A circular issued by the Ministry of Labour and Social Security provides guidance and clarification on the proper implementation of the provisions of Law 5316/2026 concerning pay transparency, equal pay for women and men, and protection and enforcement mechanisms, ahead of the entry into force of the relevant provisions on 1 November 2026.
The circular is addressed to employees, employers and job applicants in the private sector falling within the Ministry’s remit. It details businesses’ obligations and employees’ rights to ensure the proper and consistent implementation of the law transposing Directive (EU) 2023/970, while also providing illustrative tools and examples of good practice.
Pay Structures Based on Objective Criteria
From 1 November 2026, all employers, regardless of the number of employees, must establish and apply pay structures that ensure equal pay for the same work or work of equal value.
These structures must be documented in writing, enable comparative assessment of jobs, provide for a review procedure, and clearly identify the pay components applicable to each category of workers.
The assessment is based on objective, gender-neutral criteria agreed with workers’ representatives, where such representatives exist. These criteria must include skills, effort, responsibility and working conditions, and may also include any other factors relevant to the specific work or position, such as seniority and relevant soft skills.
Where an employer is bound by a collective agreement, the classifications and pay scales set out in that agreement may be used.
Transparency Before Recruitment
Any reference to sex or marital status, or the use of criteria or information resulting in direct or indirect discrimination on grounds of sex, is prohibited in publications, job advertisements, advertisements, notices, circulars and regulations concerning, among other matters, the selection of individuals to fill vacant positions.
Before the first interview, job applicants are entitled to receive information from their prospective employer about the initial pay or pay range, determined on the basis of objective, gender-neutral criteria, as well as the provisions of any collective agreement applicable to the position.
Information for Workers on Pay Levels
Workers may request, in writing, information on their individual pay level and on average pay levels, broken down by sex, for categories of workers performing the same work or work of equal value.
This information must be provided within a reasonable period and, in any event, within two months of the request.
Employers must inform their staff annually of this right and how to exercise it, while complying with personal data protection and confidentiality rules.
Support for Businesses
To assist businesses, the circular includes an illustrative pay structure template and good-practice tools, such as the FAIR PAY project’s pay gap calculator (https://fairpay.isotita.gr/) and the European Institute for Gender Equality’s toolkit (https://eige.europa.eu/gender-mainstreaming/toolkits/gender-neutral-job-evaluation).
The latter is a detailed, step-by-step guide supporting employers in creating a new job evaluation and classification system or reviewing an existing one.
Reporting on the Gender Pay Gap
Businesses with at least 100 employees are subject to additional reporting obligations.
To the Greek Ombudsman
The following information must be reported:
a. The overall gender pay gap.
b. The gender pay gap in complementary or variable pay components.
c. The overall median gender pay gap.
d. The median gender pay gap in complementary or variable pay components.
e. The proportion of female and male workers receiving complementary or variable pay components.
f. The proportion of female and male workers in each quartile pay band.
g. The gender pay gap by category of workers, broken down by ordinary basic salary and complementary or variable pay components.
This information must be submitted to the Greek Ombudsman according to the following deadlines and reporting frequency:
● Employers with at least 250 employees: by 7 June 2027 and annually thereafter by the same date.
● Employers with 150–249 employees: by 7 June 2027 and every three years thereafter by the same date.
● Employers with 100–149 employees: by 7 June 2031 and every three years thereafter by the same date.
To Workers and Their Representatives
Employers must provide all workers and their representatives with the information referred to in point (g), namely the gender pay gap by category of workers, broken down by ordinary basic salary and complementary or variable pay components.
To the Labour Inspectorate and the Greek Ombudsman
Upon request, and within two months of its submission, employers must provide the Labour Inspectorate and the Greek Ombudsman with the information referred to in point (g), namely the gender pay gap by category of workers.
Information relating to the previous four years must also be provided upon request, where available.
Joint Pay Assessment
A joint pay assessment is required when all the prescribed conditions are met:
● A difference of at least 5% in the average pay level between female and male workers in any category of workers.
● The difference cannot be justified by objective, gender-neutral criteria.
● The difference has not been remedied within six months of the submission of the pay information.
The assessment aims to identify, remedy and prevent unjustified pay differences and includes:
● An analysis of the proportion of female and male workers in each category of workers.
● Information on average pay levels for female and male workers and on complementary or variable pay components for each category of workers.
● Any differences in average pay levels between female and male workers in each category of workers.
● The reasons for those differences in average pay levels, based on objective, gender-neutral criteria, as jointly established by workers’ representatives and the employer.
● The proportion of female and male workers who benefited from any improvement in pay following their return from maternity or paternity leave, parental leave or carers’ leave, where such an improvement occurred in the relevant category of workers during the period in which the leave was taken.
● Measures to address pay differences that cannot be justified by objective, gender-neutral criteria.
● An evaluation of the effectiveness of measures arising from previous joint pay assessments.
Protection of Workers
The circular clarifies the available judicial and administrative remedies, the right of affected workers to full compensation, and the procedure for resolving related labour disputes before the Labour Inspectorate, with the participation of the Greek Ombudsman.
It also provides for protection against retaliation and adverse treatment resulting from actions taken to safeguard equal pay.