The law entered into force on 6 July 2026, but most operational obligations - including pay information rights, recruitment transparency, gender pay gap reporting, joint pay assessments, remedies and protections against victimisation - apply from 1 November 2026. That gives employers with operations in Greece a short preparation window before the core compliance regime takes effect.

At a glance: Greece's pay transparency law

• Greece transposed the Directive through Law 5316/2026, published in the Government Gazette on 6 July 2026.
• Most employer-facing obligations and employee / applicant rights apply from 1 November 2026.
• Employers must document pay structures in writing and include review procedures, and there is a right in some circumstances to reject an employee request for pay information.
• Gender pay gap reporting deadlines broadly follow the Directive, with the first reports for employers with 150 or more employees due by 7 June 2027.
• The Greek Ombudsman is the equality and monitoring body, while the Labour Inspectorate has a central enforcement role.
• Fines range from EUR 300 to EUR 50,000 per violation.

Background

The Directive required all Member States to transpose its provisions by 7 June 2026. Only four countries met that deadline: Slovakia, Italy, Lithuania and Malta. Greece missed the deadline by just 29 days, but the speed of its legislative process was remarkable. The draft law was published for consultation on 3 June 2026, the consultation window closed on 17 June, and the final law was signed into force on 6 July.

Greece is now the fifth EU Member State to finalise its transposition, and the first in southern Europe to do so, ahead of France, Spain and Germany, none of which have published final legislation.

Key takeaways for employers

The Greek transposing law 5316/2026 closely follows the Directive, but adds Greek-specific detail in several areas, including 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, including the right to information, pay gap reporting, joint pay assessments, remedies and victimisation protections, don't apply until 1 November 2026.
• 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 elements of remuneration for each category of worker.
• Employers can refuse abusive pay information requests. The law introduces a right for employers to refuse manifestly disproportionate or abusive requests for pay information, subject to Ombudsman review. The grounds for refusal are similar to those that apply to Data Subject Access Requests (DSARs) under the General Data Protection Regulation (GDPR).
• Confidentiality obligations apply to employees who receive salary data. Employees and their representatives who receive pay information are bound by an explicit confidentiality obligation, and employers can claim compensation for any breach.
• Fixed deadlines replace the Directive's "reasonable time" standard. Greece has imposed concrete timelines: six months to remedy unjustified pay gaps identified through pay reports, and one year to correct gaps arising from joint pay assessments.
• A new administrative dispute procedure adds a layer of compliance. A dedicated Labour Inspectorate process allows employees to bring pay discrimination claims through an administrative route, with mandatory Ombudsman involvement and specific timelines.
• Penalties for non-compliance are substantial. Fines range 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 and repeat offences 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 a notable gap for businesses involved in public tenders.

When does Greece's pay transparency law apply?

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

The structural provisions of the Greek law, such as scope, definitions, institutional designations and the Ombudsman's role, took immediate effect on 6 July 2026. However, all of the operational substance, including pay transparency obligations, the right to information, pay gap reporting, joint pay assessments, remedies, burden of proof and victimisation protections, won't apply until 1 November 2026.

This four-month gap is important. It gives employers time to review and adjust their pay structures, prepare reporting processes and train their HR teams before the substantive requirements bite.

How does the Greek law compare with the Directive?

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 structures, job evaluation criteria and workers’ representatives

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 than the Directive by requiring these structures to be documented in writing, to include a review procedure, and to clearly identify the elements of remuneration for each category of worker.

Under the Greek law, “workers’ representatives” means the legal representatives of the workers’ union of the most representative trade union of the undertaking. The Directive itself leaves the definition of workers’ representatives to national law and practice, so this is a national specification rather than a deviation. 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.

The four main job evaluation criteria from the Directive - skills, effort, responsibility and working conditions - are closely transposed, with “seniority and related non-technical skills” added as examples of other relevant factors. However, the law omits the Directive's express statement that soft skills must not be undervalued.

