Employees covered as workers under the EU Pay Transparency Directive can request two core types of information under Article 7: their own individual pay level and the average pay levels, broken down by sex, for categories of workers performing the same work as them or work of equal value. They can also seek reasonable clarifications if the response is inaccurate or incomplete. The Directive does not create a general right to inspect payroll or demand the individual salaries of named colleagues. The comparative information is structured around sex-disaggregated averages for the relevant worker category, with data-protection safeguards applying where individual workers could otherwise be identified.
Jurisdiction: European Union
The Request Has Two Core Information Components
Article 7 is specific about what the worker can request. The first component is information about the worker's own individual pay level. The second is comparative information consisting of average pay levels, broken down by sex, for the relevant category of workers. Employers should avoid responding with a general statement about salary policy when the worker has asked for the Article 7 information. A compliant response needs to address both the personal and comparative elements that apply to the request and present them in writing in a way the worker can understand.
The Worker Can Request Their Individual Pay Level
The worker's own pay level is the personal part of the Article 7 right. This should be distinguished from an annual salary figure chosen for convenience if the employer's pay structure includes other elements relevant to the legal concept of pay. The Directive defines pay broadly, and employers should ensure that the information supplied is consistent with the compensation structure and the national implementation that applies. HR should therefore know which payroll and compensation records establish the worker's pay level and how those records relate to the employer's pay-setting framework.
Comparative Information Is Based on Average Pay Levels
The comparative part of the request is not a list of every employee's compensation. Article 7 uses average pay levels for the relevant category of workers. The employer must calculate or retrieve the average for the category and provide the results broken down by sex. This structure helps the worker assess whether a difference may exist between female and male workers in comparable work without automatically disclosing each person's individual salary. Employers should document the calculation method and the population included so that the average can be reproduced if the worker asks for clarification.
The Averages Must Be Broken Down by Sex
A single blended average for the entire category does not satisfy the specific comparison described in Article 7. The Directive requires the average pay levels to be broken down by sex. The purpose is to make potential gender-based differences visible within the category of comparable workers. Employers therefore need reliable workforce and pay data that can support the required breakdown. Where a category is very small, however, data-protection safeguards may become important because a figure could reveal or make it possible to infer an identifiable worker's pay. Article 12 allows Member States to address that risk through restricted-access arrangements.
The Comparison Must Use the Same Work or Work-of-Equal-Value Category
The worker is not entitled merely to an organisation-wide average that may have little relevance to their role. Article 7 links the comparative information to categories of workers performing the same work as the requester or work of equal value. This makes the category selection central to the response. The employer should use objective, gender-neutral criteria consistent with the equal-pay framework rather than choosing a narrow or broad category simply because it produces a convenient result. Job evaluation, classification and worker-category governance therefore directly affect the quality of Article 7 responses.
Workers Can Request Clarifications and Details
If the information received is inaccurate or incomplete, Article 7 gives workers the right to request additional and reasonable clarifications and details and to receive a substantiated reply. This means the initial response should not be treated as the end of the process if it leaves a legitimate gap. A worker may need to understand how the category was selected, what period the figures cover or how a pay element was treated. Employers should prepare for these questions by keeping a response file that records the category definition, underlying data, calculation method and any exclusions.
Workers Do Not Receive a General Right to Inspect Payroll
Article 7 should not be expanded into a right that the Directive does not state. It does not give every worker unrestricted access to payroll systems, compensation files or the individual pay records of named colleagues. The legal entitlement is structured and limited: own pay information plus sex-disaggregated average pay levels for the relevant comparable category. This distinction protects both the usefulness of the transparency right and the privacy of other workers. Employers should avoid using privacy as a reason to withhold all comparative information, but they also should not disclose identifiable personal pay where the Directive and data-protection framework call for safeguards.
A Good Response Explains the Data Rather Than Sending Numbers Alone
Although Article 7 specifies the information to be provided, a practical response should also make the figures intelligible. The employer should identify the worker's pay level, the relevant worker category, the female and male average pay levels for that category and the period or methodology needed to interpret the result. If national law requires a particular form or channel, that should be followed. Clear presentation reduces avoidable follow-up disputes and helps demonstrate that the employer has treated the request as an equal-pay information process rather than a one-off data extraction exercise.
Frequently Asked Questions
Can employees request their own pay information?
Yes. Article 7 expressly gives workers the right to request and receive information about their individual pay level.
Can employees request average pay for comparable workers?
Yes. They can request average pay levels broken down by sex for categories of workers performing the same work or work of equal value.
Can employees demand every colleague's individual salary?
Article 7 does not create a general entitlement to named colleagues' individual salary records. The comparative right is based on average pay levels, with data-protection safeguards applying.
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.