Law 5316/2026, which transposes Directive (EU) 2023/970 on pay transparency into Greek law and strengthens the application of equal pay between men and women for equal work or work of equal value, was published in the Government Gazette on 6 July 2026. The new framework introduces significant pay transparency obligations for employers and establishes new enforcement mechanisms designed to close the gender pay gap. This newsletter outlines the law’s key provisions and highlights the main practical implications for employers.
Scope
The pay transparency framework applies to all individuals employed or seeking employment in the public and private sectors, including job applicants.
Enhanced anti-discrimination framework
The new Law expands the existing anti-discrimination framework by expressly recognising intersectional discrimination, namely discrimination based on gender in combination with other protected characteristics such as race, ethnicity, religion, disability, age, or sexual orientation.
Pay transparency obligations
Pay structures: Employers must maintain documented, gender-neutral pay structures ensuring equal pay for equal work or work of equal value, assessed against objective criteria such as skills, effort, responsibility, and working conditions. These criteria must be developed in agreement with employee representatives, where such representatives exist, and the criteria used to determine pay, pay levels, and pay progression must be made easily accessible to employees. Employers with fewer than 50 employees are exempt only from the obligation to make information relating to pay progression accessible.
Pre-employment transparency: Job applicants are entitled to receive information on the initial salary or salary range, as well as any applicable collective labour agreement provisions, before a job interview or, where no interview takes place, before concluding an employment contract. Employers are also prohibited from inquiring about applicants’ pay history and must ensure that job vacancy notices and job titles are gender-neutral.
Right to pay information: Employees may request written information on their individual pay level and on average pay levels, broken down by gender, for employees performing equal work or work of equal value; employers must respond within two months. Contractual clauses that prevent employees from disclosing their pay in order to enforce equal pay rights are prohibited.
Gender pay gap reporting
Employers with at least 100 employees must report detailed gender pay gap data for the previous calendar year, including the overall and median gender pay gap, the overall and median gender pay gap in complementary and variable pay components, the proportion of male and female employees receiving complementary or variable components, quartile pay band gender distribution, and the gender pay gap per employee category. Reporting deadlines vary by employer size:
Employers with at least 250 employees must report by 7 June 2027 and annually thereafter;
Employers with 150–249 employees must report by 7 June 2027 and every three years thereafter;
Employers with 100–149 employees must report by 7 June 2031 and every three years thereafter.
Employers with fewer than 100 employees may report voluntarily. Reported data are communicated to the Greek Ombudsman and may be published by the employer on its website or through other means.
Joint pay assessment
Employers subject to gender pay gap reporting obligations must conduct a joint pay assessment in cooperation with employee representatives where: (a) a pay gap of at least 5% exists in any employee category; (b) the employer has not justified the gap on objective, gender-neutral grounds; and (c) the gap has not been corrected within six months of reporting. Employers must implement corrective measures arising from the joint assessment within one year.
Remedies and sanctions
In cases of equal pay violations, the Labour Inspectorate may impose administrative fines and, in cooperation with the Greek Ombudsman, order the employer to cease the violation and take corrective measures. Non-compliance triggers recurring quarterly fines, with aggravating factors applied in cases of intersectional discrimination. Affected employees may also claim uncapped compensation from the employer, covering actual damages, lost income, and moral damages.
The burden of proof shifts to the employer in cases of alleged pay discrimination, including where pay transparency obligations have not been met.
Protection against retaliation
Dismissal or any other adverse treatment of employees or their representatives in response to complaints or proceedings related to enforcing equal pay rights is expressly prohibited.
Monitoring authorities
The Greek Ombudsman is designated as the equality body and monitoring authority for equal pay and pay transparency in both the public and private sectors. A dedicated unit is also established within the Labour Inspectorate to monitor equal treatment and equal pay. A new dispute resolution procedure is introduced for alleged pay discrimination, requiring a reasoned opinion from the Ombudsman before a decision is issued.
Government support for small-scale employers
The Ministry of Labour and the General Secretariat for Equality and Human Rights, in cooperation with social partners, will provide technical assistance, training, guidelines, and model pay structures to employers with fewer than 250 employees, and to their employee representatives, to facilitate compliance with these obligations.
Other provisions
In addition to transposing Directive (EU) 2023/970, Law 5316/2026 introduces a number of further employment provisions. In the area of collective labour relations, a Digital Registry of Collective Labour Agreements is established within the ERGANI II information system, and access to the ERGANI II system is expanded. Employees’ remote access to the Labour Inspectorate for resolving labour disputes is also facilitated. In the field of individual labour law, the law clarifies that managerial employees are entitled to annual leave and further extends the list of business sectors permitted to operate on Sundays and public holidays.
Entry into force
The new Law defers pay transparency obligations to 1 November 2026, while its other provisions apply from 6 July 2026.
How we can help
For guidance on complying with the new pay transparency obligations, please contact our Employment, Immigration & Global Mobility team.