Pay transparency & equal pay between men and women: what employers need to know

On 06.07.2026 Law 5316/2026 has been published, which (a) transposes Directive (EU) 2023/970 of the European Parliament on strengthening the application of the principle of equal pay between men and women, and (b) introduces key provisions across additional areas of employment law.

I. Strengthening the application of the principle of equal pay between men and women

The legislative framework introduces pay transparency obligations, provides for enhanced legal remedies, and reinforces the supervisory role of the Labour Inspectorate Authority and the Greek Ombudsman. 

In particular:

• The Law applies to individuals employed or seeking employment in the public sector, the broader public sector and the private sector, under any type of employment relationship or engagement, including independent services agreements and salaried mandates, regardless of the nature of the services provided, as well as to self-employed professionals and individuals undergoing vocational training.
• Men and women are entitled to equal pay for equal work or work of equal value. In this context, employers are required to establish and implement pay structures ensuring compliance with this principle; such structures must, inter alia, be documented in writing and include review mechanisms.
• A pre-employment transparency obligation is introduced: job applicants are entitled to receive information on (i) the initial pay level or pay range, based on objective and gender-neutral criteria, and (ii) the applicable provisions of any relevant collective labour agreement. Such information must be provided in a timely manner—prior to the interview or, where no interview takes place, prior to the conclusion of the employment contract—through appropriate means (e.g. job advertisements, publications, professional platforms), ensuring a transparent and informed salary negotiation process. Employers are prohibited from requesting information on applicants’ salary history.
• Upon request, employers must provide employees, in writing, with information on their individual pay level and on average pay levels, broken down by gender, for comparable positions, including cases of temporary agency work. This right may be exercised directly or through employee representatives or the Greek Ombudsman, with the possibility to request additional clarifications where the information provided is incomplete or inaccurate. Employers must inform employees annually of this right and the relevant procedures, and respond within a reasonable timeframe, in any case no later than two months from the request.
• Employers with at least 100 employees must publish data on the gender pay gap at company level, including the overall and median gap, both for base salary and variable or supplementary pay components, the proportion of male and female employees receiving such pay, their distribution across pay quartiles, and pay gaps per category of employees.
• Employers must report the above information for the previous calendar year within specified deadlines depending on workforce size: by 7 June 2027 and annually thereafter for employers with at least 250 employees; by the same date and every three years for those employing 150–249 employees; and by 7 June 2031 and every three years thereafter for those employing 100–149 employees. The workforce size is calculated based on the average number of employees during the preceding calendar year. For the first reporting cycle, the reference period runs from the entry into force of the Law until 31 December 2026.
• The Greek Ombudsman is competent, inter alia, to collect joint pay assessment reports and to gather and maintain pay gap data submitted by employers in a dedicated electronic database, ensuring the prompt publication of key indicators on a user-friendly platform enabling comparisons across employers, sectors and regions, as well as the retention of historical data for up to four years.
• Employers subject to pay gap reporting obligations must carry out a joint pay assessment, in cooperation with employee representatives, where a pay gap of at least 5% is identified in any category of employees, which cannot be justified by objective and gender-neutral criteria and has not been remedied within six months from the reporting date. In the absence of a trade union, employees are represented for this purpose by the three most senior employees or by another representation mechanism of their choice.
• Any breach of the prohibition of gender discrimination or of obligations relating to equal pay and pay transparency gives rise to a right to full compensation without any statutory cap, covering material and non-material damages, including back pay, bonuses or benefits in kind, default interest, loss of income and professional opportunities, as well as damages arising from intersectional discrimination. Compensation must be effective, proportionate and dissuasive, while the burden of proof lies with the employer to demonstrate before a court or other competent authority that the principle of equal treatment has not been violated.

II. Other employment law provisions

The Law further introduces, inter alia, an explicit clarification that annual leave provisions also apply to managerial employees, thereby reinforcing the universal nature of the right. In addition, it expands the list of activities exempt from mandatory Sunday rest and public holiday restrictions, including, in particular, printing and flexible packaging production, plastics manufacturing, asphalt-based insulating materials production, basic metals production, manufacture of electrical and electronic wires and cables, fabrication of metal products (excluding machinery and equipment), tobacco products manufacturing, and the production of perfumes and cosmetic preparations.