This is the first blog in a new series of blogs that will focus on Article 7’s Right to Information requirement. This lays the foundation of what’s required, what the challenges are, and how to meet them confidently. The ensuing blogs will go deeper into various key aspects of RTI and how individual Member States are addressing it in their draft legislation.
Beginning June 7, 2026, one of the most operationally complex provisions of the EU Pay Transparency Directive is due to take effect in EU Member States that transpose on time: Article 7 — the Right to Information (RTI).
Under Article 7, workers have the right to request and receive in writing:
- Their individual pay level
- The average pay levels, broken down by sex, for workers performing the same work or work of equal value
Unless shortened by Member State transposition, employers must respond within a reasonable period of time — and no later than two months from the date of request. Employees may submit requests directly, through worker representatives in accordance with national law or practice, or via an equality body. In addition, employers are required to remind workers annually that this right exists and explain how to exercise it.
This is not a passive reporting obligation. It is an on-demand, legally enforceable transparency mechanism. For many employers, it represents one of the more challenging aspects of the Directive, especially since it comes online immediately.
What Exactly Must Be Shared?
The Directive defines “pay level” as gross annual pay and the corresponding gross hourly pay. Importantly, “pay” is defined broadly. It includes not only basic salary, but also complementary and variable pay, including bonuses, allowances, and benefits in kind; essentially any consideration a worker receives directly or indirectly from the employer.
This means employers cannot limit RTI responses to base salary alone. Total remuneration must be considered.
Article 7 of the Directive requires disclosure of the unadjusted average pay level for the worker category, broken down by sex. It does not require any additional clarifications and details unless the information provided is inaccurate or incomplete. Any broader disclosure obligations would depend on how each Member State transposes the Directive, and thus far Member States have stuck close to the minimum requirements.
Under Article 6, employees are also entitled to access the criteria used to determine pay, pay levels, and pay progression. Those criteria must be objective and gender-neutral. This creates a governance obligation that extends beyond numbers and into documented pay philosophy.
Why Article 7 Is Operationally Complex
Data Consolidation and Remuneration Valuation
Most large organizations do not store all compensation data in one system. Payroll, bonuses, equity, and benefits are often managed across different vendors and platforms. Because RTI requires reporting on gross annual and hourly pay — and because pay includes benefits in cash or in kind — organizations must aggregate and transform data from multiple sources.
Benefits are a particularly sensitive area. Cash benefits such as incentive payments are relatively straightforward. Benefits in kind — such as cars, housing allowances, private medical insurance, or equity schemes — require valuation methodology. Employers must ensure consistency and comparability across worker categories.
Some Member States are signaling potential exclusions. For example, Poland and Slovakia have indicated that certain universally granted benefits may be excluded, while the Netherlands is anticipating excluding benefit components not tracked at the individual level. These nuances mean employers must evaluate RTI implementation jurisdiction by jurisdiction.
In practice, many organizations are planning quarterly or monthly data refreshes and considering a rolling 12-month lookback period to ensure information remains up to date. While Article 7 does not prescribe a specific timeframe, the expectation is that the information provided must be current.
Privacy and GDPR Considerations
Depending on the Member State transposition, employers may be required to provide worker category-level averages without revealing identifiable pay data of another worker. In small worker categories, this can create re-identification risk. RTI responses must therefore be structured carefully, with role-based permissions, audit trails, and secure delivery mechanisms, as well as set thresholds, where necessary, for alternative provision of data to workers’ representatives or equality bodies.
This is not simply a compensation exercise, it is a data protection exercise as well.
The 60-Day Compliance Clock
Two months might seem like a reasonable timeframe on the surface, but for enterprises with thousands of employees, even a small percentage of simultaneous requests could create administrative strain. Depending on the size of the team managing such requests, with even a small percentage of employees submitting RTI requests within a short window, manual workflows become untenable. Additionally, if employees believe the information provided is incomplete or inaccurate, they are entitled to request reasonable clarifications and receive a substantiated reply, which may come with its own deadline for response.
A reactive, case-by-case approach exposes employers to both operational risk and compliance failure. As a result, it is important to proactively put in place processes to manage response workflows and prepare compliant responses that include appropriate context for employees.
In addition, some forward-looking organizations are choosing a proactive strategy: making RTI reports accessible to all employees rather than waiting for requests to accumulate.
Litigation and Worker Sentiment Risk
RTI is directly connected to the potential for litigation and compliance enforcement.
Where unadjusted pay gaps are revealed, equal pay claims may follow. Workers’ representatives may become involved. Employee sentiment may shift if reports are delivered without additional context.
Transparency without preparation can create unintended consequences. Companies should gain confidence and insight through a defensible underlying pay equity analysis before disclosures are distributed at scale.
What About Contractors and Temporary Workers?
The Directive uses a broad concept of “worker,” and treatment of leased personnel, temporary staff, and certain contractors will depend on national transposition. Genuinely independent contractors may fall outside scope, but individuals labeled as contractors who legally qualify as workers under national law could fall within RTI obligations.
Employers cannot assume automatic exclusion of third-party personnel. Member State definitions and labour laws will determine scope, and organizations should closely monitor national guidance.
How Trusaic Is Helping Clients Comply with Right to Information Requests
At Trusaic, we are helping employers move from reactive compliance to scalable readiness.
First, organizations conduct a defensible pay equity analysis through PayParity®. This ensures that total remuneration is analyzed correctly, unjustified gaps are identified and remediated using R.O.S.A., and ready for RTI disclosures. A validated pay equity analysis can provide confidence and a clear understanding of risk as companies begin RTI compliance.
Second, we enable automated RTI workflows. Our bi-directional integrations with global HCM platforms allow pay equity data to flow securely from the Trusaic platform back into the HCM. Employees can then access their RTI reports directly within their existing HR systems. This eliminates manual report generation and reduces compliance risk.
For organizations that prefer platform-based access, RTI reports can also be generated and delivered securely through the PayParity platform, with role-based permissions and full auditability.
Reports can be generated instantly, refreshed regularly, and delivered in any EU language — ensuring organizations meet the two-month deadline without operational strain.
Finally, our expert advisory team will assist you in constructing your contextual narratives alongside RTI reports. (Note: Employers also have the option to utilize our in-platform AI-powered contextual narrative support). Rather than presenting raw pay data without explanation, organizations can configure tailored narratives that reflect their pay philosophy and clarify wage-influencing factors. For large enterprises anticipating thousands of RTI interactions, this significantly reduces administrative burden while improving employee understanding.
Final Thoughts
Article 7 introduces a new era of employee-triggered pay transparency. It requires organizations to aggregate complex remuneration data, protect privacy, respond within strict timelines, and manage litigation and reputational risk — all while maintaining employee trust.
This is not simply a reporting obligation. It is an operational transformation.
At Trusaic, we are helping our clients comply with Article 7 through defensible pay equity analysis, automated RTI workflows, secure HCM integrations, and assistance with contextual employee communications.
Organizations that prepare now will not only meet the Directive’s requirements — they will enter this new transparency landscape with confidence and credibility.
