Currently there is only a draft law transposing the Directive (EU) 2023/970 into Greek law. The draft law was submitted to the Greek Parliament on 24/6/2026. While the bill has not yet been voted on and therefore remains subject to possible amendments during the legislative process, according to unofficial information by the Ministry of Labour and Social Security, it is expected to be enacted in early July.

The draft bill transposes the Directive into Greek legislation by amending the Labour Code (Presidential Decree 62/2025) and Law 3094/2003. Key provisions include:

• Obligation for employers to have in place gender-neutral pay structures;

• Pre-employment pay transparency: job applicants must be informed of the initial pay or pay range prior to interview; prohibition on salary history enquiries;

• Job vacancy notices and job titles must be gender-neutral;

• Workers' right to request (in writing) information on their individual pay level and average pay levels broken down by sex for comparable categories of workers;

• Annual employer obligation to inform workers of their right to request pay information;

• Gender pay gap reporting obligations for employers with ≥100 workers, covering seven categories of data (overall gender pay gap, median gender pay gap, quartile pay bands, pay gap per category of workers, etc.);

• Joint pay assessment obligation;

• Data protection rules for pay information;

• Full compensation for victims (no upper cap), reversal of burden of proof, shift in limitation period (running from the date the worker knew or could reasonably have known of the breach);

• Prohibition of victimisation of workers and workers' representatives;

• Designation of the Greek Ombudsman (“Synigoros tou Politi”) as the equality body and monitoring body, with significant new powers;

• Establishment of a dedicated Equal Treatment and Equal Pay Unit within the Labour Inspectorate;

• Dedicated labour dispute procedure before the Labour Inspectorate for alleged pay discrimination cases.

Strengthening the application of the principle of equal pay between men and women for equal work or work of equal value and other provisions - Transposition of Directive (EU) 2023/970 - Pension provisions

Please note that, at this stage, no official English translation of the draft bill is available. We have, however, prepared a translation of the draft, for your information. 

Ib. the date it comes into force, and the date from which employers must comply with the implementing legislation (if different); 

Implementing legislation has not yet entered into force. The draft bill must first be voted upon by the Greek Parliament. No entry-into-force date has been confirmed.  The specific effective dates from which employers must comply with the implementing legislation will be established upon enactment of the final legislation. Based on the current draft of the law, it appears that no confirmed compliance date is currently available for the general obligations. These obligations (including pre-employment pay transparency and individual rights to pay information) will apply upon entry into force of the law.

For gender pay gap reporting, phased deadlines apply based on employer size. Employers with 150 or more employees must submit their first report by 7 June 2027, while employers with 100 - 149 employees must submit their first report by 7 June 2031. Employers with less than 100 employees may submit their first report by 7 June 2031 on a voluntary basis.

A Greece-specific transitional rule applies for employers with at least 150 employees. For these employers, the reference period for the first report runs from the date of entry into force of the law until 31 December 2026.

The draft bill largely mirrors the Directive. A notable addition concerns temporary/agency workers, for whom specific obligations are imposed:

(A) End user’s obligations:

• The end user must include TEA employees placed with it in its gender pay gap report.

(B) TEA’s obligations:

• Provide the end user, without undue delay, with total remuneration data for all placed workers to enable accurate pay gap reporting. If it fails to do so, the end user may apply to the Labour Inspectorate for administrative sanctions to be imposed on the TEA.

• Include in its own pay gap report any temporary worker not currently placed with an end user.

Further, the draft bill introduces a dedicated labour dispute procedure before the Labour Inspectorate specifically for cases of alleged direct or indirect pay discrimination. Key features include a reversed burden of proof, the involvement of the Greek Ombudsman, a presumption of discrimination where the employer fails to provide requested pay information, and the authority of the Labour Inspector to order corrective measures within six months. 

Greece already has a legislative framework prohibiting pay discrimination on grounds of sex, transposing Directive 2006/54/EC on equal treatment of men and women in employment.

The draft bill amends and supplements the existing aforementioned Labour Code provisions, strengthening the existing prohibition of pay discrimination rather than replacing it. 

