Greece unveils draft Pay Transparency law:A new compliance agenda foremployers

On 3 June 2026, the Greek Ministry of Labour and Social Security published for public consultation a draft law entitled "Strengthening the implementation of equal pay between men and women for the same work or work of equal value - Transposition of Directive (EU) 2023/970". The consultation is open until 17 June 2026.

The draft introduces a comprehensive framework on pay transparency before recruitment and during the employment relationship, while also strengthening reporting, enforcement and remedies in relation to gender pay gaps.

While the final text may still undergo revisions before coming into force, its overall direction is clear; employers should already be taking steps to ensure compliance.

At the recruitment stage, the draft law imposes the following obligations on employers:

• must inform about the remuneration or salary range for the position

• must inform about the relevant collective labour agreement in force for the employer (if any) and

• is not allowed to request information about the candidate's previous remuneration

The above information must be provided in a manner that ensures an informed and transparent remuneration discussion, by any appropriate means and within a reasonable time before the interview or, where no interview takes place, before the conclusion of the employment contract. In practice, this information may be included in vacancy announcements, advertisements, notices or professional networking postings.

In addition, job advertisements and recruitment procedures must be:

• Gender-neutral

• Free of other discrimination

Where a collective bargaining agreement applies, the draft law provides for a presumption that no unjustified pay discrimination exists, provided that the relevant pay framework is gender-neutral. Such agreements may therefore serve as a basis for structuring remuneration. Even so, employers remain responsible for ensuring that job categories accurately reflect the value of work performed within the organisation. Compliance will be monitored primarily by the Labour Inspectorate, which retains the power to audit and impose fines, while the Greek Ombudsman is assigned a central role in monitoring, investigating and deciding on complaints relating to equal pay and pay transparency. Importantly, the burden of proof rests on the employer to demonstrate that no unjustified pay discrimination exists.

During the employment relationship, employees are entitled to equal pay for the same work or for work of equal value. For the purposes of the draft law, "pay" is defined broadly and includes not only the ordinary basic or minimum wage or salary, but also any other consideration, whether in cash or in kind, received directly or indirectly from the employer in respect of the work performed, including variable remuneration and occupational pension elements.

Employers must establish documented pay structures, which may be agreed with employee representatives where such representatives exist. These structures must be based on objective and gender-neutral criteria, allow meaningful comparisons between roles, and clearly identify the pay components applicable to each employee category. Relevant evaluation criteria may include skills, effort, responsibility, working conditions, seniority and other factors linked to the specific role, including non-technical skills. The applicable pay criteria must be easily accessible to employees and available in accessible formats for employees with disabilities. According to the draft law, employers with fewer than 50 employees are exempt from the obligation to provide information on pay progression.

Employers must provide employees, upon request, with written information on their individual pay level and on the average pay levels, broken down by gender, for categories of employees performing the same work or work of equal value. Requests may be submitted through employee representatives or through the Greek Ombudsman. If the employer does not respond within two months, or if the information provided is incomplete, inadequate or requires clarification, the employee may seek additional information directly or again through employee representatives or the Greek Ombudsman. The employer may refuse a request that is manifestly disproportionate or abusive, particularly if repetitive; in such case, the employee may refer the matter to the Greek Ombudsman, which will assess the validity of the request. Employers must also inform all employees annually of this right and of the procedure for exercising it.

Employers with at least 100 employees will be required to report the following data for their undertaking:

a) the overall gender pay gap,

b) the gender pay gap in terms of supplementary or variable remuneration elements,

c) the overall median gender pay gap,

d) the median gender pay gap in terms of supplementary or variable remuneration elements,

e) the percentage of female and male employees receiving supplementary or variable remuneration elements,

f) the percentage of female and male employees in each quartile salary bracket,

g) the gender pay gap by category of employee, broken down by usual basic salary and supplementary or variable remuneration elements.

The above information is to be calculated on the basis of gross annual remuneration, meaning the aggregate of all remuneration components, including basic salary and all additional or variable elements, together with the corresponding gross hourly remuneration for each active employee. For the purposes of the indicators relating to supplementary or variable remuneration, the aggregate amount of such elements is taken into account rather than each element separately. The same methodology applies to part-time and temporary agency workers.