Pay transparency in recruitment

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, or, if no interview takes place, before the employment contract is concluded. The law goes further than the Directive by requiring “documented and transparent” negotiation, and expressly refers to professional networking websites as a channel for publishing this information.

The prohibition on pay history questions is also closely transposed, and the Greek law extends it to cover “any person acting on behalf” of the employer and to apply during “all cases of communication concerning access to employment”, not just interviews.

Right to pay information and the Ombudsman's role

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. This must be provided within two months.

The Greek law adds employee representatives and the Ombudsman as alternative channels for requesting this information. It also introduces a right for employers to refuse manifestly disproportionate or abusive requests, for example where a request is repetitive. In that case, the employee can refer the matter to the Ombudsman, who will assess the validity of the request. France has recently adopted a similar approach in its updated draft, with employers not being required to respond to abusive requests. 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 has 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.

Confidentiality and restrictions on use of pay data

Employees can't be prevented from disclosing their own pay for the purpose of enforcing 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, provided that they do not disclose the actual remuneration of individual workers performing the same work or work of equal value.

Gender pay gap reporting obligations in Greece

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.

For the first reporting cycle only, the reference period seems to run from the law's entry into force (6 July 2026) to 31 December 2026, rather than a full calendar year - employers should scope their first report accordingly.

Report accuracy must be confirmed in writing by the employer's management, after consulting workers' representatives. Representatives also have the right to access the methodologies used.

The law also adds a two-month deadline for providing pay gap information to the Labour Inspectorate and the Ombudsman on request, together with a requirement to provide historical data for the previous four years, where available. Employers must also provide a documented response to any requests for further clarification on the report within two months (while the Directive only says 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, provided the required data points are clearly identifiable and presented in accordance with the applicable European Sustainability Reporting Standards, and the Ombudsman is notified accordingly.

Smaller employers (under 250 employees) can expect technical assistance, training and model pay-structure guidance from the Ministry of Labour and the General Secretariat for Equality to help them meet their obligations.

Deadlines for correcting unjustified pay gaps

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 (which is required where there is a 5% or more difference in any category that has not been justified or corrected within six months), employers must then correct the unjustified wage differences within one year of the assessment being notified.

Where there is no trade union, employees are represented for joint pay assessment purposes by the three most senior employees, unless they choose another form of representation.

Labour Inspectorate dispute procedure for pay discrimination

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

An employee alleging pay discrimination can file a complaint with the Labour Inspectorate. 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, and any corrective measures must be implemented within six months.

Failure by the employer to provide the requested information is treated as a failure to justify the pay difference, and any unjustified difference is presumed to be discriminatory, reversing the practical burden onto the employer.

A notable additional feature is that 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. 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.

Employees who successfully bring an equal pay or pay transparency claim are entitled to full, uncapped compensation, covering bonuses or payments in kind, default interest, lost income and professional opportunities, as well as damages for any intersectional discrimination.

Penalties and sanctions

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

• fines range from EUR 300 to EUR 50,000 per violation and are imposed by the Labour Inspectorate, taking into account factors such as the seriousness of the violation, the degree of fault, the size of the business, the number of employees affected, and any aggravating or mitigating circumstances, including intersectional discrimination; and

• in cases of repeated high or very high severity violations, the Labour Inspectorate can order a temporary closure of all or part of a business for up to three days (or four to five days for four or more violations within two years). In the most serious cases, permanent closure can be recommended.

Under the Greek law, corrective measures may be ordered by the Labour Inspectorate, 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 is also required to maintain a register of employers who have been 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, while the Ombudsman provides the equality-body oversight required by the Directive.

Public procurement and equal pay compliance

The Greek law does not transpose Article 24 of the Directive, which would link equal pay compliance to eligibility for public contracts and potentially exclude operators with a pay gap of 5% or more. This is a significant gap, particularly for businesses that bid for public contracts in Greece.

What should employers do now?

Employers with operations in Greece should use the window before 1 November 2026 to:

• 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.

For the latest developments on how EU Member States are transposing the Directive, visit our EU Pay Transparency Directive Hub.