Upon entry into force of the draft law, the amended Labour Code will constitute the single applicable framework.

IAdditional secondary legislation is expected to be published.

The draft Law provides that ministerial decisions will define the support measures available to employers and the methodology and level of fines for breaches. A separate joint ministerial decision will regulate the creation and operation of the Greek Ombudsman’s digital platform, including its interoperability with the ERGANI II employment information system.

No timeline has been confirmed for the adoption of these instruments

The general scope of the draft law broadly includes persons employed or seeking employment in the public, wider public and private sectors, under any form of work relationship or engagement, including contracts for work, paid mandates, self employed professionals and persons in vocational training.

However, the specific pay transparency, pay reporting and joint pay assessment obligations apply only to employers and workers in a dependent employment relationship. In this respect, the draft law follows the Directive’s approach without local variation.

Note: Greek labour law does not distinguish between blue-collar workers and white-collar employees; both categories are treated as employees under the same legal framework.

The draft law sets out the requirements that pay structures must meet. Specifically, pay structures must:

• be based on objective and gender-neutral criteria, including at minimum the criteria on skills, effort, responsibility and working conditions;

• allow for the comparative assessment of jobs and categories of workers so that compliance with the principle of equal pay can be verified;

• be documented in writing and provide for a review procedure;

• clearly identify the elements constituting pay for each category of workers; and

• be applied in an objective and gender-neutral manner.

Further, the Regulatory Impact Assessment (RIA), provides that a "pay structure" means the set of rules, classifications, criteria and procedures by which remuneration is determined, organised and managed within an organisation, organisational structure or undertaking, including gender-neutral job evaluation and classification systems. Pay structures are not limited to a simple record of remuneration, but constitute a comprehensive remuneration policy framework capable of enabling the objective and transparent assessment of the comparability of jobs and preventing gender-based discrimination. The key characteristics of the pay structure, the grouping and classification of jobs, the evaluation methodologies and criteria, and their application must be made directly and easily accessible to employees.

The draft law defines “work of equal value” as work determined to be of equal value based on impartial, objective and gender-neutral criteria.

The concept is introduced into Greek law for the first time by the draft law. The determination must be made at the level of the individual employer and must apply to all workers employed by that employer.

Minimum factors include skills, effort, responsibility and working conditions. Additional relevant factors, including seniority, may also be taken into account, provided all criteria are objective and gender-neutral.

Employers must provide job applicants with: (i) the initial remuneration or pay range for the role, based on objective and gender-neutral criteria; and (ii) the relevant provisions of any applicable collective agreement.

The draft law does not provide a specific list of pay components for the purposes of the “initial pay range” disclosed to job applicants. 

However, the draft law defines "pay" as the ordinary basic or minimum wages or salaries and any other consideration, in cash or in kind, which a worker receives directly or indirectly (including complementary or variable components) as consideration for employment. This definition mirrors the Directive without local variation.

This information is provided in such a manner so as ensure informed and transparent negotiation on pay, by any appropriate means, in writing or orally, within a reasonable time before the interview for the position or, if no interview is conducted, before the conclusion of the employment contract - for example, in job postings, announcements, calls and publications on professional networking websites.

Not expressly provided, but likely yes.

The draft law applies to all “persons seeking employment” without distinguishing between internal and external candidates. Internal applicants for advertised positions should therefore be covered, although this is not expressly clarified and may be addressed in secondary legislation.

The draft bill does not explicitly address whether employers may use salary history information already in their possession when determining pay for internal hires or promotions.

The prohibition is limited to asking job applicants about their salary history - it does not expressly prohibit employers from relying on salary history data they already hold.