The draft law sets the following reporting timetable in respect of data for the previous calendar year:

• for companies with 250+ employees, until 7th June 2027 and subsequently every year until the same date

• for companies with 150-249 employees, until 7th June 2027 and subsequently every three years until the same date and

• for companies with 100-149 employees, until 7th June 2031 and subsequently every 3 years until the same date

Employers with fewer than 100 employees may choose to submit the same information voluntarily, following the deadline applicable to employers with 100-149 employees.

The accuracy of the reported information must be confirmed by a written employer statement following consultation with employee representatives, where applicable.

The draft law also contains a transitional rule for first-time reporting by employers with 150 or more employees: for that initial cycle, the relevant reference period will run from the date the law enters into force until 31 December 2026.

The draft law also introduces a mandatory internal review mechanism for employers that are subject to pay gap reporting. Where the reported data reveals a gender pay gap for any category of employees and the difference cannot be objectively justified, the employer must take corrective action in cooperation with the Labour Inspectorate, employee representatives and the Greek Ombudsman. If the unjustified gap reaches or exceeds 5% and is not remedied within six months, a joint pay assessment procedure is triggered together with employee representatives. This assessment will examine, among other matters, the gender distribution of employees, average pay levels, the causes of the pay differences, the impact of parental leave, and the corrective measures required. The assessment must be notified to the Greek Ombudsman and, upon request, to the Labour Inspectorate. Employers must then implement the measures arising from the joint assessment and eliminate unjustified pay differences within one year from notification of the assessment to the Greek Ombudsman. For the purposes of this procedure, employee representatives are defined as the most representative enterprise-level trade union or, where no such union exists, an employee committee composed of three members in undertakings with up to 149 employees or five members in undertakings with 150 or more employees, unless another form of representation is chosen.

In assessing whether female and male workers perform the same work or work of equal value, the comparison is not confined to employees working for the same employer. It may extend to situations where remuneration is determined by a single source or body that sets the relevant pay conditions. In addition, the comparison is not limited to employees working at the same time as the employee bringing the claim.

Employees who consider that they have suffered discrimination may request pay information, initiate legal proceedings and/or seek representation through a trade union or the competent equality body, namely the Greek Ombudsman.

The draft law provides for a combination of civil and administrative consequences for breaches of the equal pay and pay transparency rules, including the following:

1. Full compensation of the victim, which covers positive and consequential damages, as well as moral damages, and aims at the full rehabilitation of the victim, without being subject to a maximum limit;

2. Administrative fines for breaches of labour legislation, ranging from EUR 300 to EUR 50,000. In the event of an infringement of rights or obligations linked to the principle of equal pay and pay transparency, the Labour Inspectorate, in cooperation with the Greek Ombudsman, may, upon request of the complainant and after inviting the employer to provide explanations, order the employer to take one or more corrective measures. If the employer fails to comply with such order, a recurring fine may be imposed for each three-month period of non-compliance, depending on the size of the undertaking. The exact scale of fines is expected to be specified by ministerial decision.

3. The employer may seek compensation from employees and employees' representatives who violate their confidentiality obligation regarding pay data.

Final Thoughts

The draft law follows the architecture of Directive (EU) 2023/970 closely and, at first reading, does not appear to depart materially from the Directive in most areas.

At the same time, the Greek proposal gives a particularly prominent role to the Greek Ombudsman, both as equality body and as a key actor in the monitoring and enforcement framework. A number of implementing details will still need to be clarified, either during the consultation process or through subsequent ministerial acts, especially in relation to procedure, reporting methodology and the practical interaction between employees, employee representatives, employers and the Ombudsman.

From a practical perspective, employers operating in Greece should already be reviewing recruitment materials, pay-setting practices, job evaluation frameworks, pay documentation and internal reporting capabilities. Particular attention should be paid to whether current remuneration structures are sufficiently objective, documented and gender-neutral, and whether the business would be in a position to explain any pay differentials by reference to legitimate criteria.

The final text of the law may still evolve during consultation, but the compliance direction is evident: pay transparency is moving from policy discussion to enforceable obligation, and early preparation will be critical.

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