EU pay transparency tracker

EU Employee Pay Information Request Tracker

Log every employee pay-information request, run the two-month clock, assemble a privacy-safe response, and keep the annual reminder on schedule, so the pay-information right becomes a routine process rather than a scramble, with the moments to bring in qualified local counsel and your data protection adviser marked.

$59USD

One-time purchase, no subscription. Instant download.

Built by expert HR practitioners and leaders

  • A Framework you set once: the pay-information right in plain terms, your response window, two months by default, and your small-group privacy threshold, five by default, both driving the rest of the workbook
  • A Request Log that runs the clock: one row per request, the due date and a days-left countdown computed for you, a status that flags overdue, and a rollup of logged, open, responded, and overdue
  • A disclosure builder: enter the category make-up, check the small-group privacy flag, and assemble a written response with averages by sex, never the pay of an identifiable person
  • The annual notice on record: a log for the yearly reminder to all workers that the right exists and how to use it, the separate duty that handling requests well does not satisfy
  • A review checklist and definitions: eight checks to clear before a response goes out, from confirming the local window to retaining a copy, and plain-language definitions of the terms the right uses

The tracker structures the work and keeps the record. It is not a legal determination, and it routes the close calls, the disclosure limits, the local window, and anything cross-border, to qualified local counsel and your data protection adviser.

One-time purchase Instant download Editable files 14-day guarantee

Readiness tools and general information, not legal or tax advice. The pay-information right is set by Directive (EU) 2023/970 and put into effect by national law in each member state, which varies and is still arriving, and some countries set a shorter response window. Confirm country-specific requirements with qualified local counsel and your data protection adviser before you act.

Last reviewed June 2026

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What you get

One workbook, seven tabs that run the pay-request right

One Excel workbook that also works in Google Sheets, with a Start Here guide and a one-page guide to running it in Sheets. Set the Framework once, log each request as it lands, build the response in What to Disclose, and keep the Annual Notice log current. Built to be the single place a request lives from arrival to answer.

PDFStart here

Start Here Guide

A one-page map that sets the order: set your window and threshold on Framework, log each request as it arrives, build the response in What to Disclose, clear the Review Checklist, and send inside the window. The same map sits on the first tab of the workbook, with the standing instruction to pause where a step carries legal weight.

XLSXExcel

Framework

The pay-information right at a glance: what an employee can request, what you do not disclose, the response window, the annual reminder, who can ask, the pay-secrecy ban, and the small-group caution, above the two settings that drive the workbook, your response window and your small-group privacy threshold.

XLSXExcel

Request Log

One row per request: the date received, the channel, the requester, the category, and what was asked. The due date computes from your window, the days-left countdown turns amber as the deadline nears and flags overdue, and a rollup keeps logged, open, responded, and overdue in view.

XLSXExcel

What to Disclose

The response builder. Enter the category and its make-up, read the small-group privacy flag against your threshold, and assemble the written response from the include list, with the do-not-include list and the reminder to respond in writing inside the window.

XLSXExcel

Annual Notice

The log for the yearly reminder to all workers that the right exists and how to use it: the year, the date sent, the channel, the audience, the owner, and the evidence link, with a rollup of notices logged and the most recent year.

XLSXExcel

Review Checklist + Definitions

Eight checks to clear before a response goes out, from confirming the local window to retaining a copy on file, and plain-language definitions of the terms the right uses, from equal-value work to equality body.

How it works

The method in the order a request runs

Configure once, then log, build, and send inside the window. The tracker keeps you organized and on record; counsel and your data protection adviser handle the close calls.

STEP 01

Set your window and threshold

Open the Framework tab, set your response window and your small-group privacy threshold, and let both drive the workbook. The Directive baseline is two months and some national laws are shorter, so confirm yours with counsel and set it once.

STEP 02

Log each request as it lands

Record every request on the Request Log on arrival, whoever it comes through, the employee directly, worker representatives, or an equality body. The clock runs from the date of the request, the due date and the days-left countdown compute for you, and the rollup keeps the open count honest.

STEP 03

Build a privacy-safe response

Work through What to Disclose: enter the category and its make-up, check the small-group privacy flag, and assemble the written response, their own pay level, the average pay levels by sex for the equal-value group, and the objective criteria used to set pay.

STEP 04

Send inside the window and record it

Clear the Review Checklist, send the written response inside the window, and record the response date so the clock and the record stay together. Then keep the Annual Notice log current so the yearly reminder is never missed.

The standard

Every request logged, answered in the window, and on the record

Pay-information requests go wrong in patterns: a request logged late or not at all, a deadline counted from memory, a response that points at one identifiable pay, a small category disclosed without a second look, and an annual notice nobody owns. The fix is a small system, a log that runs the clock, a builder that checks privacy, and a record of what was sent and when, and this tracker gives you all of it, with the moments to stop and get qualified help marked.