Yes. Employers must ensure that job vacancy notices, advertisements, vacancy notices, and professional networking website postings as well as job titles used in recruitment are gender-neutral and that recruitment processes are conducted in a non-discriminatory manner. Where gender-specific terms do not exist in Greek, a neutral term must be used. This reflects the Directive, with a language-specific adaptation

Employers must: 

• make pay information criteria easily accessible to workers, 

• provide the criteria used to determine remuneration, pay levels and pay progression (these criteria must be objective and gender-neutral), 

• maintain and apply written pay structures based on at least the criteria set out in the Labour Code (skills, effort, responsibility and working conditions). These structures must enable the comparative assessment of job positions and categories of workers, so as to allow verification of compliance with the principle of equal pay and be applied in an objective and gender-neutral manner.

No specific medium is prescribed.

The relevant criteria must be easily accessible to workers. Pay structures must be documented in writing. Information must be provided in accessible formats for persons with disabilities.

The draft bill sets out the criteria that employers must use when determining pay, pay levels and pay progression. These criteria must be:

• objective and gender-neutral;

• agreed with workers' representatives, where such exist; and

• based on the following factors: skills, effort, responsibility and working conditions, as well as any other factor deemed relevant to the specific job or position, including by way of example seniority and relevant non-technical skills.

No further clarification regarding the "objective and gender-neutral criteria" is included.

Yes. Employers with fewer than 50 employees may choose not to apply the obligation to inform workers about pay progression criteria. This reflects an option clearly provided by the Directive and is not a Greece-specific policy choice beyond the exercise of that option. All other pay structure and transparency obligations apply to all employers regardless of size.

The draft law defines "pay" as the ordinary basic or minimum wages or salaries and any other consideration, in cash or in kind, which a worker receives directly or indirectly (including complementary or variable components) as consideration for employment. This definition mirrors the Directive without local variation.

No provision specific definition is provided.

In addition, according to the RIA, "pay" includes, in particular, basic salary, allowances, supplementary or variable pay, voluntary benefits, compensation for business travel, and employer contributions to occupational pension schemes. For the purposes of the pay transparency measures set out in the draft law, including, inter alia, the provision regarding right to pay information,"pay" means the elements constituting the gross earnings received by employees during the relevant reporting period.

The draft bill does not explicitly provide for the exclusion of any pay components from the calculation of gross hourly pay.

Information must be provided within a reasonable period and, in any case, within two months of the request.

Information must be provided in writing. All information must be provided in a format accessible to persons with disabilities, taking into account their particular needs.

No exceptions provided based on headcount.

Yes. Workers may request pay information through all three channels:

• individually;

• through workers' representatives; and

• through the Greek Ombudsman, which is designated as the equality body under the draft bill.

Workers have a right to request clarifications. Where information is inaccurate or incomplete, workers may request - personally, through representatives, or through the Greek Ombudsman - additional reasonable clarifications and details and must receive a reasoned response.

Yes. Employers must inform workers, annually, of their right to request pay information and the steps required to exercise that right.

Not expressly specified.

There is no requirement to provide information in Greek, nor a prohibition on providing it in English.

In practice, information is expected to be provided in Greek, given the local legal and employment context. Employers operating internationally may wish to provide bilingual documentation as a matter of prudent compliance.

Individual employment contracts, collective agreements or works rules cannot prevent workers from disclosing their own pay where the purpose of the disclosure is to safeguard the principle of equal pay.

Employers may require workers who have received information about others' pay levels (i.e. average pay levels broken down by sex) not to use that information for any purpose other than exercising their right to equal pay. Workers and workers' representatives are expressly bound by a duty of confidentiality in relation to pay data they receive.

Where a worker breaches the confidentiality obligation, the employer may seek compensation for any damage suffered as a result.

Any existing pay secrecy clauses that conflict with the pay secrecy prohibition will be rendered automatically void and unenforceable upon entry into force.

Employers are not expressly required to amend existing contracts, though doing so is advisable as a matter of good practice in terms of complying with the new legislation.

employers with at least 100 workers must report the following seven categories of information in relation to their organisation:

• the overall gender pay gap;

• the gender pay gap in complementary or variable pay components;

• the overall median gender pay gap;

• the median gender pay gap in complementary or variable pay components;

• the proportion of female and male workers receiving complementary or variable pay components;

• the proportion of female and male workers in each quartile pay band; and

• the gender pay gap per category of workers, broken down by ordinary base salary and complementary or variable pay components.

