Right to information — Article 7 in the day-to-day HR workflow

An employee sends an email to HR: please tell me what people in my category earn, broken down by sex. The two-month clock starts.

For most HR teams, the first such email lands as a fire-drill: who is in "my category", what does "broken down by sex" actually mean, where does the calculation methodology come from. The first request consumes weeks. The tenth one should consume hours. The difference between the two is whether the workflow exists before the request arrives.

This guide is the workflow. Six steps from intake to closing the loop, with the documentation that lives behind each. Directive 2023/970 sets the floor; national transposition may extend it.

What Article 7 actually requires

Three elements of the requirement:

• Who can request. Any employee. The request can be made directly or through worker representatives. The right cannot be contractually waived; pay secrecy clauses are unenforceable (Article 7, paragraph 6).
• What gets disclosed. The requesting employee's individual pay level, plus the average pay levels broken down by sex for the category of workers performing equal work or work of equal value.
• By when. Within a reasonable period not exceeding two months from the request. National transposition may specify shorter periods.

Additionally, the employer informs all workers annually of their right to request this information. The annual notice is the second piece of the Article 7 obligation that often gets overlooked.

The six-step workflow

The annual notice

Article 7, paragraph 4, requires the employer to inform all workers annually about their right to request. This is a single piece of communication — once per year — that needs to:

• State the right exists
• Explain how to exercise it (the intake channel)
• Confirm the 2-month response period
• Be delivered in writing, accessible to all workers

Most companies handle this through the employee handbook or an annual all-hands communication. The discipline is the annual frequency — not the comprehensiveness of any single notice.

What needs to exist before the first request arrives

Three artefacts that turn the workflow from improvised into routine:

1. The category map. Every role mapped to a category of equal work or work of equal value, with the Article 4 criteria documented. Lookup time per request: minutes.

2. The comparator-calculation method. A documented method for calculating per-category mean and median pay by sex. Same method applied every request; reproducibility ensured.

3. The response template. A standard document that takes the calculation output and produces the disclosure. Pre-approved by legal review where applicable. Each response is a fill-in rather than a draft-from-scratch.

These three artefacts mean a request that arrives Monday gets a response Friday rather than two months from now. Two-month responses are technically compliant but operationally indicate the absence of the artefacts above.

Reading the request patterns

Requests rarely come in isolation. Three patterns observed in the first wave of countries where Article 7 has been transposed:

• Clustering by category. Three requests in the same week from the same category usually precede a wider conversation in that team. Worth surfacing to the business leader of that function.
• Clustering by tenure cohort. Recent hires asking comparator questions often reflects a transparency expectation gap — the offer process gave them a number, but not a context, and they're seeking the context post-hire.
• Clustering by gender. If requests come predominantly from one gender within the same category, the underlying pay question is more focused than the request volume suggests.

Article 7 is the easiest of the directive's obligations to handle routinely — once the upstream documentation exists. Without it, every request is a project.

Workflow software handles the intake. It does not handle the category map, the comparator calculation, or the documented methodology. Those are upstream of the workflow — and that is where the directive lives.

Where the diagnostic starts

The Article 7 workflow rests on the category map and the comparator-calculation methodology. The ReadinessCheck™ surfaces whether those upstream artefacts are in place — by axis of the directive's principal obligations, without requiring any salary data.