Implementation of the EU Directive on Pay Transparency in Greece: New Obligations and Challenges for Employers
The European Union Directive on strengthening the application of the principle of equal pay for men and women for work of equal value or for work of the same value, through pay transparency and enforcement mechanisms (EU 2023/970) introduces in Greece a new regulatory framework aimed at strengthening pay equity, transparency, and accountability in the workplace.
The deadline for its transposition into the laws of the Member States (and thus also in Greece) was June 7, 2026, a deadline that was not met under Greek law, as the public consultation on the relevant bill was not completed until June 17, 2026. Despite the late transposition of the Directive, the existence of a draft bill is a positive development and raises expectations for the immediate completion of the legislative process.
The new Directive substantially enhances transparency in hiring procedures and reaffirms the principle of equal pay for work of equal value. At the same time, it introduces new compliance, reporting, and corporate governance obligations, requiring organizations to adopt a more structured, documented, and data-driven approach to compensation policies.
Key Obligations of Employers During the Hiring Process
Prospective employees acquire the right to receive from the potential employer, within the framework of proper corporate compliance, information regarding:
the starting pay or pay range, based on objective and gender-neutral criteria corresponding to the specific job position, and
where applicable, the relevant provisions of the collective bargaining agreement that apply to the position.
This information should be provided in a timely manner to ensure a transparent and well-informed salary negotiation, such as, for example, by publishing the salary in the job posting or prior to the interview.
At the same time, employers are prohibited from asking candidates for information regarding their salary history.
Furthermore, employers must ensure that job postings and job titles are gender-neutral and do not create direct or indirect discrimination, so as to effectively protect the principle of equal pay.
Transparency in Pay Policies
The Directive stipulates that employers must make the criteria used for the following easily accessible to employees:
the determination of pay,
pay levels, and
pay progression.
These criteria must be objective and gender-neutral.
At the same time, employees gain the right to request and receive written information regarding their pay level, as well as information on the average pay of employees performing the same or equivalent work.
Reporting and Disclosure Requirements
Employers, depending on the size of the company, will also be required to provide specific data regarding their company, such as:
a) the gender pay gap,
b) the gender pay gap with respect to supplementary or variable components,
c) the median gender pay gap,
d) the median gender pay gap with respect to supplementary or variable pay components,
e) the percentage of female and male employees receiving supplementary or variable pay components,
(f) the percentage of women and men in each quartile of the wage scale,
(g) the gender pay gap by employee category, broken down by regular base pay and supplementary or variable components.
Employees are also protected from any adverse treatment or retaliation for exercising the rights granted to them by the Directive or for supporting their colleagues.
Under the Directive, the above transparency and reporting obligations apply to employers as follows:
Employers with 250 or more employees must provide, by June 7, 2027, and annually thereafter, the information specified above (items a–g) regarding the previous calendar year.
Employers with 150 to 149 employees must provide, by June 7, 2027, and every three years thereafter, the information specified above (items a–g) regarding the previous calendar year.
Employers with 100 to 149 employees shall provide, by June 7, 2031, and every three years thereafter, the information specified above (items a–g) regarding the preceding calendar year.
Member States may, in accordance with national law, require employers with fewer than 100 employees to provide information regarding pay.
Scope
Although some of the law’s obligations apply only to companies employing a specific number of workers, the core compliance obligations have a broad scope of application.
Specifically, they apply:
to individuals employed by or applying for employment in the public sector, the broader public sector and the private sector, regardless of the employment relationship or form of employment (including project-based contracts and commissioned work), regardless of the nature of the services,
to self-employed professionals, as well as
to individuals who are receiving or are candidates to receive vocational training of any kind or form.
Consequently, the scope of the law extends beyond traditional employment relationships and covers a particularly broad range of forms of employment and vocational training.
Conclusion
In light of the upcoming submission and passage of the relevant law transposing the Directive in Greece, companies, and specifically their human resources departments, are urged to promptly assess their existing compensation structures, hiring practices, and data management capabilities.
Compliance with the new framework is not only a legal obligation but also an opportunity to strengthen credibility, equality, and trust in the workplace.
