Pay transparency in Greece
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Pay information requests In force
Own pay and sex-disaggregated same/equal-value category averages; CircularA.II requires active workers and consistent temporal/calculation bases for individual and comparator values. Identifiable-person data are restricted to representatives/Inspectorate/Ombudsman under Article 13, without disclosing individual coworkers' real pay. Historical/single-source comparators under Article 18 concern dispute proof, not an unrestricted information-request population.
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Time to respond 2 months
Every request starts a clock. Answering one needs pay structures and equal-value groupings that already exist.
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Salary history questions are banned
Applicants learn the pay range before the interview, and employers may not ask what they earn today.
Greece has already passed its pay transparency law. Law 5316/2026 was published on 6 July 2026 and amends the Greek Labour Law Code, so this is enacted legislation, not a proposal still working its way through parliament.
The catch is timing. Most of the employer-facing duties, including the employee pay information right, the recruitment rules, and the reporting framework, do not take effect until 1 November 2026. That gives employers a real but limited window to get ready before these become live obligations.
Reporting deadlines then stretch out further depending on company size, with the largest employers filing first and smaller ones following years later.
The measure
- Law or measure
- Law 5316/2026, strengthening equal pay through pay transparency and enforcement mechanisms
- Core obligations start
- 1 Nov 2026
- Who is covered
- Nationwide public/private framework. Core Labour Code Articles 37,56 A-56 D apply to private-sector dependent employment and the specified public-sector bodies/companies under Article 47(2); the broader equality chapter has a wider personal scope. Principal transparency duties have applied since 1 November 2026.
What the law requires
- Pay range before the interview Source for: Pay range before the interview
- Salary history questions banned Source for: Salary history questions banned
- Pay information requests, 2 months to respond Source for: Pay information requests, 2 months to respond
- Gap reporting from 100 employees Source for: Gap reporting from 100 employees
- Joint pay assessment at a 5% gap Source for: Joint pay assessment at a 5% gap
How Greece differs from the Directive
Greek law requires written, reviewable pay structures; pay progression disclosure may be omitted below 50 employees. The first 150+ report covers only 1 November-31 December 2026. JPA has default non-union representatives and a one-year corrective period after communication, distinct from the six-month trigger. Public-sector authority/publication arrangements differ from private employment.
What this means for employers
From 1 November 2026, employees in Greece will have the right to ask for their own pay level and sex-disaggregated average pay for people doing the same work or work of equal value. Employers will have two months to respond once that right takes effect. The same commencement date brings in the salary range rule for recruitment and the ban on asking candidates about their pay history.
Reporting obligations apply to employers with 100 or more employees, and employers calculate and file the figures themselves under the EU’s seven standard metrics. The largest employers, those with 250 or more staff, have the earliest deadline; employers with 100 to 149 staff have several more years before their first report is due. A 5.0% pay gap is the trigger point that leads to a joint pay assessment.
- Map your headcount against the 100-employee reporting threshold and identify which first-report deadline applies to you.
- Review recruitment practices so job postings and hiring conversations are ready for the salary range rule and the salary history ban.
- Build a response process for employee pay information requests, working to the two-month deadline.
- Watch for implementing decisions on how electronic reporting will work in practice, since these details are still to come.
Enforcement and open questions
- Competent authority
- Ministry of Labour and Social Security; Labour Inspectorate for private-sector enforcement; Greek Ombudsman as statutory equality/monitoring body. The National Transparency Authority replaces Labour Inspectorate functions for specified public-sector reporting, JPA, privacy and compliance provisions.
- Equality body
- Greek Ombudsman
- Penalties
- Article 16 applies LabourCode 572 administrative sanctions to equal-pay/transparency breaches, with aggravating/mitigating factors including intersectional discrimination. Article 17 permits compliance orders and recurring fines for each 3 months of noncompliance. Article 31 delegates specific fine calculations/amounts to ministerial decisions; no verified dedicated implementing fine schedule is recorded here.
- What could still change
- Core duties are legally live from 1 November 2026; reporting deadlines remain 2027/2031. Current ministry hub and circular status list still identify Law 5316 and Circular 26923 as applicable. Remaining gaps: exact portal/schema and public-sector implementing arrangements; detailed hours/FTE/partial-year/headcount averaging algorithms; dedicated fine decisions; procurement and litigation-cost rules. Circular drafting shorthand (JPA>100 versusstatutory≥100; a-fversusallseven toOmbudsman)must not override the statute.
