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25 September 2026 · 8 min read

Pay information request: employer reply template

An employee asks for average pay by gender for their role? What to disclose, the deadline, and a free reply template for small employers.

When an employee asks what colleagues in comparable roles earn, the EU Pay Transparency Directive gives you a clear job: send them their own pay level and the average pay levels, split by sex, for the category of workers doing the same work or work of equal value, within two months at the latest. This guide explains what to include, how to calculate it, and gives you a complete reply template you can adapt.

What the employee may ask for

Article 7 of Directive (EU) 2023/970 gives every worker the right to request, and receive in writing, two pieces of information:

  • Their individual pay level, for example their gross annual salary.
  • The average pay levels, broken down by sex, for the categories of workers doing the same work as them or work of equal value.

The right applies regardless of company size. A team of eight has the same duty as a company of 800. Workers may also make the request through their workers' representatives or an equality body, so do not be surprised if the question arrives from someone other than the employee.

The deadline: two months at the latest

You must answer within a reasonable period, and at the latest within two months from the date of the request. Two months is the outer limit, not a target. In a small company the numbers are usually easy to produce, so answering within two or three weeks is realistic and signals that you take the question seriously.

If the information you give is inaccurate or incomplete, the worker may ask for clarification and further details, and they are entitled to a reasoned reply. Keep that in mind when you write the first answer: clear numbers and a short explanation save a second round.

Two related duties

  • Annual information. Employers must inform all workers every year about their right to request this information and the steps to follow. A short paragraph in the staff handbook plus a yearly email or intranet message works well.
  • No pay secrecy. Contract clauses that stop workers from disclosing their own pay are not allowed. Workers may share their pay, for example to check for unequal pay. Review your employment contract templates for confidentiality wording that covers salary.

Step 1: define the comparison category

The average is only meaningful if the category is right. It covers workers doing the same work or work of equal value. Work of equal value is assessed with objective, gender-neutral criteria: skills, effort, responsibility and working conditions. Two roles with different job titles can still be work of equal value, for example a warehouse team lead and a customer service team lead who score similarly on those four criteria.

If you have already scored your roles and grouped them into grades, the grade is usually the natural comparison category. If you have not, this request is a good reason to start. The ValuGrade wizard scores each role on the four criteria and groups roles into grades in a few minutes.

Step 2: calculate the averages

Use the same pay definition for everyone, and state it in your reply. A common choice is gross annual base salary for a full-time equivalent. Practical points:

  • Convert part-time salaries to full-time equivalents, otherwise the averages mix hours with pay.
  • Decide whether bonuses, allowances and benefits in kind are included, and apply the choice consistently. The directive's concept of pay includes more than base salary, so mention what you included.
  • Calculate the average for women and the average for men in the category separately. Use a clear reference date, for example pay on 1 September 2026.

Example: in grade 3 there are three women earning €41,000, €44,000 and €46,000 and two men earning €43,000 and €47,500. The average for women is €43,667 and the average for men is €45,250.

Step 3: very small categories

In a small company a category may contain only one or two people. Then an "average" can reveal a single colleague's salary, which is personal data. Handle this carefully:

  • Check whether a wider category is still legitimate, for example combining roles that score as work of equal value on the four criteria.
  • If a figure would identify one person, explain honestly why you cannot give it in that form, and what you can give instead.
  • National law may add specific rules for small categories or for how the data is shared. Check the status for your country on our country status page before you reply.

Never skip the request just because the category is small. Respond, explain, and give as much as you properly can.

Step 4: keep a record

Keep the request, the date you received it, your calculation (category, pay definition, reference date) and your reply. If the worker asks for clarification or the answer is questioned later, you can show how you reached the numbers.

Reply template

Adapt the placeholders in square brackets. Send it in writing, by email or letter.

Subject: Your request for pay information
Dear [name],
Thank you for your request of [date of request] for information about pay. As set out in the EU Pay Transparency Directive, you are entitled to this information, and we are happy to provide it.
Your individual pay level: your gross annual base salary on [reference date] is [amount] (full-time equivalent: [amount]).
Your comparison category: [category], which covers the roles [roles in the category]. These roles are grouped as the same work or work of equal value based on four criteria: skills, effort, responsibility and working conditions.
Average pay levels in this category on [reference date], gross per year, full-time equivalent: women [amount]; men [amount].
What we included: [base salary only / base salary plus fixed allowances and bonuses]. Part-time salaries have been converted to full-time equivalents.
[If the category is very small: Because this category contains only [number] people, publishing an average for one group would reveal an individual colleague's pay. We have therefore [explain what you did, for example combined categories of equal value or given the overall average].]
Our pay criteria are described in [document or location], which is available to all employees. If anything in this reply is unclear, or you would like more detail, please let me know and I will get back to you.
Kind regards,
[your name], [job title], [company]

Ireland and other countries

The directive sets the baseline, but national law decides the details. In Ireland, for example, the directive had not yet been transposed at the time of writing, while other member states have adopted or are drafting their laws. See the Ireland page and check the official source before relying on a specific procedure.

Prepare once, answer in minutes

The easiest way to answer quickly is to have a pay structure in place before the first request arrives. The paid ValuGrade report includes this reply template prepared for every role, together with grades, salary bands and a written pay-criteria policy. For job ads, the free salary range generator writes the pay sentence for you.

This article provides structure and templates, not legal advice.

Frequently asked questions

Does this right apply to small companies?
Yes. Under the directive, the right to pay information applies regardless of company size. Only the gender pay gap reporting duty depends on headcount.
How long do I have to reply?
Within a reasonable period, and at the latest within two months of the request. In a small company, a reply within a few weeks is usually realistic.
Do I have to name colleagues or give their individual salaries?
No. You give the worker their own pay level and averages by sex for the comparison category, not individual salaries of colleagues. Take care that a very small category does not reveal one person's pay.
Can a worker's representative make the request?
Yes. Workers may request the information through their workers' representatives or through an equality body.
Can I forbid employees from telling each other what they earn?
No. Clauses that stop workers from disclosing their own pay are not allowed under the directive.

This article provides structure and general information, not legal advice.

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