Pay Transparency in Greece: How key obligations impact your organization and how to prepare

Pay transparency is rising steadily on the European and national agenda. With the introduction of the EU Pay Transparency Directive [and corresponding Greek Law 5316/2026, which transposed Directive (EU) 2023/970 into Greek Law, issued on 6 July and coming into effect as of 1 November 2026], the principle of equal pay for equal work or work of equal value is strengthened and transparency obligations for employers are enhanced. The new framework is expected to have a significant impact on how organizations manage remuneration, job architecture, recruitment, career progression, HR data and gender pay-gap reporting. 

Employers are required to provide more insight into their remuneration policies and to actively investigate pay differences between men and women. This requires more than just signaling: organizations must be able to explain differences and correct them where necessary. 

Pay transparency is no longer solely an HR or compliance topic. It is becoming a broader strategic, governance and data challenge, requiring coordination across HR, Legal, Compliance, Finance, Data & Technology, Internal Audit and Senior Management. Equal pay thus becomes a topic for which employers must demonstrably take responsibility.

Most of the substantive obligations take effect on November 1, 2026. Taken together, these obligations require a coordinated response across several functions. The practical consequence is that readiness cannot be achieved by any single function acting alone, and it needs to be substantially in place before November 1, 2026, well ahead of the first gender pay gap filing deadline in June 2027, since the burden of proof, uncapped compensation and new dispute routes are all live from that earlier date.

Key obligations at a glance

1. Pay transparency in recruitment

Effective: November 1st, 2026
Applies to: All employers, regardless of size; no headcount threshold.

• Candidates must receive information on the initial pay or pay range for a position, based on objective and gender-neutral criteria, in interviews or elsewhere in the hiring process. 
• Employers are also prohibited from asking candidates about their previous or current salary history.
• Job titles and postings must be gender-neutral.

2. Transparent pay-setting and career progression

Effective: November 1st, 2026
Applies to: All employers, regardless of size. Employers with fewer than 50 employees are exempt from the pay-progression disclosure limb.

• Employers need objective, gender-neutral criteria for determining pay levels and, where applicable, pay progression. 
• These criteria should be documented and accessible to employees.

3. Employee right to information

Effective: November 1st, 2026
Applies to: All employers, regardless of size; no headcount threshold.

• Employees will have the right to request information regarding their individual pay and average pay levels, broken down by gender, for comparable categories of employees performing the same work or work of equal value.
•  Employers shall reply to the employees within 2 months from the date the request was received.
• Confidentiality clauses that prevent staff from discussing their own pay for equal-pay purposes are no longer enforceable.

4. Gender Pay Gap Reporting

Effective: First report due June 7th, 2027 (≥150 employees) or June 7th, 2031 (100–149 employees)
Applies to: Mandatory for employers with 100+ employees – see table below

• Eligible employers are required to calculate and report defined gender pay-gap metrics.

Reporting requirements and frequency have been set as below: 

5. Action on unexplained pay gaps

Effective: November 1st, 2026
Applies to: In practice, employers with 100+ employees; a smaller employer that reports voluntarily could also be captured.

• Where a significant gender pay gap is identified (a 5% threshold has been set) within an employee category and cannot be objectively justified by gender-neutral factors, employers may be required to undertake a joint pay assessment and take corrective action.

Why should Organizations act now? 

Pay transparency can create challenges across multiple dimensions of the organization.

Regulatory & Legal Risk

Failure to comply with transparency and equal-pay requirements may expose organizations to legal claims, enforcement action and financial consequences.

Remuneration Risk

Inconsistent or insufficiently documented pay-setting practices may make it difficult to demonstrate that pay differences are objectively justified.

Data & Technology Risk

Organizations may not currently have the data quality, systems or analytical capabilities required to produce accurate pay-gap analysis and respond to employee information requests.

HR & Operating Model Risk

Existing job architecture and employee classification may not adequately support the identification of employees performing the same work or work of equal value.

Employee & Reputation Risk

Increased transparency may lead to greater employee awareness of remuneration differences and potentially increase workforce expectations and employee relations risks.

Our approach

We support companies across the full implementation lifecycle, from initial diagnostic and readiness assessment through to ongoing monitoring and reporting. Our team, comprising experts across multiple areas of expertise, works in close collaboration and coordination with your organization's different departments to help you navigate and comply with the new legal requirements. We scale and tailor our approach to your organization's specific starting point, ensuring you receive exactly the support you need.