Yes. The reporting deadlines in the draft bill mirror those in the Directive exactly.

Employers with at least 250 workers must submit their first report by 7 June 2027 and annually thereafter. Employers with between 150 and 249 workers must also submit their first report by 7 June 2027 but are required to report every three years thereafter. Employers with between 100 and 149 workers have until 7 June 2031 to submit their first report, and must also report every three years thereafter.

Reports relate to the preceding calendar year, subject to a transitional provision for Greece: for the first reporting cycle only (employers with at least 150 workers), the reference period runs from the date of entry into force of the law to 31 December 2026

No. The draft bill does not specify a single snapshot date. Instead:

Headcount is determined by reference to the average number of workers during the preceding calendar year, rather than on a fixed snapshot date.

Pay data is calculated on the basis of gross annual pay for each active worker during the preceding calendar year, again without reference to a specific snapshot date.

No general obligation (private sector) applies. Publication on a website is voluntary for private sector employers.

Submission to the Greek Ombudsman is required.

Reports are submitted via the Greek Ombudsman’s digital platform (to be established and integrated with ERGANI II). No timeline for the platform has been confirmed. 

The Greek Ombudsman is required to publish data received from employers on a publicly accessible, user-friendly electronic platform enabling comparisons between employers, sectors and regions. Data from the preceding four years must be accessible where available.

Secondary legislation governing the creation and operation of the digital platform (to be issued by joint Ministerial decision following enactment) is expected to provide further detail on this point.

Not addressed.

The draft law refers only to male and female workers, mirroring the Directive. No guidance is provided on treatment of workers who do not identify with either gender.

No. The draft bill adopts the same headcount thresholds as the Directive (100, 150 and 250 workers) for gender pay gap reporting obligations.

The draft bill does not provide any sector-specific exemptions or adjusted requirements.

In terms of size-specific adjustments, the following apply:

• Fewer than 50 workers: employers may be exempt from the obligation to inform workers of the criteria used for pay progression (though all other pay transparency obligations apply).

• Fewer than 100 workers: employers are not subject to mandatory gender pay gap reporting but may report voluntarily on a triennial basis.

• Fewer than 250 workers: employers are entitled to receive technical assistance, model pay structures and training from the Ministry of Labour and Social Security to facilitate compliance with pay transparency obligations.

The above reflect the options already provided by the Directive.

The draft bill provides two distinct timescales depending on the context:

• Following gender pay gap reporting: Where gender pay differences are not justified on the basis of objective, gender-neutral criteria, employers must take corrective measures to restore equality within six (6) months. This is done in cooperation with workers' representatives, the Labour Inspectorate and the Greek Ombudsman.

• Following a joint pay assessment: Where unjustified pay differences are identified through a joint pay assessment, employers must implement the resulting corrective measures within one (1) year of the communication of the joint pay assessment to workers, workers' representatives, the Labour Inspectorate and the Greek Ombudsman.

The draft bill does not prescribe specific remedial measures that employers must take. However, when implementing measures identified arising from the joint pay assessment, implementation must include a review or introduction of gender-neutral job evaluation and classification systems to eliminate direct and indirect pay discrimination.

The RIA provides the following guidance regarding corrective measures adopted following gender pay gap reporting:

• Corrective measures must be taken in cooperation with the Greek Ombudsman and the Labour Inspectorate.

• Reduction of pay of higher-paid workers is expressly not permitted as a corrective measure. Any unilateral reduction of pay by an employer would constitute a unilateral prejudicial change in employment terms.

• Corrective measures may include:

o upward adjustment of pay, including retroactive payment where inequality is identified;

o review of job descriptions using gender-neutral job evaluation criteria;

o review of bonus and supplementary pay criteria;

o investigation of any correlation between family responsibilities and lower pay; and

o measures promoting work-life balance (e.g. flexible working arrangements, on-site childcare).

