covered population and any local variants used for different Member States. If the communication is delivered through an HR platform, system logs or distribution records can support the compliance file. Evidence should be proportionate and should not create unnecessary personal data. The purpose is to show that the organisation had a repeatable annual process and that workers were told how to exercise the right.
National Implementation May Add More Detailed Requirements
Article 7(3) creates the EU-level baseline, while Member States implement the Directive through national law. National rules may specify language, representatives, competent authorities, notice channels or additional worker protections. Multi-country employers should therefore use a common annual-notice framework with local adaptations rather than assuming that the same communication is sufficient everywhere. The central policy should preserve the Directive's minimum requirement to notify all workers every year and explain the steps for exercising the right, while local instructions address country-specific requirements.
Frequently Asked Questions
How often must employers remind workers about pay-information rights?
Article 7 requires employers to inform all workers on an annual basis.
What must the annual notice explain?
It must inform workers of their right to receive the Article 7 information and the steps they need to take to exercise that right.
Does the Directive require the notice to be sent by email?
The Directive does not prescribe one universal delivery channel. Employers should use a reliable and accessible method and check national implementation requirements.
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.