Information right
The Article 7 information right: process, deadlines, practice
Under Article 7 of the EU Pay Transparency Directive, every worker can request information in writing about their individual pay level and the average pay levels, broken down by gender, for equal work or work of equal value. The employer must respond within two months – regardless of company size.
Who can ask and what must be answered
The information right applies to all workers, including part-time and fixed-term staff. Requests can be made directly or through worker representatives or an equality body. The employer must provide the worker’s own pay level and the average pay levels – broken down by gender – for the category of workers performing equal work or work of equal value.
Employers must also actively inform their workers annually about this right. Contract clauses preventing workers from discussing their pay are not permissible for equal-pay purposes.
The two-month deadline in the process
The response is due within two months of the request. If the information is incorrect or incomplete, workers can request additional reasonable clarifications and details. For employers this means: deadline tracking from receipt, defined responsibilities, a reproducible calculation of the comparison figures and documented delivery.
Without prepared worker categories, the deadline is hard to meet: the comparison group of equal or equivalent work must already be defined when the request arrives – building it ad hoc is methodologically vulnerable and unrealistic in the time available.
Data protection in the response
Averages must not allow conclusions about individual persons. Small comparison groups require safeguards, such as suppressing values below a minimum group size. Processing pay data is subject to the GDPR and the purpose limitation of Article 12 of the Directive: the data may only be used for equal-pay purposes.
What a defensible information-request workflow looks like
An audit-ready process includes at least these steps:
- Record receipt and calculate the deadline automatically (request date + two months).
- Determine and document the requesting worker’s comparison category.
- Calculate metrics from current pay records, suppressing small groups.
- Run a privacy and subject-matter review before sending, using the four-eyes principle.
- Deliver the answer in writing and archive it as a snapshot with the calculation state.
Frequently asked questions
How quickly must the employer respond to an information request?
Within two months of receiving the request. If the information is incorrect or incomplete, workers can request additional clarification.
Does the information right also apply in small companies?
Yes. Unlike the reporting duties, the information right has no threshold – it applies to employers of any size.
May the employer disclose the pay of individual colleagues?
No. The response contains averages by gender for the comparison category. Conclusions about individuals must be prevented through minimum group sizes and aggregation.