Greece implements the Gender Pay Transparency Directive with some gold-plating

At a glance

• Following a burst of legislative activity in recent weeks, Greece has enacted Law 5316/2026 to implement the Gender Pay Transparency Directive (Directive), with most employer obligations taking effect from 1 November 2026.
• Employers will be required to maintain written pay structures, support pay decisions with objective criteria and comply with new transparency requirements during recruitment and employment.
• The legislation provides employees with rights to request pay information, although employers may refuse requests that are repetitive or manifestly excessive, subject to review by the Greek Ombudsman.
• Larger employers will be subject to gender pay gap reporting obligations, with the first reporting deadlines beginning in June 2027 for employers with 150 or more employees. 
• Greece has introduced strict enforcement mechanisms, including mandatory remediation periods for unjustified pay gaps, administrative dispute resolution procedures and fines of up to EUR50,000 per infringement.

With remarkable speed - going from consultation on a draft bill, to final legislation being in force in the space of just over a month - Greece has implemented the Directive. The legislation entered into force on 6 July 2026; however, most of the new obligations will apply from 1 November 2026, giving employers a small period to prepare.

While the new framework largely mirrors the Directive, it includes several employer-friendly and country-specific provisions. In particular, employers should note that:

• Employers will be required to maintain written pay structures, clearly show the remuneration components applicable for each category of workers.
• Employers may refuse pay information requests that are considered manifestly excessive or abusive, subject to review by the Greek Ombudsman.
• The legislation introduces express confidentiality obligations for individuals who receive pay data.
• The law establishes gender pay gap reporting obligations in line with the Directive, with the first reports due in 2027 for employers with at least 150 employees.
• There are specific deadlines for addressing unjustified pay gaps including those identified by joint pay assessments.
• A new dedicated administrative procedure has been created through which employees can pursue pay discrimination complaints. 
• Non-compliance may result in significant sanctions, with fines ranging from EUR300 to EUR50,000 per infringement and additional enforcement measures for repeated breaches.

Employers with operations in Greece should use the period to November to review pay structures, recruitment practices, reporting processes and procedures for handling employee requests for pay information.