The transposition deadline passed on 7 June 2026 with only a handful of member states on time, and several, including the Netherlands, Sweden, the Czech Republic, and Denmark, have pointed to 1 January 2027. The right itself does not get simpler by waiting: once the national law lands, a worker can ask for their own pay level and the average pay levels by sex for the group doing the same work or work of equal value, the answer is due in writing within two months or sooner where national law says so, and employers must tell all workers every year that the right exists and how to use it. A tracker set up before the first request is cheap, and a scramble after it is not.
The clock starts when the request lands, not when HR notices. The window runs from the date of the request, so the habit that matters is logging on arrival. One row on the Request Log captures the date, the channel, and what was asked, and the due date and the countdown compute from that moment.
Averages by sex, never the pay of an identifiable person. The right covers their own pay level and the average pay levels by sex for the equal-value group, not the pay of a named colleague. Where the group is small an average can point at a person, so the builder flags any category below your threshold and the disclosure limits are confirmed locally before anything goes out.
The annual notice is the duty teams miss. Handling each request well does not satisfy the separate duty to remind all workers, every year, that the right exists and how to use it. The Annual Notice tab keeps the year, the owner, and the evidence, and a logged notice is the difference between done and assumed.

The tracker tells you when to call a lawyer

Most requests can be logged, built, and answered in-house with the workbook. Some sit near a legal line, and the tracker marks them, so you get qualified local counsel and your data protection adviser in before a response goes out. Advice before you send is far cheaper than defending a disclosure after.

Confirming the response window, the request routes, and the disclosure limits in each country where you employ, since national law can be shorter or broader than the Directive baseline A small or unusual category where an average could identify an individual, and the data-protection rules that interact with the disclosure A request arriving through worker representatives or an equality body, or in a country where the national law has not yet landed A response that would cross borders or cover more than one entity, country, or pay system A pay gap the averages will surface, and what to say and do about it before and after you send A worker raising retaliation, or a pay-secrecy clause still sitting in contracts or policies

Who does what

Answering the right splits the work between you, the tracker, and your advisers. Here is the split, stated plainly.

  • The tracker structures the work; you run it. The log, the builder, the checklist, and the annual notice keep the work consistent and on record. Logging on arrival, naming the equal-value category, and sending inside the window are yours to do.
  • The tracker counts the window; counsel confirms it. The due date computes from the response window you set, two months by the Directive baseline. The exact window, who can ask, and how, are national and still arriving, so the local rule is confirmed with counsel rather than assumed.
  • The builder flags privacy; counsel and your data protection adviser rule on it. A category below your threshold is a flag to stop and check the local disclosure limits and the data-protection interaction, not a determination either way.
  • The workbook gives you the Directive baseline as reviewed; you confirm the rest. The Framework states the right as of its June 2026 review. The position in each country where you operate is confirmed with qualified local counsel before you rely on it.
  • The tracker keeps the record, and the record is the point. A logged request, a dated response, the privacy check, the cleared checklist, and the annual notice are what a documented position looks like if a response is ever challenged.
Is this for you

Who it is built for

Who this tracker fits, and where to go if that is not you.

Built for

  • An HR or reward team that has to answer employee pay-information requests on time and on record, in one or more EU countries, and wants the clock, the privacy check, and the paper trail handled in one place.
  • An employer that needs the yearly notice to staff and a privacy-safe way to answer requests, without standing up the full readiness program.
  • A people team expecting requests once the right is widely known, that wants the system in place before the first one arrives rather than built during it.

If you’re looking for

Questions

Before you buy

What format are the files and can I edit them?
One Excel workbook that also works in Google Sheets, with a Start Here guide and a one-page guide to running the workbook in Sheets. The input cells are open while the formulas are protected, each working tab opens on a worked example you replace with your own requests, and the files are yours to keep.
Is this legal advice?
No. It is general information and a self-review structure for planning. The tracker marks where to bring in qualified local counsel and your data protection adviser, and it does not determine that any disclosure complies. Take the close calls to counsel before you send.
What is the worker information right?
An employee may ask for their own pay level and the average pay levels, split by sex, for the category doing the same work or work of equal value, plus the objective criteria used to set pay and pay progression, and the employer responds in writing within two months, sooner where national law says so. Requests can also come through worker representatives or an equality body. The Request Log runs the window and What to Disclose builds the response.
How does the small-group privacy check work?
You set a small-group threshold on the Framework tab, five by default, and the builder flags any category below it so the response stays at averages by sex and nothing that could identify one pay. The exact limit is national and interacts with data-protection law, so the close calls go to counsel and your data protection adviser before the response is sent.
The transposition deadline has passed and our country has not finished. Is this still useful?
Yes, and the gap is the reason to set the system up now. The deadline was 7 June 2026, only a handful of member states were on time, and several have pointed to 1 January 2027, so the rules arrive country by country. The response window and the privacy threshold are settable for exactly that reason, and a tracker in place before your national law lands beats one built after the first request.
What is the refund policy?
Digital products are covered by a 14-day money-back guarantee. See the refund policy for the full terms.
What happens after I buy?
Checkout delivers an instant download link, and a receipt with the same link arrives by email. Open the Start Here page first; it tells you the order to work in. If a file gives you trouble, email support@truestephr.com.
Can I expense this purchase to my business?

Most customers buy TrueStep HR tools for business use, and a tool you use for work often qualifies as a deductible business expense. Whether it does for you depends on your situation, so confirm with your accountant or tax professional. Your receipt arrives by email at checkout and works as documentation.

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Get the kit

Handle every pay-information request on time and on record

Set the window once, log each request as it lands, build a privacy-safe response, and keep the annual notice current, in a file you keep, with the moments to bring in counsel marked.

$59
One-time purchase, no subscription

A workbook and general business information for planning, not legal or tax advice. Last reviewed June 2026.