While the law entered into force in July 2026, most operational obligations apply from 1 November 2026. This includes pay information rights, recruitment transparency, gender pay gap reporting, joint pay assessments, remedies and protections against victimisation. That gives employers with operations in Greece a short preparation window before the core compliance regime takes effect. 

In this article, we summarise some of the key features of Greece’s new framework that employers need to be aware of. 

The Greek transposing law 5316/2026 closely follows the Directive but adds Greek-specific detail in several areas. These include written pay structures, fixed remediation deadlines, employee information requests, enforcement and penalties. Employers with operations in Greece should focus on the following points:  

• The main operational obligations take effect on 1 November 2026: While the law was enacted on 6 July 2026, the substantive pay transparency requirements apply from 1 November 2026. These requirements include the right to information, pay gap reporting, joint pay assessments, remedies and protection against victimisation. 

• Employers must have written, documented pay structures: The Greek law goes beyond the Directive by requiring pay structures to be documented in writing, to include a review procedure, and to clearly identify the remuneration elements for each category of worker. 

• Employers can refuse abusive pay information requests: Employers may refuse manifestly disproportionate or abusive requests for pay information, subject to Ombudsman review. The refusal grounds resemble those that apply to Data Subject Access Requests (‘DSARs’) under the EU General Data Protection Regulation (‘GDPR’). 

• Employees who receive salary data must keep it confidential: This obligation also applies to employee representatives. Employers can claim compensation if either party breaches this explicit confidentiality obligation. 

• Fixed deadlines replace the Directive’s ‘reasonable time’ standard: Employers have six months to remedy unjustified pay gaps identified through pay reports. They have one year to correct gaps arising from joint pay assessments. 

• A new administrative dispute procedure adds a compliance layer: Employees can bring pay discrimination claims through a dedicated Labour Inspectorate process. The process requires mandatory Ombudsman involvement and follows specific timelines. 

• Non-compliance can attract substantial penalties: The Labour Inspectorate can impose fines ranging from EUR 300 to EUR 50,000 per violation. Repeated high or very high severity violations can result in temporary closure of all or part of a business. Repeat offences or a failure to comply with an order issued by the Labour Inspectorate can trigger recurring fines every three months.

• The law is silent on public procurement: Greece has not transposed Article 24 of the Directive, which links equal pay compliance to public contract eligibility. This is because other existing Greek legislation already confirms that employers who commit violations of labour laws are excluded from participating in public tenders.  

One of the most significant changes between the draft and the final law is the split commencement date.  

The law’s structural provisions took effect on 6 July 2026. These cover scope, definitions, institutional designations and the Ombudsman’s role. However, most of the operational provisions apply from 1 November 2026. These include pay transparency obligations, the right to information, pay gap reporting, joint pay assessments, remedies, burden of proof and victimisation. 

This gap is important. It has given employers more time to review and adjust their pay structures, prepare reporting processes and train their HR teams before the substantive requirements bite. 

The Greek law broadly follows the Directive but adds important national detail and omits one Directive provision. The main similarities and differences are summarised below. 

‘Pay’ is interpreted broadly under Greece’s transposing law. It includes basic or minimum salary and any other cash or in-kind consideration received directly or indirectly in respect of work. This includes variable remuneration and occupational pension elements.  

Under the Directive, employers must have pay structures that ensure equal pay, based on objective, gender-neutral criteria agreed with workers’ representatives where they exist. Notably, the Greek law goes further by requiring these structures to: 

• be documented in writing; 

• include a review procedure; and  

• clearly identify the elements of remuneration for each category of worker. 

The applicable pay criteria must be readily accessible to employees and available in accessible formats for employees with disabilities. Employers with fewer than 50 employees are exempt from providing information on pay progression. 

Regarding job evaluation, the Greek law closely follows the Directive’s four main job evaluation criteria: skills, effort, responsibility and working conditions. It adds ‘seniority and related non-technical skills’ as examples of other relevant factors. However, it omits the Directive’s express statement that ‘relevant soft skills shall not be undervalued’. 

The Greek law defines ‘workers’ representatives’ as the legal representatives of the workers’ union of the most representative trade union of the undertaking. The Directive leaves the definition of workers’ representatives to national law and practice. Greece therefore adds a national specification rather than deviating from the Directive. However, by narrowing the definition to the most representative trade union, the Greek law may have implications for workplaces with multiple trade unions, where it will be important to identify which union qualifies as ‘most representative’ for these purposes.   

For the purposes of conducting a joint pay assessment, and in the absence of any trade union representatives, employees must be represented by the three most senior employees in the enterprise, unless they choose another method of representation. 

The Greek law transposes the Directive’s requirements on pre-employment pay transparency, with some useful additional detail. 