Further, the RIA provides the following guidance regarding corrective measures arising from the joint pay assessment:

• Corrective measures may concern both direct pay adjustments and structural changes to evaluation and classification policies.

• The choice and scope of measures will be determined according to the type and extent of the identified discrepancies, the size of the undertaking and its actual capabilities.

• Corrective measures may include:

o review of professional appraisal and job classification systems;

o revision of allowance and bonus criteria;

o training of managers and workers' representatives on equal pay and gender-neutral job evaluation; and

o establishment of mechanisms for regular monitoring and transparency.

Cooperation is required but not defined in detail.

Corrective measures must be taken “in cooperation” with workers’ representatives, the Labour Inspectorate and the Greek Ombudsman.

The draft law does not define “cooperation” or specify whether agreement is required. The obligation is to act cooperatively rather than unilaterally; however, the employer is not required to obtain consent from these bodies before implementing corrective measures

A joint pay assessment must be conducted in co-operation with workers' representatives when all three of the following conditions are met cumulatively:

• the pay gap data reveals a difference of at least 5% in the average pay level between female and male workers in any category of workers;

• the employer has not justified that difference on the basis of objective, gender-neutral criteria; and

• the employer has not corrected the difference in the average remuneration level within six months of submitting the pay gap data.

The joint pay assessment must include: 

• an analysis of the proportion of female and male workers in each category of workers;

• information on the average pay level of female and male workers, and on complementary or variable pay components, for each category;

• any differences in average pay levels between female and male workers in each category;

• the reasons for those differences, based on any objective, gender-neutral criteria, as jointly determined by the employer and workers' representatives;

• the proportion of female and male workers who benefited from any pay improvement following their return from maternity, paternity, parental or care leave, where such an improvement occurred in the relevant category during the period of leave;

• measures to address any unjustified pay differences; and

• an assessment of the effectiveness of measures identified in any previous joint pay assessment.

Disclosure is required to multiple stakeholders.

The assessment must be made available to all workers and their representatives and to the Labour Inspectorate upon request. It must also be communicated to the Greek Ombudsman as part of its monitoring role.

Yes - access is restricted.

Where disclosure of pay information could directly or indirectly identify an individual worker’s pay, access is limited to workers’ representatives, the Labour Inspectorate and the Greek Ombudsman.

Workers’ representatives and the Greek Ombudsman may advise employees on potential equal pay claims without disclosing identifiable pay data. All processing of pay data must comply with GDPR and be used solely for the purpose of enforcing the equal pay principle

Employers face three categories of consequences.

• Civil liability: Workers are entitled to full, uncapped compensation covering direct financial loss, consequential loss and non-material harm (moral damage). In equal pay claims, this includes back pay, bonuses and benefits in kind, default interest, loss of income and career prospects, and harm arising from intersectional discrimination.

• Administrative fines: Breaches constitute violations of labour law. The Labour Inspectorate may impose fines, taking into account aggravating and mitigating factors. Non-compliance with a compliance order triggers recurring fines every three months. The levels will be set by ministerial decision.

• Non-compliant employers registry: The Labour Inspectorate must maintain a register of employers sanctioned for breach of the equal pay principle.

Workers have access to judicial and administrative remedies.

A worker may bring proceedings before the civil courts, initiate a Labour Inspectorate dispute procedure, seek mediation through the Greek Ombudsman, or file a complaint with another competent authority. These rights apply even after employment ends.

The Greek Ombudsman, trade unions and other organisations may also act on the worker’s behalf with their consent.

The draft law defines "workers' representatives" as the legal representatives of the workers' association of the most representative trade union organisation in the enterprise.

The draft law introduces a Greece-specific fallback mechanism exclusively for the purposes of the joint pay assessment. Where no trade union exists in the enterprise, workers are represented by the three (3) employees with the longest length of service in the undertaking, unless the workers choose a different method of representation.

Under the draft law, workers’ representatives benefit from the following rights and protections:

• Pay structure criteria: A right of agreement - not merely consultation - on the objective, gender-neutral criteria used to establish pay structures and worker categories. 

