What employees will be able to learn about their colleagues’ pay...

From 1 November, employees can request information on average pay levels by gender for work of equal value. Employers must justify pay differences and apply objective criteria.

What employees will be able to learn about their colleagues’ pay...

This article is an AI translation of an original piece published in Greek. Read original

The Ministry of Labour is taking a landmark step for the Greek labour market by implementing the new framework for pay transparency.

With the transposition of European Directive 2023/970, businesses are now required to operate with full transparency, establishing objective pay criteria and safeguarding the principle of equal pay for work of equal value.

The new framework is expected to curb unjustified pay discrimination, without ending rewards for individual performance and merit.

As Euro2day.gr was told by Nikos Milapidis, the Ministry of Labour’s secretary-general for labour relations:

«The implementation, from 1 November, of Law 5316/2026 on pay transparency is an important step towards a fairer and more modern Greek labour market. Pay transparency, equal pay for equal work or work of equal value, and employees’ right to information strengthen trust in employment relations and create clearer rules for employees and businesses.

The new reality requires respect for the principle of equal treatment, without discrimination on the grounds of sex or any other reason. This does not mean that pay differences based on performance will disappear. Merit is an integral part of the law».

In practice, from 1 November, Greek businesses will have to operate with “open books”, as the new pay transparency legislation gives employees the right to access information on the pay received by colleagues doing the same work.

At the same time, it requires businesses to maintain documented pay structures and introduces a process for monitoring the pay gap at larger companies.

According to the Ministry of Labour’s explanatory circular, the new framework for pay transparency and equal pay for men and women comes into force on 1 November, with Law 5316/2026 transposing European Directive 2023/970 into Greek law.

Businesses will therefore take on significant responsibility for being able to demonstrate, using objective criteria, why they pay employees doing the same or equivalent work differently.

A key change is the requirement for all employers, regardless of the number of employees, to have a written pay structure. It will no longer be enough for a business to pay different salaries simply because “that’s what was agreed”.

There must be a system that explains how roles are classified and how pay is set, in an objective and gender-neutral way.

The criteria must include, among other things, skills, effort, responsibility and working conditions, while seniority and other relevant skills may also be taken into account. Where a collective agreement applies, the categories and pay bands it sets out may be used.

In practice, the new legislation focuses not only on how much someone is paid, but also on how their salary was determined.

One important provision is the right of current employees to request, in writing, information on:

  • their own pay level,

  • average pay levels by gender,

  • the categories of employees doing the same work or work of equal value.

The employer must respond within two months.

Employers must also inform staff each year of this right and how to exercise it.

This creates, for the first time, a clear formal means of comparison: employees do not have to merely suspect that pay inequality exists; they have the right to request information to investigate it.

Businesses with at least 100 employees will have additional obligations, including reporting data on the pay gap: the overall and median pay gaps between men and women, the share of men and women receiving variable bonuses, their distribution across the quartiles of the pay scale, and the pay gap by employee category.

The requirements are scaled according to the size of the business.

Businesses with 250 or more employees will report annually, while those with 150-249 employees will report every three years. For businesses with 100-149 employees, the first report is due in 2031, with subsequent reports also due every three years.

A key date to note: the first major deadline for businesses with 150 or more employees is 7 June 2027.

This information will not simply remain in the company’s files. The data will be submitted to the Greek Ombudsman, while employees and their representatives will have the right to receive specific information on the pay gap by employee category.

The Labour Inspectorate and the Greek Ombudsman may also request the relevant data. Employers must provide it within two months, and information from the previous four years may also be requested, if available.

What happens, then, if a pay gap of more than 5% is found between men and women in the average pay level for a particular employee category?

If the gap cannot be justified by objective, gender-neutral criteria and is not corrected within six months, a joint pay assessment process will be triggered.

This will examine why the gap exists, the composition of the workforce, the variable elements of pay, whether pay rises were granted after maternity, paternity, parental or care leave, and what corrective measures should be taken. In other words, the 5% threshold is a trigger for scrutiny, not automatic proof of unlawful discrimination.

If employees believe they have been subject to pay discrimination, the law provides for judicial and administrative remedies, a labour-dispute resolution process at the Labour Inspectorate involving the Greek Ombudsman, and full redress for the discrimination by the employer.

Finally, the recruitment process will also change. Before the first interview, job applicants are entitled to be told the starting pay or pay range, based on objective and gender-neutral criteria.

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