Job applicants have the right to receive information, in writing or orally, on the initial remuneration or its range before the job interview. If no interview occurs, the employer must provide it before concluding the employment contract. The Greek law goes further than the Directive by requiring ‘documented and transparent’ negotiation and indicatively refers to several potential channels for publishing this information. This includes, among others, professional networking websites. These channels are provided by way of example only and are not intended to be exhaustive.   

In line with the Directive, employers must also inform applicants of any applicable collective labour agreement. Vacancy notices and recruitment procedures must be gender-neutral and free from other discrimination.  

The Greek law also closely transposes the prohibition on pay history and extends it to: 

• cover ‘any person acting on behalf’ of the employer; and  

• apply during ‘all cases of communication concerning access to employment’, not just interviews. 

Employees have the right to request and receive information on their individual pay level and the average pay levels, broken down by gender, for categories of workers performing the same work or work of equal value. They can do so personally, through employee representatives or through the Ombudsman. This must be provided within two months.  

If the employer does not respond within two months, or if the response is incomplete, inadequate or requires clarification, the employee may seek further information. Again, employees may do so personally, through employee representatives or through the Ombudsman.   

Employers must inform all employees annually of their right to information and the procedure for exercising it. 

Employers have a right to refuse manifestly disproportionate or abusive requests, such as repetitive requests. In that case, the employee can refer the matter to the Ombudsman, who will assess the validity of the request. The inclusion of such grounds for refusal (albeit with a high bar) has echoes of the regime governing data subject access requests under the GDPR. 

The Ombudsman plays a central role throughout the Greek law. It is the designated equality and monitoring body and can become involved in resolving disputes over pay information requests, monitoring the framework and publishing pay gap data on a dedicated digital platform. 

Employers cannot prevent employees from disclosing their own pay to enforce equal pay rights. However, the Greek law adds two provisions not found in the Directive: 

• First, employees and their representatives who receive pay data relating to other workers are bound by an explicit confidentiality obligation. 

• Second, if they breach that obligation, the employer can claim compensation for damage suffered. 

Where disclosure of pay data could identify an individual worker, access is limited exclusively to workers’ representatives, the Labour Inspectorate or the Ombudsman. Workers’ representatives or the Ombudsman may advise employees on potential claims. However, they must not disclose the actual remuneration of individual workers performing the same work or work of equal value. 

The reporting thresholds and deadlines align with the Directive: 

• 250+ employees: report by 7 June 2027, then annually. 

• 150 to 249 employees: report by 7 June 2027, then every three years. 

• 100 to 149 employees: report by 7 June 2031, then every three years. 

The Greek law specifies that all recurring reports must be submitted by 7 June of the relevant year, filling a gap left by the Directive. 

The report must cover the overall and median gender pay gaps, including: 

• gaps in supplementary or variable remuneration;  

• the proportions of women and men receiving those elements; 

• the gender distribution across pay quartiles; and  

• gaps by employee category.  

The calculations use gross annual remuneration and corresponding gross hourly remuneration for each active employee. Supplementary and variable elements are aggregated. The same methodology applies to part-time and temporary agency workers.  

For the first reporting cycle only, there is a lack of clarity regarding the reference period that applies. While on the face of the legislation the reference period seems to run from 6 July 2026 to 31 December 2026, the Ministry of Labour has unofficially stated that it will run from 1 November 2026 until 31 December 2026. It is hoped that this ambiguity will be resolved once the relevant circulars and Ministerial Decisions on the transposing law are published. Employers should look out for any further clarity from the Ministry of Labour. Failing that, employers should await publication of the relevant circulars and Ministerial Decisions which should clarify this ambiguity. It is anticipated that they will be published later this month.  

Management personnel at the employer must confirm the report’s accuracy in writing after consulting workers’ representatives. Representatives also have the right to access the methodologies used. 

Employers must also provide pay gap information to the Labour Inspectorate and Ombudsman within two months of a request. They must additionally provide historical data covering the previous four years, where available and upon request. Employers must also provide a documented response to any requests for further clarification on the report within two months. The Directive only requires responses within a ‘reasonable time’. 

Employers already preparing a corporate sustainability report may incorporate their gender pay gap disclosures into that report, rather than filing separately. They must, however, ensure the required data points are clearly identifiable and presented in accordance with the applicable European Sustainability Reporting Standards. They must also notify the Ombudsman accordingly. 

The Ministry of Labour and General Secretariat for Equality will support employers under 250 employees to meet their obligations. They will offer technical assistance, training and model pay-structure guidance. 

The Directive requires employers to remedy unjustified pay gaps ‘within a reasonable period of time.’ Greece has replaced this with concrete deadlines. 