• Pay gap reporting: A right to be consulted on the accuracy of the data before submission to the Greek Ombudsman and to access the methodologies used. The employer’s management must confirm the accuracy of the data in writing following that consultation.

• Joint pay assessment: A right to participate in all stages, including jointly determining with the employer the objective, gender-neutral criteria used to explain pay differences, and cooperating in implementing corrective measures.

• Corrective measures: A right to be involved in the implementation of corrective measures arising from pay gap reporting and joint assessments.

• Protection from retaliation: Protection against dismissal or adverse treatment linked to complaints or enforcement actions, mirroring the Directive.

• Confidentiality obligation: An express statutory duty of confidentiality in relation to pay data. Breach may give rise to a civil claim for damages.

There is no standalone "failure to engage" provision. However, there are indirect consequences, i.e.: (a) Administrative fines: To be set by ministerial decision, for breaches of obligations that include agreeing or consulting with workers’ representatives, (b) Reversal of burden of proof: Automatic reversal in subsequent equal pay claims, unless the breach was manifestly unintentional and minor, (c) Recurring fines: For non-compliance with Labour Inspectorate compliance orders, issued every three months and calibrated by the size of the undertaking, the seriousness of the breach, the degree of fault and any recurrence.

Employers must consult workers’ representatives on the accuracy of the data before submission and provide access to the methodologies used. Management must confirm the accuracy of the data in writing following consultation.

Multiple enforcement routes are available.

• Individual claims: Workers may bring court proceedings, file a complaint with the Labour Inspectorate, or seek mediation through the Greek Ombudsman. These remain available after termination of employment.

• Representative actions: With the worker’s consent, the Greek Ombudsman, trade unions and other organisations with a legitimate interest may bring or join proceedings.

• Labour dispute procedure: Workers may initiate a procedure before the Labour Inspectorate. Where the Greek Ombudsman issues a reasoned opinion, the Labour Inspector may require corrective measures within six months.

• Burden of proof: Breach of pay transparency obligations triggers a reversal of the burden of proof, unless the breach is clearly minor and unintentional.

• Access to evidence: Courts may order disclosure of relevant evidence, including confidential information, subject to safeguards.

• Protection from retaliation: Workers and representatives are protected from dismissal or adverse treatment linked to enforcement actions.

• Limitation period: Begins when the worker becomes aware (or could reasonably be expected to become aware) of the breach.

The Ministry of Labour and Social Security and the General Secretariat for Equality and Human Rights, in cooperation with the social partners, are responsible for providing support to employers, in the form of technical assistance and training - including the provision of guidelines and model pay structures, the organisation of education and training programmes and the operation of a support centre - targeted specifically at employers with fewer than 250 employees and their workers’ representatives, in order to facilitate compliance with all pay transparency obligations. 

In addition, the Ministry and the General Secretariat, in cooperation with the Ombudsman, make available evaluation tools and methodologies from national, European and international organisations (such as the European Institute for Gender Equality and the International Labour Office) to all employers and social partners, so that they can establish and use gender-neutral systems of professional evaluation and classification. The Labour Inspectorate plays a complementary role in providing practical guidance on the application of the reporting requirements.

Partially. The specialised support measures (technical assistance, training, guidelines, model pay structures and the support centre) are available only to employers with fewer than 250 employees and their workers’ representatives. However, the evaluation tools and methodologies made available by the Ministry and the General Secretariat in cooperation with the Greek Ombudsman are accessible to all employers and social partners, regardless of size.

No dedicated public resources are currently available, as the law has not yet been enacted.

The RIA provides substantive guidance on the interpretation and application of key concepts introduced by the draft law, including the concepts of pay structures and pay, as well as the scope of corrective measures. References to the RIA have been included throughout this questionnaire where relevant.

Further, additional secondary legislation is expected to be published. Specifically, the draft law provides that ministerial decisions will define the support measures available to employers and the methodology and level of fines for breaches. A separate joint ministerial decision will regulate the creation and operation of the Greek Ombudsman’s digital platform, including its interoperability with the ERGANI II employment information system.