Pay Information Requests: Ready Before the First One Arrives

Published June 2026 - originally on LinkedIn.

Under the EU Pay Transparency Directive, employees have the right to request information about their individual pay level and the average pay levels - broken down by gender - for categories of workers doing the same work or work of equal value.

Companies also need to have clear, objective, gender-neutral criteria for pay, pay levels, and pay progression.

That's not just a reporting exercise. It means someone in your company needs to be able to explain how pay decisions were made - with real criteria, not "it felt right at the time."

This is where most companies get stuck.

Not because they don't have salary bands. But because nobody has defined who owns the request, what the response looks like, or what happens when the answer reveals a gap.

Here's what I'd want in place before the first request comes in:

Ownership. Who receives the request? The manager? HR? People Ops? What's the intake process, and what's the expected response time?

Criteria and comparable groups. How do you define "same work or work of equal value" in your org? If you can't answer that clearly, you can't answer a pay information request either.

Response template. You don't want managers improvising an explanation of pay criteria in a 1:1. Have a standard format ready that HR has signed off on.

Manager briefing. Managers will be the first people employees ask - even before a formal request. They need to know what they can say, what they shouldn't guess at, and when to route to HR.

Escalation path. What if the answer reveals a pay gap you can't justify with objective criteria? You need a process for that before it becomes a bigger problem.

Tooling. If you have the budget, a good compensation tool can make this much cleaner: request outputs, audit trail, and less manual coordination. But the tool still needs the underlying logic: comparable groups, pay criteria, ownership, and escalation rules. Without that, you're just automating a gap.

Having bands is not enough if you can't explain the decisions behind them.

This is the part of EU PTD readiness that most companies haven't thought through yet. If you're working on it, DM me - this is often where a review gets most practical.