Where pay reports reveal an unjustified gap, employers must take corrective measures within six months, in cooperation with workers’ representatives, the Labour Inspectorate and the Ombudsman.  

If the gap persists and triggers a joint pay assessment, employers must then correct the unjustified wage differences within one year of the assessment being notified. A joint pay assessment is triggered where there is a 5% or more difference in any category that has not been justified or corrected within six months. 

The joint pay assessment must examine: 

• the gender distribution of employees;  

• average pay levels;  

• the causes of identified differences; 

• the effect of parental leave; and  

• the corrective measures required.  

The employer must notify the Ombudsman and, on request, the Labour Inspectorate of the assessment. 

The Greek law introduces a dedicated administrative dispute resolution procedure before the Labour Inspectorate. The Directive has no equivalent procedure. 

In addition to the right to request pay information from their employer, an employee alleging pay discrimination can also file a complaint with the Labour Inspectorate. They can seek representation through a trade union or the Ombudsman. The employer must provide pay-setting information within 15 days. The Ombudsman is notified and issues a reasoned finding. The Inspector, who conducts the labour dispute, then makes a decision within 60 days. The employer must implement any corrective measures within six months. 

If employers fail to provide the requested information, this is treated as a failure to justify the pay difference, and any unjustified difference is presumed to be discriminatory. This reverses the practical burden of proof onto the employer. 

Where an employer is covered by a collective labour agreement that determines employee remuneration based on gender-neutral criteria, there is a presumption that no unjustified pay discrimination exists. This is a notable feature of the Greek law. However, if the Ombudsman or Labour Inspector concludes that pay discrimination is present, despite the existence of such an agreement, they must provide a specific, comprehensive and detailed justification in their findings or, as applicable, in any corrective measures imposed. 

Successful claimants are entitled to full, uncapped compensation. This covers bonuses or payments in kind, default interest, lost income and professional opportunities. It also covers damages for any intersectional discrimination. 

Violations of the pay transparency obligations are treated as violations of labour legislation under Article 572 of the Greek Labour Code. Under this article: 

• The Labour Inspectorate can impose fines ranging from EUR 300 to EUR 50,000 per violation. It considers the violation’s seriousness, the degree of fault, the business size and the number of affected employees. It also considers any aggravating or mitigating circumstances, including intersectional discrimination. 

• The Labour Inspectorate can order a temporary closure of all or part of a business after repeated high or very high severity violations. Closure may last up to three days. Four or more violations within two years can lead to closure for four or five days.  

The Labour Inspectorate may order corrective measures in cooperation with the Ombudsman. If the employer fails to implement the measures specified in the order, a recurring fine may be imposed for each three-month period of non-compliance following the implementation deadline set out in the order. The amount of the fine is determined taking into account the size of the undertaking, the seriousness of the infringement, the degree of fault, and any previous violations by the employer. 

The Labour Inspectorate must also maintain a register of employers sanctioned for violations of the equal pay principle.  

In practice, this gives the Labour Inspectorate both an enforcement and corrective role. It can impose sanctions, order remedial measures and maintain visibility of sanctioned employers. Meanwhile, the Ombudsman provides the equality-body oversight required by the Directive. 

The Greek law does not expressly transpose Article 24 of the Directive. That provision links equal pay compliance to eligibility for public contracts. This is because other existing Greek legislation already excludes employers that have committed breaches of labour legislation from participating in public procurement exercises. This includes breaches of Greece’s law transposing the EU Pay Transparency Directive.  

The transposition of the EU Pay Transparency Directive had been widely anticipated by employers in Greece. Nevertheless, certain provisions of the transposing legislation give rise to interpretative and practical challenges, creating a degree of legal uncertainty for employers. Further clarification is expected through the issuance of the relevant Ministerial Decisions, which will be instrumental in establishing a more comprehensive framework for the effective implementation and application of the new requirements.  

In the meantime, there are certain actions that employers with operations in Greece should take in the window before 1 November 2026. These can be summarised as follows: 

• Audit existing pay structures to ensure they meet the new requirements for written documentation, review procedures and clear identification of remuneration elements for each worker category. 

• Review recruitment processes to ensure pay ranges are disclosed to applicants and that salary history questions are eliminated from all stages of the hiring process, including by third parties acting on the employer’s behalf. 

• Prepare for pay gap reporting, particularly if the organisation has 150 or more employees, given the first reporting deadline of 7 June 2027. 

• Establish internal processes for handling employee pay information requests, including protocols for identifying and responding to potentially abusive requests and for managing confidentiality obligations. 

• Engage with workers’ representatives on pay evaluation criteria and the methodology for grouping employees into comparable categories.