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What documents do you need when responding to a pay transparency request?

An employee asking for compensation information expects a substantiated answer within the prescribed deadline. These are the documents you must have ready for that.

For a request for information about remuneration, you need three types of documents: a record of the request itself with the date of receipt, the underlying job classification with the criteria on which it is based, and an overview of the average remuneration level of the comparable group, broken down by gender. What you do not need, and should not provide, is the individual salary of a named colleague.

The detail that plays the most significant role in this matter is that the initiative does not lie with you but with the employee, and that the clock starts running from the moment of receipt. This makes recording the request itself just as important as the answer you provide. Without a noted receipt date, it is difficult to demonstrate afterwards that you responded within the deadline, and that is precisely what supervisory authorities look at when a request becomes the subject of a dispute.

Record the request itself

Note when the request was received, via which channel, and what was asked exactly. An employee can ask about their own remuneration level compared to the comparable group, about the criteria used in the classification, or about both. Also record when and with what content you replied. This log is not merely a nice addition but the proof that the deadline was met, and it remains relevant if an employee later submits a second or third request.

The underlying documents

A substantive answer stands or falls with the quality of the job classification that underlies it. Without a classification based on objective, gender-neutral criteria, there is no comparable group against which to measure an average remuneration level, and therefore no useful answer to the request. Anyone who does not yet have this classification in order will find in the step-by-step explanation in the knowledge base what the classification is about and how it relates to the right to information.

In addition to the classification itself, there is the remuneration policy that describes how salary, allowances and other remuneration components come about. This policy does not need to be handed over to the employee, but it is the source from which the answer is built. If a documented policy is lacking, an information request falls back on loose agreements and individual files, and that makes a consistent answer considerably more difficult.

What you do not provide

The right to information concerns the average remuneration level of the comparable group by gender, not the salary of an individual colleague. A request that actually asks what a named person earns falls outside the scope of this right. Where exactly that line is in borderline cases is a question for a lawyer or the competent supervisory authority, not something that can be established on the basis of this provision.

Repetition and retention period

An information request is rarely a one-off event. Employees who once know this right exists sometimes ask for it periodically, and colleagues within the same department follow each other's example. One file per request, containing the request, the answer and the figures used, prevents each subsequent request from starting from scratch. It also makes it visible whether the remuneration level of the comparable group has changed over time, which in turn relates to the broader reporting obligations for larger employers.

Whether your organisation currently falls under any of these obligations, and which documents are specifically missing, can be established with a few targeted questions. Take the free check and see in a few minutes where you stand before the first request arrives. Anyone who first wants to understand how the classification, the policy and the requests relate to each other can read that afterwards in the frequently asked questions about information requests, and whoever wants to bring the classification, policy and handling together in one system will find its structure on the page with subscriptions and what is included.

This text describes how the right to information is structured and which documents are commonly used to have on hand. It is not legal advice on your specific situation; consult a lawyer or the competent supervisory authority for that.

This article is general information and not legal advice.