Under Article 7 of Directive (EU) 2023/970, workers have the right to request and receive in writing information about their own individual pay level and the average pay levels, broken down by sex, for categories of workers performing the same work or work of equal value. Workers can make the request directly or, subject to national rules and practice, through workers' representatives or an equality body. Employers must inform workers annually about this right and the steps for using it, and must respond within a reasonable period and no later than two months after the request. The right is designed to support equal-pay enforcement, not to create a general entitlement to named colleagues' individual salary records.
Jurisdiction: European Union
Article 7 Creates a Written Right to Pay Information
Article 7 gives workers a specific information right that can be used to examine whether pay treatment is consistent with the principle of equal pay. The worker can request information about their own individual pay level and comparative information about average pay levels within the relevant category of workers. The comparative figures must be broken down by sex. The right is not framed as a discretionary HR service. It is a worker right that Member States must give effect to through national implementation. Employers therefore need a process capable of receiving requests, identifying the correct comparison group, extracting the relevant pay information and issuing a written response that can be explained if challenged.
Workers Receive Their Own Pay Level and Comparative Average Pay Data
The two parts of the right should be kept separate. First, the worker is entitled to information about their individual pay level. Second, the worker is entitled to average pay levels, broken down by sex, for categories of workers performing the same work or work of equal value. The Directive does not turn this into a general right to browse payroll records or obtain a list showing every colleague's individual salary. The comparison is structured around averages for a legally relevant category. That design is intended to provide enough evidence to identify potential unequal pay while reducing unnecessary disclosure of individual workers' personal compensation information.
The Relevant Comparison Group Is a Category of Workers
A pay-information response depends on how the employer identifies the category of workers used for comparison. Article 7 refers to workers performing the same work as the requester or work of equal value to theirs. This means the category should not be selected simply because people have the same job title, sit in the same department or report to the same manager. The underlying equal-pay framework looks at objective, gender-neutral criteria relevant to job value. Employers should therefore align Article 7 response procedures with their job architecture and work-of-equal-value methodology so that the category can be justified consistently rather than improvised for each request.
Workers Can Use Representatives or an Equality Body
Article 7 provides more than one route for exercising the information right. Workers must be able to request and receive the information through workers' representatives in accordance with national law or practice. They must also have the possibility to request and receive the information through an equality body. This matters where a worker is uncomfortable approaching the employer directly or needs assistance understanding the information. Employers should document how representative-based requests are authenticated, who is authorised to receive the response and how confidentiality is preserved. National implementation may add procedural detail, so multi-country employers should not assume the same request channel works identically in every Member State.
Employers Must Notify Workers Every Year
The right should not remain hidden in an internal legal policy. Article 7 requires employers to inform all workers annually of their right to receive the relevant information and of the steps they need to take to exercise that right. The annual notice should therefore do more than state that pay transparency exists. It should identify the request route, the team or channel that receives requests and any information the worker needs to provide. Employers should retain evidence that the notice was issued to the covered workforce, because an operational right is much easier to demonstrate when the communication process itself is documented.
The Response Must Be Provided Within Two Months at the Latest
Article 7 requires employers to provide the information within a reasonable period of time and, in any event, within two months from the date the request was made. The two-month period is an outer limit, not a target for every request. A straightforward request may reasonably be answered sooner, while a complex category-of-workers analysis may require more work. HR and compensation teams should therefore record the request date, assign an owner, track the response deadline and identify early whether clarification is needed. A central request log can help prevent requests from being delayed because they move between HR, payroll, legal and compensation teams without clear ownership.
Workers Can Ask for Clarification if the Information Is Incomplete
Article 7 also anticipates situations in which the first response does not resolve the worker's concern. If the information received is inaccurate or incomplete, the worker has the right to request additional and reasonable clarifications and details and to receive a substantiated reply. That means employers should be able to explain the basis of the category used, the meaning of the figures and any relevant methodological choices rather than sending unexplained numbers. A defensible response file should preserve the source data, calculation logic, category rationale and communications so that a later clarification can be answered consistently without rebuilding the analysis from the beginning.
Accessibility and Data Protection Apply to Pay Information
Article 8 requires information shared under Article 7 to be provided in a format accessible to persons with disabilities and taking account of their particular needs. Article 12 adds a separate data-protection layer. Where Article 7 information involves personal data, processing must comply with Regulation (EU) 2016/679. Member States may also provide that where disclosure would directly or indirectly reveal the pay of an identifiable worker, access is limited to workers' representatives, the labour inspectorate or an equality body. Employers should therefore design the response process so that the worker receives the information needed for equal-pay enforcement without unnecessarily exposing another person's individual pay.
The Information Right Is Tied to Equal-Pay Enforcement
The Directive links Article 7 information to the exercise of the right to equal pay. Employers may require workers not to use information obtained under Article 7, other than information about their own pay or pay level, for purposes unrelated to exercising that right. At the same time, workers cannot be prevented from disclosing their own pay for the purpose of enforcing equal pay. This distinction is important. The Directive supports transparency needed to test pay equality while still allowing safeguards around comparative information that may involve other workers. Policies should reflect that balance rather than using confidentiality language so broadly that it defeats the worker's statutory information right.
Frequently Asked Questions
What pay information can a worker request under Article 7?
A worker can request their individual pay level and the average pay levels, broken down by sex, for categories of workers performing the same work or work of equal value.
How long does an employer have to respond?
The employer must respond within a reasonable period and in any event no later than two months from the date of the request.
Does Article 7 give workers the individual salaries of named colleagues?
No general right to named colleagues' individual salary records is created. The comparative entitlement is to average pay levels by sex for the relevant category, subject to data-protection safeguards.
Must employers remind workers about the right?
Yes. Employers must inform all workers annually about the right and the steps required to exercise it.
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.