Employers must provide the pay information required by Article 7 within a reasonable period of time and, in every case, no later than two months from the date the worker makes the request. The two-month period is an outer limit, not a standard delay that employers should automatically use. Straightforward requests may need to be answered sooner, while more complex requests can require time to identify the correct category of workers, verify the source data and prepare the written response. Employers should therefore log the request date immediately, assign ownership and track the deadline from the day the request is made.
Jurisdiction: European Union
Article 7 Sets a Reasonable Period and a Two-Month Outer Limit
Article 7(4) of Directive (EU) 2023/970 requires employers to provide the information referred to in Article 7(1) within a reasonable period of time and, in any event, within two months from the date on which the request is made. Both parts of the rule matter. The response should be reasonably prompt for the circumstances, while two months operates as the maximum EU-level period. An employer should therefore avoid treating two months as an automatic service standard. Where the relevant category and pay data are already structured, the reasonable response period may be much shorter.
The Clock Runs From the Date the Request Is Made
The Directive measures the outer limit from the date on which the request is made. That makes intake control important. Employers should record the request date, the worker, the channel used and the information requested as soon as the request enters the organisation. A request should not lose days because it first reaches a line manager, shared HR mailbox or worker representative before being transferred to compensation or legal. Internal routing may be necessary, but it should not obscure the original date. A central register can provide a reliable deadline calculation and evidence of when the request was received and answered.
Simple Requests and Complex Requests May Take Different Amounts of Time
The reasonable-period standard recognises that Article 7 requests can vary in complexity. A worker's own individual pay level may be straightforward to confirm, while the comparative part of the response can require analysis of the correct category of workers performing the same work or work of equal value. The employer may need to validate job architecture, identify the relevant population, calculate average pay levels broken down by sex and review whether data-protection safeguards affect how the information can be presented. Complexity can justify careful work, but it does not remove the two-month outer limit.
Employers Need Clear Ownership for the Response
A pay-information request can touch several teams at once. HR may receive the request, compensation may identify the comparison category, payroll may supply pay data, legal may review the national implementation and privacy safeguards, and worker-relations teams may coordinate with representatives. Without a named owner, requests can stall between functions. Employers should define one accountable role for each request and establish a workflow showing which teams provide inputs and by when. The legal deadline applies to the employer, not to separate internal departments, so internal handoffs should be designed around the final response date.
Accuracy Still Matters Even When the Deadline Is Approaching
The response deadline does not justify sending figures that have not been checked. Article 7 gives workers the right to written information about their individual pay level and the relevant average pay levels broken down by sex. If those figures are inaccurate or incomplete, workers can request additional and reasonable clarifications and details and receive a substantiated reply. Employers should therefore build review time into the process rather than waiting until the end of the two-month period. Source data, worker-category logic and calculations should be capable of being reproduced if the worker asks follow-up questions.
A Request Log Helps Demonstrate Timely Compliance
A defensible request log should record the date received, the requesting worker, the request channel, the relevant category under review, assigned owner, internal milestones, response date and any later clarification request. This does not mean creating unnecessary personal data. The goal is to preserve enough evidence to show that the employer operated the Article 7 process consistently and within time. Where requests are received through workers' representatives or an equality body, the log should also reflect the authorised route used and any national procedural requirements that affect the response process.
National Implementation Can Add Procedural Detail
Directive (EU) 2023/970 sets the EU minimum timing framework, but Member States transpose the Directive into national law. National rules may define the request channel, specify formal requirements, identify competent bodies or create more favourable worker protections. Multi-country employers should therefore avoid assuming that one central procedure is sufficient in every jurisdiction. A group-wide control can preserve the two-month outer limit while local instructions address country-specific details. Where national law sets a shorter or more protective rule, the local requirement should govern the operational process in that jurisdiction.
Frequently Asked Questions
Does an employer always have two full months to answer?
No. Article 7 requires a response within a reasonable period and in any event within two months. Two months is the outer limit, not an automatic waiting period.
When does the two-month period start?
The Directive measures the period from the date on which the request is made. Employers should therefore record the original request date immediately.
Can a worker ask for clarification after receiving the response?
Yes. If the information is inaccurate or incomplete, Article 7 allows the worker to request additional reasonable clarifications and details and receive a substantiated reply.
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.