Common questions
Is Greece's pay transparency law already in force?
The law itself, Law 5316/2026, was published and took effect on 6 July 2026. However, the core employer duties in Articles 8 to 20 and 27, including the pay information right and reporting rules, do not commence until 1 November 2026.
Which employers in Greece need to report pay gap data?
The reporting framework applies to employers with 100 or more employees. Employers with 250 or more staff have their first report due by 7 June 2027, while employers with 100 to 149 staff have until 7 June 2031 for their first report.
Can employers in Greece still ask candidates about their salary history?
A salary history ban is enacted under Law 5316/2026 and is scheduled to take effect on 1 November 2026. Until that date, this restriction is not yet binding.
What happens if a pay gap analysis in Greece shows a problem?
A gap of 5.0% or more triggers a joint pay assessment under the law. Penalties for non-compliance are provided through the general Labour Law Code sanction regime, though no specific euro amount is recorded for pay transparency breaches specifically.
- Pay information request right Art. 7(1)
- In force
- Response deadline Art. 7(4)
- 2 months
- Salary range in recruitment Art. 5(1)
- Yes
- Salary history questions banned Art. 5(2)
- Yes
- Joint pay assessment trigger Art. 10(1)
- 5%
Own pay and sex-disaggregated same/equal-value category averages; CircularA.II requires active workers and consistent temporal/calculation bases for individual and comparator values. Identifiable-person data are restricted to representatives/Inspectorate/Ombudsman under Article 13, without disclosing individual coworkers' real pay. Historical/single-source comparators under Article 18 concern dispute proof, not an unrestricted information-request population.
Official-source deep review3November2026. Relevant Law5316/2026andCircular26923provisions inspected; current ministry hub/status register confirms known measure. Core commencement1November2026has occurred. No universal private employerwebsite duty, annualrequestcap or fixedrolling12monthvariableperiod inferred. GR-LEGAL-DEEP-20261103-1793735857356
Read the sourceThe employer must answer in writing within this period.
Official-source deep review3November2026. Relevant Law5316/2026andCircular26923provisions inspected; current ministry hub/status register confirms known measure. Core commencement1November2026has occurred. No universal private employerwebsite duty, annualrequestcap or fixedrolling12monthvariableperiod inferred. GR-LEGAL-DEEP-20261103-1793735857356
Read the sourceApplicants receive the pay or pay range before the interview, based on objective, gender-neutral criteria.
Official-source deep review3November2026. Relevant Law5316/2026andCircular26923provisions inspected; current ministry hub/status register confirms known measure. Core commencement1November2026has occurred. No universal private employerwebsite duty, annualrequestcap or fixedrolling12monthvariableperiod inferred. GR-LEGAL-DEEP-20261103-1793735857356
Read the sourceWhether employers are prohibited from asking applicants about their current or previous pay.
Official-source deep review3November2026. Relevant Law5316/2026andCircular26923provisions inspected; current ministry hub/status register confirms known measure. Core commencement1November2026has occurred. No universal private employerwebsite duty, annualrequestcap or fixedrolling12monthvariableperiod inferred. GR-LEGAL-DEEP-20261103-1793735857356
Read the sourceThe unjustified gap that obliges the employer and worker representatives to assess pay together.
Official-source deep review3November2026. Relevant Law5316/2026andCircular26923provisions inspected; current ministry hub/status register confirms known measure. Core commencement1November2026has occurred. No universal private employerwebsite duty, annualrequestcap or fixedrolling12monthvariableperiod inferred. GR-LEGAL-DEEP-20261103-1793735857356 Cumulative conditions: category average gap at least 5%, no objective gender-neutral justification, and no correction within 6 months after reporting.
Read the source- Reporting threshold
- 100 employees
- Reporting model
- Employer-calculated / employer-filed Operational data-production and filing model for pay-gap reporting: employer-calculated, authority-calculated, hybrid, proposed, pre-existing or absent.
- First report, 250 or more employees
- By 7 Jun 2027
- First report, 100 to 149 employees
- By 7 Jun 2031
- Metrics required
- EU seven only Art. 9(1): Seven metrics: mean gap; variable-component gap; median gap; median variable gap; variable-pay participation by sex; quartile distribution by sex; category-level gap split basic and variable.
