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Final legislation to transpose the EU Pay Transparency Directive in Greece

August 07, 2026

Law 5316/2026, transposing the EU Pay Transparency Directive (2023/970) into local law, was published in the Official Gazette on July 6, 2026. Most obligations will take effect on November 1, 2026, and apply to all public- and private-sector employers, with certain reporting requirements limited to companies with 100 or more employees. Although the legislation closely follows the directive's provisions, it also introduces some deviations from, and additions to, the directive.

Greece's Pay Transparency Directive legislation: Governance framework

Provision and timingGreeceAlignment with the directive
Category of workerCategory of worker is defined as employees performing the same work or work of equal value and who are grouped by their employer according to objective gender-neutral criteria, including skills, responsibility, effort and working conditions.Aligned with the directive
Transparency prior to employment
Compliance from: November 1, 2026
Employers are required to provide information on the initial pay or pay range for the role, as well as any applicable collective bargaining agreement (CBA), before interviewing candidates or before concluding the employment contract, if interviews do not take place. Information may be provided by any appropriate means, in writing or orally.
Employers, or other persons acting on their behalf, are prohibited from inquiring into job applicants' current salary or salary history.
Aligned with the directive except for timing
Transparency on pay criteria
Compliance from: November 1, 2026
Employers are required to make information on the criteria used to determine pay and benefit levels and pay progression (which must be objective and gender-neutral) easily available to workers.
The requirement on pay progression does not apply to organizations with fewer than 50 employees.
Aligned with the directive except for timing
Employee right to information
Compliance from: November 1, 2026
Employees are entitled to request information on their individual pay level and average pay levels, broken down by gender, for workers performing the same work or work of equal value. The information must be provided within two months from the date of the request. Companies may refuse requests that are disproportionate or abusive (e.g., repetitive).
Employers are required to inform employees annually of their right to this information and how to obtain it.
Aligned with the directive except for timing
Gender pay gap reporting
First compliance by: June 7, 2027
Organizations with 100 or more employees are required to report periodically on gender pay gaps by entity and by category of worker. Entities with 100 to 249 employees report every three years; those with 250 or more employees report annually. Information must be provided to employees and employee representatives; upon request, it must also be provided to the public authority responsible for equality enforcement and monitoring of pay transparency compliance (Greek Ombudsman) and the Labor Inspectorate.
Reporting commences on June 7, 2027, for entities with 150 or more employees and on June 7, 2031, for those with 100 to 149 employees.
Aligned with the directive
Pay gap assessmentsWhere gender pay gaps of 5% or more are identified at the category of worker level and cannot be justified on objective, gender‑neutral grounds or corrected within six months, employers must conduct joint pay assessments in cooperation with employee representatives and adopt corrective measures within one year. In the absence of trade union delegates, workers are represented by the three employees with the longest service, unless a different representation method is chosen by workers.Exceeds the directive in specifying a timeline to implement corrective measures
Pay structures 
Compliance from: November 1, 2026
Employers must establish and document remuneration systems, based on objective gender-neutral criteria, that clearly identify the remuneration elements of each category of workers and enable a comparison of jobs and worker categories. Criteria must be agreed with employee representatives (if any) and should include responsibility, skills, effort, working conditions, and any other factor considered relevant such as seniority and non-technical skill.
Employers may use CBA classifications, if applicable to them.
Exceeds the directive in requiring pay structures to be documented in writing
Other matters (including penalties)A new administrative dispute resolution before the Labor Inspectorate is introduced for alleged pay discrimination. 
Violations constitute labor law violations subject to administrative sanctions under Article 572 of the Labor Code; the method and amount of fines for pay transparency violations will be further specified by ministerial decision.
Aligned with the directive

Employers should prepare to implement the pay transparency legislation, including revising existing pay structures and establishing reporting systems to support compliance. Greece had an unadjusted gender pay gap of 13.4% as of 2024, compared with the EU average of 11.1% (Eurostat data).

Contacts

Michael Zeler

Head of CEE, Work, Rewards & Career, Central and Eastern Europe

Evgenia Zartaloudi

Consultant, Work, Rewards & Career, Central and Eastern Europe

Topic

Pay Transparency Legislation