Greece Becomes the Fifth Country to Complete Transposition
EU Member States were required to transpose the Directive into national law by 7 June 2026. Only Slovakia, Italy, Lithuania and Malta completed the process by the deadline. Greece followed 29 days later, becoming the fifth country to do so.
Despite missing the deadline, Greece moved quickly. The draft law was published for consultation on 3 June, the consultation closed on 17 June, and Parliament adopted the law on 2 July. It was published and entered into force four days later.
With the main requirements taking effect on 1 November 2026, employers operating in Greece have limited time to review their processes and prepare for the new rules.
Recruitment and Hiring Transparency
One of the most significant changes concerns recruitment.
From 1 November 2026, job applicants will have the right to receive information about the starting salary or applicable salary range before the interview. Employers must also provide details of any relevant collective agreement provisions.
Employers will no longer be permitted to ask applicants about their current or previous salary.
Clearer Requirements for Pay Structures
The law introduces clearer requirements for how employers design their pay structures and assess the value of different roles. Pay decisions must be based on objective and gender-neutral criteria to support equal pay for equal work or work of equal value.
This places greater emphasis on structured job evaluation, clearly defined roles, and documented criteria for pay-setting and pay progression. Employers must also be able to explain how roles are compared and what any differences in pay are based on.
Greater Access to Pay Information
From 1 November 2026, employees will have greater access to information about their pay. They may request written information about their own pay level and the average pay levels for groups performing the same work or work of equal value. The average pay data must be broken down by sex.
Employers must respond within two months and inform employees each year of their right to request pay information and how to exercise it.
To manage these requests effectively, employers will need clearly defined groups of comparable roles, reliable pay data, and well-established internal procedures.
Reporting Begins in 2027
Gender pay gap reporting will apply to employers with at least 100 employees. The first reporting deadline will depend on the size of the organisation:
- Employers with 250 or more employees must submit their first report by 7 June 2027 and report annually.
- Employers with 150 to 249 employees must submit their first report by 7 June 2027 and report every three years.
- Employers with 100 to 149 employees must submit their first report by 7 June 2031 and report every three years.
Employers with fewer than 100 employees may report voluntarily.
Although the reporting obligations will begin at different times, employers covered by the rules will need accurate and comparable pay data across different groups of workers.
Joint Pay Assessments
A joint pay assessment will be required where all three of the following conditions are met:
- An average gender pay gap of at least 5 percent is identified within a category of workers.
- The difference cannot be justified by objective and gender-neutral criteria.
- The gap has not been corrected within six months.
The assessment must be carried out together with employee representatives. Where unjustified pay differences are identified, the employer must take corrective action.
Greece has also introduced a specific remediation deadline. Where a joint pay assessment is required, unjustified pay differences must be corrected within one year of the Greek Ombudsman being notified of the assessment.
Stronger Enforcement and Employee Rights
The law strengthens protection in cases of pay discrimination through compensation rights, penalties, and changes to the burden of proof.
The Greek Ombudsman will be responsible for equality and oversight. A dedicated department within the Labour Inspectorate will also monitor compliance and handle disputes relating to pay discrimination.
In equal pay disputes, employers may be required to show that differences in pay are based on objective and gender-neutral criteria.
What Employers Should Prepare for
As most requirements will apply from 1 November 2026, employers operating in Greece should review:
- Recruitment processes and procedures for communicating salary information
- Pay structures and job architecture
- Job evaluation methods
- Pay-setting and progression criteria
- Procedures for handling employee requests for pay information
- Gender pay gap analysis and reporting capabilities
- HR and payroll data quality
- Documentation supporting pay decisions
Greece has now moved from draft legislation to a final national framework. Employers should use the period before November to assess how the new requirements affect their existing processes and identify which systems, procedures, and supporting documentation need to be updated.
