This is the second blog in a new series of blogs that will focus on Article 7’s Right to Information requirement. Access the first blog of the series, which sets the foundation of what’s required, what the challenges are, and how to meet them confidently.
The EU Pay Transparency Directive (EUPTD) introduces a new Right to Information (RTI) that allows workers to request data about their pay and how it compares to others performing the same work or work of equal value.
In our previous article in this series, we explained the core elements of RTI requests, including what pay information must be provided and how employers should prepare their compensation data.
This installment focuses on two operational requirements that will require careful preparation from employers:
- The timing requirements for responding to RTI requests
- The obligation to annually inform workers of their RTI rights
While these provisions may appear straightforward, the details around deadlines, clarification requests, and employee notification procedures are already evolving through Member State draft legislation.
RTI Response Timing: Two Months Under the Directive
The Directive requires employers to provide a response to RTI requests “within a reasonable period of time but in any event within two months from the date on which the request is made.”
While this establishes a baseline requirement, Member State draft transpositions are already introducing some variation in how this timing requirement will be applied.
In drafts published to date:
- Most Member States reaffirm the two-month response deadline
- Others, like Poland, are proposing shorter response periods of 30 days
As a result, employers operating across multiple EU jurisdictions should anticipate the need to respond to RTI requests within as little as one month in certain countries.
This compressed timeline will require organizations to ensure their pay data and worker category structures are readily available to support timely responses.
Requests for Clarifications: Additional Employer Obligations
Workers who receive RTI information also have the right to request additional and reasonable clarifications and details if the information provided is incomplete or inaccurate. The Directive does not address who determines whether a response is incomplete or inaccurate or what reasonable clarifications and further details must be provided, procedures for which may also vary among Member States.
The Directive requires employers to provide a substantiated reply to such requests.
However, the Directive does not establish a specific deadline for responding to these clarification requests.
As a result, Member State drafts are taking different approaches:
- 30-day deadline – Slovakia and Poland
- “As soon as possible” – Sweden
- No defined deadline – Cyprus, Finland, Italy, Netherlands
- Reasonable time interpreted as approximately four weeks – Denmark (based on explanatory notes)
This emerging variability means employers may face different compliance timelines depending on the jurisdiction, particularly when responding to requests for additional explanation.
For this reason, some organizations are choosing a proactive strategy: making RTI reports accessible to all employees rather than waiting for requests to accumulate and juggling varying response deadlines.
In that same vein, some enterprises we’re working with intend to include contextual narratives with RTI reports to proactively limit additional requests for clarification.
Annual RTI Notifications: Employers Must Inform Workers of Their Rights
In addition to responding to requests, the Directive requires employers to inform workers annually about:
- Their right to request pay level information
- The procedure for submitting such requests
The Directive does not establish a specific deadline for providing this annual notification. However, Member State drafts may add additional structure.
For example:
- Poland’s draft legislation proposes a deadline of March 31 for providing annual reminders to employees.
Importantly, the obligation to notify employees only applies once RTI rights become enforceable in each Member State following national transposition of the Directive.
For Member States expected to transpose the Directive by June 2026, employers should begin preparing communication materials and processes now while waiting for national legislation to take effect before issuing notifications.
Why the Annual Reminder Requirement Matters
The annual notification requirement also creates an opportunity for employers to establish clear and standardized procedures for handling RTI requests.
Article 7 states that workers have “the right to request and receive in writing” RTI information. While the information provided by employers must be “in writing,” the Directive does not explicitly require that the request itself be made in writing, nor does it establish a clear framework for who is the appropriate recipient of such a request.
This creates potential practical and compliance challenges for tracking RTI requests once made.
To mitigate this risk, employers should establish a clear RTI request procedure through its annual notification, including guidance on:
- Where requests should be submitted
- Whether requests must be made in writing
- How requests submitted by employee representatives or equality bodies will be handled
Equally important, employers should maintain auditable documentation that employees were annually notified of the request procedures..
Preparing for the First Wave of RTI Requests
Once RTI rights take effect and employers provide their first annual notification to workers, organizations should anticipate that these communications may trigger an initial wave of RTI requests.
Employers should therefore establish internal workflows that allow them to:
- Track RTI requests and response deadlines
- Identify the relevant worker categories
- Generate compliant pay comparison data
- Provide substantiated replies to clarification requests when needed
Without structured workflows and readily accessible compensation data, meeting these obligations within the required timelines could become administratively burdensome.
Looking Ahead: Member State Variations Will Continue to Emerge
As EU Member States continue publishing draft legislation to transpose the Directive, additional detail is emerging on how RTI procedures will function in practice.
These variations include:
- Response deadlines for RTI requests
- Timing requirements for clarification responses
- Deadlines for annual employee notifications
Employers operating across multiple jurisdictions will need to carefully monitor these developments to ensure they remain compliant with each country’s national implementation.
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, 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 — easing the operational strain on organizations.
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.
Organizations that partner with us will not only be supported in meeting Directive’s requirements — they will enter this new transparency landscape with confidence and credibility.
