Greece's pay transparency law takes effect on 1 November 2026. Law 5316/2026 brings the EU Pay Transparency Directive (EU) 2023/970 into Greek law, and the Ministry of Labour explained how it applies in a circular issued on 7 October 2026. Here is what changes, who it affects and a practical checklist for the weeks ahead.
Who does it apply to?
Every private-sector employer in Greece, regardless of size. Companies with fewer than 100 employees don't have to report their gender pay gap, and so never face the joint pay assessment that can follow a report; everything else applies to them too.
The five changes that matter most
- Every employer needs written pay structures. You must be able to show how pay is set for each role, using objective, gender-neutral criteria. Skills, effort, responsibility and working conditions must be part of the assessment; seniority and soft skills can be added. If you follow a collective agreement, you can build on its job categories and pay scales.
- Candidates can ask about pay before the first interview. Applicants may request the starting salary or pay range for the role, and the relevant collective agreement terms. Job ads can no longer mention gender or family status, or use criteria that disadvantage one sex directly or indirectly.
- Employees can ask what others earn, on average. Any employee may request in writing their own pay level and the average pay of men and women doing the same work or work of equal value. You have up to two months to reply, and you must remind all staff of this right once a year.
- Larger employers must report their gender pay gap. Companies with 100 or more employees report to the Greek Ombudsman: the overall and median pay gap, the gap in bonuses and variable pay, the share of men and women in each pay quartile, and the gap per employee category.
| Employees | First report | Then |
| 250 or more | 7 June 2027 | Every year |
| 150–249 | 7 June 2027 | Every three years |
| 100–149 | 7 June 2031 | Every three years |
| Under 100 | No reporting duty | Pay structures and information rights still apply |
- Unexplained gaps trigger a joint pay assessment. If your report shows a gap of at least 5% in average pay between women and men in any category, and you can't justify it with objective criteria or fix it within six months, you must carry out a joint pay assessment with employee representatives.
Your checklist before 1 November
- ☐ List every role and group them into categories of equal or equivalent work
- ☐ Document the criteria and pay ranges for each category
- ☐ Review job ad templates for gendered language or family-status references
- ☐ Prepare a standard answer for candidates who ask about pay
- ☐ Set up a process to answer employee information requests within two months
- ☐ Plan the annual notice to staff about their right to pay information
- ☐ If you have 150+ employees, start collecting the data for your June 2027 report now
How Optimal can help
Optimal Pay, delivered with Ad Hoc Legal, starts with a diagnostic of your pay data and processes and takes you through to documented structures and reporting.
Contact us to book a diagnostic.
This article is general information, not legal advice. Last updated 11 October 2026.
