How to answer a pay information request
Under Article 7 of the EU Pay Transparency Directive, every worker may ask for their individual pay level and for the average pay levels, broken down by sex, for categories of workers doing the same work or work of equal value. The request can come from the worker directly or through workers' representatives or an equality body. You reply within a reasonable period, and at the latest within two months of the request.
The key step is defining the comparison category. Group roles that are the same work or work of equal value, based on the four gender-neutral criteria: skills, effort, responsibility and working conditions. Then calculate the average pay for women and for men in that category, on the same basis for everyone: the same reference date, the same pay elements and part-time salaries converted to full-time. The mini calculator in this tool fills in the averages from a list of salaries.
Small categories need care. If disclosure would reveal the pay of an identifiable co-worker, national law may provide that only workers' representatives, the labour inspectorate or the equality body receive that information. Check national law and explain transparently in the reply how the information is being provided.
Keep a record of the request, the date you replied and how you calculated the figures. Remember that workers must be informed of this right every year, and that clauses stopping workers from disclosing their own pay are not allowed. The paid ValuGrade report includes this reply template for every role in your pay structure.
Frequently asked questions
- How long do I have to reply?
- Within a reasonable period and at the latest within two months of the request, under the directive. National law may set more detail.
- Do I have to give the salaries of individual colleagues?
- No. You give the employee's own pay level and average pay levels by sex for their category, not individual salaries.
- What if the category has only one or two people?
- Be careful with personal data. Check what national law provides, as it may route the information through workers' representatives, the labour inspectorate or the equality body. Explain transparently in the reply how the information is being provided.
- Is the letter stored anywhere?
- No. The letter is generated in your browser. Nothing is stored or sent anywhere.