The new Greek Equal Pay Framework: Key takeaways from Law 5316/2026 on Pay Transparency 

Pay transparency is about to become a day-to-day reality in the Greek labour market. Law 5316/2026, which transposes the EU Pay Transparency Directive (EU) 2023/970, was published in the official Government Gazette on 6 July 2026, but its core pay transparency provisions were deferred until 1 November 2026. On 7 October 2026, the Ministry of Labour and Social Security also issued an implementing circular that clarifies key practical points and includes a sample pay structure that businesses can adapt. The new framework reshapes the relationship between employers, employees and job candidates, creating new obligations on one side and enforceable rights on the other. Below, we outline its key features. 

Written Pay Structures 

The cornerstone of the framework is the pay structure, which every employer must adopt, regardless of size. It must be in writing and determine pay on the basis of objective, gender-neutral criteria, covering at minimum skills, effort, responsibility and working conditions. It must also enable different roles to be compared, set out the pay components for each employee category and provide for a review procedure. Where a collective labour agreement applies, its job classifications and pay scales may be relied upon. Once the structure is in place, employees are entitled to easy access to the criteria used to determine pay, pay levels and pay progression; in businesses with fewer than 50 employees, however, the pay progression criteria need not be disclosed. 

Transparent and Gender-Neutral Recruitment 

Transparency begins at the recruitment stage. Job advertisements, announcements and any other documents used in the hiring process must be gender-neutral and must not give rise to gender discrimination. Candidates are entitled to be informed of the starting pay or pay range for the role, as well as any relevant terms of the applicable collective labour agreement, in good time before the interview (or, where there is no interview, before the employment contract is signed), for example in the job advertisement. Candidates may also no longer be asked about their current or previous pay. 

Employees’ Right to Information 

Throughout the employment relationship, employees may request, either directly or through their representatives or the Greek Ombudsman, information on their individual pay level and on the average pay levels, broken down by gender, of colleagues performing the same work or work of equal value. Employers must respond in writing within two months at the latest. Where the information provided is inaccurate or incomplete, the employee is entitled to request further clarification. Manifestly excessive or repetitive requests may be refused, in which case the employee may refer the matter to the Ombudsman. Employers must also remind all staff of this right annually, and no employment contract, collective labour agreement or workplace regulation may prevent employees from disclosing their pay for the purpose of enforcing the principle of equal pay. 

Gender Pay Gap Reporting 

In addition to the rules above, which apply to all employees, businesses with 100 or more employees must report gender pay gap data to the Greek Ombudsman and share the pay gap per employee category with their employees and employee representatives. Reporting deadlines depend on headcount: 

• Employers with at least 250 employees: by 7 June 2027, and annually thereafter. 
• Employers with 150 to 249 employees: by 7 June 2027, and every three years thereafter. 
• Employers with 100 to 149 employees: by 7 June 2031, and every three years thereafter. 

Reporting is intended to drive real change. Where a report reveals a gap of 5% or more in any employee category that cannot be justified on objective, gender-neutral grounds and has not been remedied within six months, a joint pay assessment must be carried out with the employee representatives, and any unjustified gaps must be rectified within one year. 

Enforcement and Remedies 

Breaches of the pay transparency obligations constitute violations of labour law and are subject to administrative sanctions; they may also give rise to claims for compensation. The Labour Inspectorate, in cooperation with the Greek Ombudsman, may also order corrective measures and impose recurring fines for every three months of non-compliance with such an order. 

The framework also has significant procedural implications. In pay discrimination disputes, where an employer has failed to meet its transparency obligations, the burden of proof shifts to the employer to show that there was no discrimination, unless the failure was manifestly unintentional and minor. Conversely, where a collective labour agreement sets pay per speciality on the basis of gender-neutral criteria, there is a rebuttable presumption that no unjustified pay discrimination exists. 

Looking Ahead 

The new framework marks a shift from pay confidentiality towards pay openness in Greece. For businesses, this means putting the necessary processes in place and aligning HR, legal and payroll functions to support ongoing transparency and reporting. For employees and candidates, it brings new tools to understand and challenge pay decisions. 

For any questions on these or other legal developments, please contact the Zepos & Yannopoulos Employment, Immigration & Global Mobility team.