On 6 July 2026, Greek law 5316/2026 was published in the Government Gazette, which transposes into Greek law Directive (EU) 2023/970 on pay transparency and equal pay. The new legislative framework establishes a set of obligations aimed at strengthening the principle of equal pay for equal work or work of equal value and enhancing transparency in remuneration practices across both the private and public sectors. The rules apply to all employers, regardless of sector, with certain obligations depending on employer size. The provisions concerning employer pay transparency obligations enter into force on 1 November 2026.
Pre-contractual stage
- At the pre-contractual stage, applicants are entitled to receive information on the initial pay or pay range for the position, based on objective and gender-neutral criteria, as well as on the relevant provisions of any applicable collective bargaining agreement. This information must be provided before the interview or, where no interview takes place, before the conclusion of the employment contract. Employers are also required to ensure that job titles and vacancy announcements are gender-neutral and that recruitment processes are conducted in a non-discriminatory manner.
During the employment relationship: pay structures and information right
- During the employment relationship, all employers must establish and apply written and documented pay structures that ensure compliance with the principle of equal pay for equal work or work of equal value. These structures include the rules, criteria, classifications and procedures used to determine and manage remuneration, including gender-neutral job evaluation and classification systems. Employees also have the right, upon request, to receive written information on their individual pay level and on average pay levels, broken down by sex, for categories of workers performing equal work or work of equal value.
Reporting obligations
- Starting from 7 June 2027, additional reporting obligations apply depending on headcount. Employers with at least 100 employees are required to report pay gap data to the Greek Ombudsman, as well as to employees and their representatives, including information on the overall and median gender pay gap, the gender pay gap in variable components, and the distribution of employees across pay quartiles and worker categories. Reporting obligations apply on different timelines depending on workforce size, with employers of 250 or more employees reporting annually, those with 150 to 249 employees reporting every three years, and those with 100 to 149 employees first reporting in 2031 and thereafter every three years.
- Employers subject to pay gap reporting obligations must also carry out a joint pay assessment in cooperation with workers’ representatives where a reported gender pay gap of at least 5% in any worker category remains unjustified and uncorrected within six months of reporting.
Remedies and enforcement
- The enforcement framework provides for administrative sanctions for breaches of pay equality and transparency obligations, escalating fines imposed by the Labour Inspectorate in cooperation with the Ombudsman for continued non-compliance, full compensation for affected employees without any upper limit (including material and non-material damages), and a shift in the burden of proof in favour of employees in cases of non-compliance.
- The competent authorities responsible for implementation and oversight include the Greek Ombudsman, the Labour Inspectorate, the National Transparency Authority, and the Ministry of Labour and Social Insurance.
The following Q&A section is intended to assist employers in understanding the practical implications of the new legislative framework:
Q&A — PRACTICAL QUESTIONS
- Do these obligations apply to us if we employ fewer than 100 employees?
Yes, with the exception of pay gap reporting, which applies only to employers with at least 100 employees, the pay transparency obligations generally apply regardless of headcount. The only limited exemption concerns employers with fewer than 50 employees, who may choose not to provide information on pay progression criteria. All other obligations remain applicable.
- What information must be provided to candidates in order to comply with the pre-contractual transparency obligation?
Candidates must be informed, before the interview (or, if no interview takes place, before conclusion of the employment contract), of the initial pay or pay range for the position and of any applicable collective bargaining agreement provisions. This information may be provided by any appropriate means, either in writing or orally.
- Can we ask candidates what they currently earn or what they earned in their previous job?
No. The employer, and any person acting on the employer’s behalf, during the interview and throughout all communication relating to access to employment, is not permitted to submit to applicants questions concerning their pay history during their current or previous employment relationships.
- An employee has asked us for information about average pay levels broken down by sex for their category of employees. What are our obligations?
You are required to provide the requested information in writing, including the employee’s individual pay level and the average pay levels, broken down by sex, for employees performing equal work or work of equal value. The information must be provided within two months of the request.
Employers must also inform employees annually of their right to request this information and the procedure for doing so.
A request may only be refused if it is manifestly disproportionate or abusive (e.g., in the case of repetitive requests), in which case the employee may refer the matter to the Ombudsman to obtain the information.
- Can we include a clause in employment contracts prohibiting employees from discussing their salaries with colleagues?
No. Individual employment contracts, collective agreements, or Labour Regulations cannot restrict employees, by means of contractual terms, from disclosing their pay when the purpose of such disclosure is to safeguard the principle of pay equality. Any such clause is void.
However, there is a qualification: employers may require employees who have received pay data pursuant to the right-to-information provisions — other than information about their own pay or pay level — not to use that information for any purpose other than exercising their right to equal pay. Employees and workers’ representatives are bound by a duty of confidentiality and discretion in relation to pay data they receive, and any breach entitles the employer to claim compensation for the damages suffered.
- We have around 160 employees. What exactly triggers the “joint pay assessment”, and when must it be completed?
A joint pay assessment is required where the employer’s pay gap report reveals a gender pay gap of at least 5% in any category of workers, the difference cannot be justified by objective and gender-neutral criteria, and it is not remedied within six months of the reporting date.
The assessment must be carried out together with workers’ representatives, made available to employees and the competent authorities, and followed by corrective measures. Any unjustified pay differences must be remedied within one year of the assessment notification.
As an employer with 150–249 employees, your first pay gap report would be due by 7 June 2027 and thereafter every three years.
- If an employee is dismissed and later brings an equal pay claim, is the claim time-barred?
Not necessarily. The limitation period for equal pay claims starts when the employee becomes aware, or can reasonably be expected to become aware, of the alleged breach. Under the established Greek legislative framework, the employee is presumed to have become aware of the breach upon receiving pay information under the right-to-information provisions or upon termination of the employment relationship.
- Can an employee be dismissed for making an equal pay complaint?
No. The law introduces explicit anti-retaliation protection. Dismissal or any other adverse treatment of employees and workers’ representatives is prohibited when it constitutes an employer’s reaction to a complaint within the employer’s organization or to any administrative or judicial procedure for the purpose of enforcing any rights or obligations related to the principle of pay equality.
- What should be the first steps that an employer should follow to ensure compliance in practice?
Compliance with the law requires action across several fronts simultaneously. The following is a structured sequence of priority steps, drawn directly from the obligations set out in the law’s articles.
- Establish or review your pay structure
- Audit your recruitment and selection processes
- Make pay criteria accessible to your existing workforce
- Set up an internal process for responding to pay information requests
- Establish an annual notification procedure for employees (On an annual basis, you must inform all employees of their right to receive pay information and of the steps they need to follow to exercise that right. This notification can be incorporated into your pay policy, internal regulations, or a regular communication cycle, but it must cover all employees without exception.)
- Review and revise employment contracts and internal regulations regarding pay confidentiality (Any contractual terms — whether in individual employment contracts, collective agreements, or internal work regulations — that restrict employees from disclosing their pay for the purpose of safeguarding pay equality are void and must be removed.)
- Determine your headcount obligation for pay gap reporting and begin data collection (If you employ at least 100 employees, you are subject to pay gap reporting obligations.)
