Pay transparency in Greece from 1 November: what you can ask your employer

From 1 November 2026, anyone applying for a private-sector job in Greece must be told the pay on offer before the interview, and anyone already in a job can ask how their pay compares with that of colleagues, and get a written answer.³

On 7 October the Ministry of Labour and Social Security (Υπουργείο Εργασίας και Κοινωνικής Ασφάλισης, Ypourgeio Ergasias kai Koinonikis Asfalisis) issued circular 26923 on how these rules apply.¹ It is posted on Diavgeia (Διαύγεια), the government's online register of official decisions, under the reference number (ΑΔΑ) Λ88Δ46ΝΛΔΓ-Χ0Κ.¹ The circular explains Law 5316/2026, published in the Government Gazette (ΦΕΚ) on 6 July 2026, which brings EU Directive 2023/970 into Greek law.⁴ The law amends Greece's Labour Code (Κώδικας Εργατικού Δικαίου, Kodikas Ergatikou Dikaiou), and its pay-transparency articles take effect on 1 November 2026.⁴ The circular is addressed to employers, employees and job candidates in the private sector.³ It is signed by Nikolaos Milapidis, Secretary-General for Labour Relations.³

Before you are hired, the employer must tell you the pay

Employers must give candidates the starting pay or its range, based on objective, gender-neutral criteria.³ This must happen a reasonable time before the interview, or, if there is no interview, before the contract is signed.³ It can be given in writing or orally, by any suitable means; a job advert is one way, but not the only one.³ Candidates must also be told which provisions of a collective agreement apply to the job.³

Employers, and anyone acting for them, may not ask candidates what they were paid in current or previous jobs.³ Job adverts and job titles must be gender-neutral, with no reference to sex or family status.³

You can ask how your pay compares with colleagues'

Employees can ask for their own pay level and for the average pay, broken down by sex, of the categories of workers who do the same work as them or work of equal value.³ The employer must give the information in writing.⁴ You can ask directly, through workers' representatives, or through the Greek Ombudsman (Συνήγορος του Πολίτη, Synigoros tou Politi).³ "Pay" here means more than basic salary: it includes, in particular, allowances, supplementary or variable pay (such as bonuses or overtime), voluntary benefits, allowances for travel away from the usual workplace, and employer contributions to occupational pension schemes, in cash or in kind.³

The employer must answer within a reasonable time, and in any case within two months of the request.⁴ If the employer does not answer, or the answer is inaccurate or incomplete, you are entitled to ask for additional, reasonable clarification and details, and to receive a substantiated reply.³ Every year, employers must tell all employees about this right and the steps to use it.³⁴ Agency workers get the information from the company where they are placed, which the law calls the "indirect employer" (in our translation).⁴

An employer may refuse a request "if the request is manifestly disproportionate or abusive, in particular because of its repeated nature" (in our translation).⁴ If that happens, you can make the request through the Ombudsman, who decides whether it is justified.³

Every employer, whatever its size, must have and apply written pay structures based on objective, gender-neutral criteria.²³ Employers must make easily accessible to staff the criteria they use to set pay, pay levels and pay progression.³ Those with fewer than 50 staff may leave out only the criteria for pay progression.³

You can talk about your own pay to defend equal pay

No individual contract, collective agreement or set of work rules can stop employees from disclosing their own pay when the purpose is to uphold equal pay.³ Information you receive about colleagues' pay is treated differently.⁴ You must keep it confidential, and your employer can require you to use it only to pursue your right to equal pay.⁴ If you breach these duties, the employer can claim damages.⁴

Larger employers must report their gender pay gap

Employers with 100 or more staff must report on the gender pay gap to the Ombudsman on this timetable:³

Staff	First report due	After that (by 7 June)
250 or more	7 June 2027	every year
150 to 249	7 June 2027	every three years
100 to 149	7 June 2031	every three years

Staff numbers are the average headcount over the previous calendar year.³ The pay gap by category of worker must go to all employees and their representatives, and to the Labour Inspectorate (Επιθεώρηση Εργασίας, Epitheorisi Ergasias) and the Ombudsman on request.³ Publishing the figures more widely is optional.³

A joint pay assessment is required only when all three of these conditions are met.³ The average gap between women and men in any category of worker is at least 5%; the employer has not justified it on objective, gender-neutral grounds; and it has not been corrected within six months of the data being submitted.³ The six months run from the day the employer files, not from the deadline.³ For a report filed on the last possible day, 7 June 2027, they would end on 7 December 2027, by our calculation.³

The circular says the rules on pay structures, pay requests, pay-gap reporting and joint pay assessment also apply to the public sector, as defined in Law 4270/2014.¹ It does not explain how public-sector employees should use them.¹ The law says that in the public sector, the Labour Inspectorate's enforcement role is carried out by the National Transparency Authority (Εθνική Αρχή Διαφάνειας, Ethniki Archi Diafaneias).⁴

If you think you are underpaid

You can file a labour-dispute application (αίτηση εργατικής διαφοράς) with the Labour Inspectorate over suspected pay discrimination and ask for corrective measures.³ You can also go to court or to other administrative authorities.³ The Ombudsman is sent the application and the summons straight away and "may attend the hearing and ask for additional clarifications and information" (in our translation).³ If the employer does not give the requested information during the dispute, it is treated as having failed to justify the pay differences, and pay differences the employer does not justify are presumed to be discriminatory.³ At the complainant's request, and after first asking the employer to explain, the Inspectorate, working with the Ombudsman, can order the employer to end the breach and take corrective measures. If the employer does not comply, a recurring fine is imposed for every three months of non-compliance.⁴

If pay discrimination is alleged and the employer has not met its pay-transparency duties, the employer must prove there was no discrimination.³

The burden of proof shifts in your favour.³ If you raise a pay-discrimination claim and the employer has not met its transparency obligations, the employer must prove there was no discrimination.³ The exception is where the employer proves that its breach of the transparency duties was "manifestly unintentional and minor" (in our translation).³

Compensation must restore the person in full, covering actual loss, lost earnings and non-material damage, "without an upper limit" (in our translation).³ It includes back pay with related bonuses or payments in kind, default interest, and lost income and career opportunities.⁴ For equal-pay claims, the limitation period (the deadline for bringing a claim) does not start before you learn of the breach, or could reasonably be expected to.³⁴ You are presumed, unless shown otherwise, to know when you receive pay information through the new request right, or when the job ends.³⁴ This rule applies only to claims arising from 1 November 2026.³⁴

The law bans the employer from dismissing employees or their representatives, ending their employment in any other way, or treating them less favourably in retaliation for a complaint inside the company or for administrative or court action over equal pay.³⁴

What the documents do not say

Neither the law's enforcement article nor the circular gives euro amounts for fines.⁴ The repeated fine for ignoring an Inspectorate order is set according to the size of the business, the severity of the breach, the degree of fault and any repeat offending.⁴ Breaches count as violations of labour law under the Labour Code's general rules on administrative sanctions.³