Greece passed its transposition of Directive (EU) 2023/970 on 2 July 2026, when Parliament approved Law 5316/2026 – Strengthening the implementation of equal pay between men and women for the same work or for work of equal value and other provisions – Transposition of Directive (EU) 2023/970 – Pension provisions before its 2026 recess. The law entered into force upon publication in the Government Gazette on 6 July 2026.
While some portions of the law are in effect now, other operative compliance obligations including — Right to Information (RTI), pre-employment transparency, gender pay-gap reporting, Joint Pay Assessments, and the Labour Inspectorate’s dispute procedure — will officially take effect 1 November 2026.
What Took Effect on 6 July 2026?
A narrower set of provisions entered into force immediately upon publication:
- Amended definitions and the anti-discrimination framework, including the definitions of pay, pay level, and intersectional discrimination
- Designation of the Greek Ombudsman as the equality and monitoring body, alongside a new dedicated department within the Labour Inspectorate
- Statistics, dissemination, and various transitional and enabling provisions
Notably, the definitions of “pay” and “pay level” are now in force ahead of the obligations that rely on them. “Pay” is defined broadly to include the ordinary basic or minimum wage and any other consideration, in cash or in kind, that a worker receives directly or indirectly from employment. “Pay level” is defined as gross annual pay and its corresponding gross hourly equivalent — both aligned with the Directive.
What Is Deferred Until 1 November 2026?
The core employer-facing obligations do not take effect until November:
- Pay structures and equal-value criteria
- Pre-employment pay transparency
- Right to Information on pay levels
- Gender pay-gap reporting
- Joint pay assessments and related data protection provisions
- Remedies, penalties, compensation, and burden of proof
- The Labour Inspectorate’s pay-discrimination dispute procedure
For planning purposes, the definitions Greek employers will be measured against exist as of July, but no reporting, disclosure, or pre-hire obligation is enforceable until 1 November 2026. First reporting deadlines run on a separate track (see below).
What Does Pre-Employment and Post-Employment Transparency Require?
Effective 1 November 2026, job applicants gain the right to receive information on the position’s starting pay or applicable pay range, along with any relevant collective-agreement provisions, before an interview, or, where no interview is held, before the contract is concluded.
The law also carries a pay-history ban: employers may not ask applicants about their pay history in current or prior roles.
Collective agreements also matter at the enforcement stage. In the Labour Inspectorate’s pay-discrimination dispute procedure, unjustified pay differences are generally presumed discriminatory. But where the employer is bound by a collective agreement that sets pay by specialization using gender-neutral criteria, it is presumed that no unjustified pay discrimination exists, and the general presumption does not apply. Importantly, the presumption is rebuttable: the Ombudsman or Labour Inspector may still find discrimination despite the collective agreement, but only with specific, fully reasoned findings.
How Does Greece’s Right to Information Requirement Work?
Many of Greece’s RTI provisions closely mirror Article 7 of the Directive. Upon an employee’s request, the employer must provide in writing the employee’s individual pay level and the average pay levels, broken down by sex, for categories of employees performing the same work or work of equal value.
Key mechanics, all effective 1 November 2026:
- Response deadline: two months from the request for the core information.
- Employer refusal right: an employer may refuse requests that are “manifestly disproportionate or abusive, in particular due to its repetitive nature,” with the employee able to escalate to the Ombudsman for a ruling on the merits.
- Use restriction: employers may limit employees from using received information, other than their own pay, for purposes beyond exercising the equal-pay right, with a right to compensation for breach.
- Temporary workers: the user (indirect) employer must supply the requested information after receiving the individual pay level from the temporary work agency.
- Annual notice: employers must inform all employees annually of this right and how to exercise it.
- Accessibility: information must be provided in a format accessible to persons with disabilities.
What Are the Reporting Thresholds and Deadlines?
Gender pay-gap reporting applies to employers with at least 100 employees, averaged over the prior calendar year:
- 250+ employees: First report due 7 June 2027, then annually thereafter
- 150–249 employees: First report due 7 June 2027, then every 3 years thereafter
- 100–149 employees: First report due 7 June 2031, then every 3 years thereafter
- Under 100 employees: Reporting is voluntary, on a 3-year cadence if elected
What Triggers a Joint Pay Assessment?
A Joint Pay Assessment is triggered cumulatively where reporting shows a 5% or greater average pay difference in any category of workers, the employer has not justified the difference on objective, gender-neutral grounds, and the gap has not been remedied within six months. The assessment is conducted jointly with employee representatives, and corrective measures must follow.
Notably, Greece goes further than the Directive’s general “reasonable period of time” standard for remediation. Once a Joint Pay Assessment is triggered, employers must implement corrective measures and eliminate unjustified pay differences within one year from notification of the assessment to the Greek Ombudsman.
How Trusaic Can Help
At Trusaic, we provide employers across the EU with solutions to comply confidently with the Directive.
Our Complete EU Pay Transparency Solution enables compliant pay systems, ensures gender-neutral job evaluations, and automates complex reporting obligations to keep you one step ahead of EU pay transparency enforcement.
- PayParity® analyzes your rewards data (compensation/benefits in kind) and quickly identifies any potential unjustified inequities. It enables you to more easily comply with Article 7 (right to information) and Article 6 requirements (pay setting and progression policy).
- Our Remediation Optimization Spend Analysis (R.O.S.A.) works as PayParity’s remediation engine to find the most cost-effective way to close nominal pay gaps to ensure compliance.
- Automated RTI workflows: Our bi-directional integrations with global HCM platforms allow pay equity data to flow securely from the Trusaic platform back into the HCM. Employees can then access their RTI reports directly within their existing HR systems. This eliminates manual report generation and reduces compliance risk.
- For organizations that prefer platform-based access, RTI reports can also be generated and delivered securely through the PayParity platform, with role-based permissions and full auditability.
- Salary Range Finder® ensures equitable pay at the point of hire to prevent any increases in pay gap and enables you to easily comply with the Directive’s salary range disclosure and salary history ban requirements.
- Pay Decisions: Generate fair, competitive offers instantly from Workday.
Trusaic is GDPR compliant and can assist any organization in any EU state in meeting its obligations under both the EU Corporate Sustainability Reporting Directive and the EU Pay Transparency Directive.
Visit our always updated Member State Transposition Monitor to stay on top of the latest EU Pay Transparency Directive developments.