- Pre-existing regime
- Law 5316/2026 amends LabourCode provisions previously codifying Law 3896/2010 equal-treatment/equal-pay rules. New structures, recruitment, information, reporting/JPA and specified enforcement amendments commenced 1 November 2026; the earlier equal-pay baseline is distinct from these new transparency duties.
- Formal transposition stage
- Fully in force
- Scope
- Nationwide
Next milestone
Core duties have applied since 1 November 2026. Covered 150+ employers must retain 1 November-31 December 2026 data and first report by 7 June 2027;100-149 first report by 7 June 2031. Verify Ombudsman digital submission/database decision, public-sector coordination decisions and specific fine schedules under Article 31; do not wait for the reporting deadline to implement current information/recruitment duties.
Primary sources
- Law 5316/2026 — strengthening equal pay through pay transparency and enforcement mechanisms Primary source, checked 4 November 2026
- Formal transposition stage Fully in force · in force · High confidence
- Core employer obligations Fully operational · in force · High confidence
- Transposition scope Nationwide · in force · High confidence
- Salary range in recruitment Yes · in force · High confidence
- Salary history questions banned Yes · in force · High confidence
- Pay information request right Yes · in force · High confidence
- Response deadline 2 months · in force · High confidence
- Reporting threshold 100 · in force · High confidence
- First report, 250 or more employees By 7 Jun 2027 · in force · High confidence
- First report, 100 to 149 employees By 7 Jun 2031 · in force · High confidence
- Reporting model Employer-calculated / employer-filed · in force · High confidence
- Joint pay assessment trigger 5% · in force · High confidence
- Info reference period Multiple / mixed · in force · High confidence
- Info pay basis Multiple / mixed · in force · High confidence
- Info pay components scope Total remuneration / all components · in force · High confidence
- Info request frequency At any time / no stated limit · in force · High confidence
- Info employee reference period eligibility No prior-period service condition was identified; repetitive or abusive requests may be rejected under the enacted framework. · in force · High confidence
- Info normalisation method Private employment: current fixed pay annualised and expressed as gross hourly pay; variable pay uses a suitable recent actual period consistently for individual and comparator values. · in force · High confidence
- Reporting reference period Previous calendar year · in force · High confidence
- Reporting pay basis Actual remuneration paid / earned · in force · High confidence
- Reporting pay components scope Total remuneration / all components · in force · High confidence
- Reporting population basis Threshold eligibility uses previous-calendar-year average headcount including leavers, part-time/fixed-term/agency staff and continuing employees on leave. Pay averages/reporting/JPA use the circular's active-worker population; those two populations must not be conflated. User employers include assigned agency workers; agencies include unassigned periods. Legal-entity responsibility is preserved despite central group processing. · unclear · High confidence
- Reporting normalisation method Gross annual remuneration and corresponding gross hourly remuneration; supplementary/variable metrics aggregate those components rather than report each separately. The same approach applies to part-time/agency workers. The reviewed sources do not fix a complete hours divisor, FTE annualisation or partial-year scaling algorithm; do not transplant the current-rate individual-information method into historical reporting. · in force · High confidence
- Employer required input data Current fixed pay and component details; recent actual variable-pay history; sex, hours, equal-value categories and objective evaluation criteria; separate previous-year threshold headcount/leave/leaver records and active pay-comparison population; agency assignment periods; reporting legal entity; management confirmation and representative consultation. Preserve 1 November-31 December 2026 reporting actuals for 150+ first reports. · unclear · High confidence
- First data period needed First 250+ and 150-249 reports due 7 June 2027 cover 1 November-31 December 2026 under the statutory transition as clarified by CircularA.III. Later ordinary reports cover the previous calendar year;100-149 first report due 7 June 2031 therefore normally concerns 2030. Threshold headcount remains separately based on the previous-calendar-year average. · unclear · High confidence
- Own pay information Yes · in force · High confidence
- Comparator information Yes · in force · High confidence
- Comparator information start 1 Nov 2026 · in force · High confidence
- Annual average information start · unclear · High confidence
Change history
Recent updates
Greece clarifies pay-transparency calculations before the November start
An official Ministry circular explains how private employers should prepare for the 1 November 2026 commencement, including pay calculations and the short first reporting period.
This page is maintained by Evenpay from official primary sources and reviewed before publication. It is general information, not legal advice. Requirements vary by member state and change as national laws progress; figures described as proposed are subject to amendment.
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