By Benjamin Kerner
BLOG OVERVIEW: Greece became the fifth EU Member State to complete transposition of the EU Pay Transparency Directive, publishing Law 5316/2026 in the Government Gazette on July 6, 2026 after a July 2 parliamentary vote. The law largely tracks the Directive on reporting deadlines and headcount thresholds, but adds Greece-specific features. Core compliance obligations including application-stage transparency, right-to-information, gender pay gap reporting, joint pay assessments, and dispute resolution, do not take effect until November 1, 2026, while structural provisions applied immediately on July 6. Employers with Greek operations should begin preparing now.
On July 6, 2026, Greece published legislation (Law 5316/2026) transposing the EU Pay Transparency Directive (the Directive) following passage through parliament on July 2, 2026. This passage and publication come after the Greek government released a public draft of the transposition in June accompanied by a public comment period ending on June 17, 2026.
The Greek law does not differ much from the Directive on items such as the prescribed initial reporting deadlines and headcount thresholds, but a few key differences exist.
One difference is in regard to collective bargaining agreements (CBA). Specifically, pay established through a CBA between Greek entities carries a presumption that no unjustified pay discrimination exists. Should pay discrimination be identified during a review despite the existence of a CBA, a specific, detailed, and complete statement of reasons must be included with the findings or within any act imposing corrective measures.
While the Directive does not specifically designate enforcement or equality bodies, the Greek law provides this information. For the purpose of monitoring and enforcing the Directive, the Greek Ombudsman has been named the Greek equality body and will be in charge of processing complaints, responding to information requests, and joint pay assessments. The National Transparency Authority is framed as the organization that will carry out the Ombudsman’s monitoring role in the public sector.
Specifically, the National Transparency Authority is set to handle checks following complaints submitted to itself, to the Ombudsman, or on its own initiative. This is an important difference when compared to the Labour Inspectorate, which is set to handle private sector enforcement, as the National Transparency Authority does not only act following a referral or complaint.
Furthermore, the Labour Inspectorate will receive private sector complaints, conduct evaluations, and impose administrative sanctions at the direction of the Ombudsman. Additionally, this body is required to inform the Ombudsman when they receive a complaint and when an investigation and sanctioning actions have been completed. The Ombudsman also has final say over findings and penalties relating to the private sector. If the Labour Inspectorate wishes to deviate from the Ombudsman’s determination in a given case, they are required to provide official justifications for the deviation.
Unlike the Labour Inspectorate, the National Transparency Authority will act more independently and does not have a duty to follow the Ombudsman’s conclusions. However, this authority can voluntarily provide summary data on complaints and pay evaluations to the Ombudsman.
Although this law was published on July 6, 2026, there are certain elements that do not go into effect right away. Specifically, pay transparency compliance obligations related to pre-employment/application process transparency, right-to-information rules, gender pay gap reporting, joint pay assessments, and the formal dispute resolution process do not officially take effect until November 1, 2026. This was included in the text of the final bill to provide time for employers to prepare for adoption.
All provisions and items outside of specific compliance obligations (Chapter C and Chapter D of the final bill) went into effect on July 6, 2026. These provisions include designation of the Greek Ombudsman as the equality and monitoring body, and the enshrinement of official definitions for terms such as “pay” and “pay level”.
“Pay” within the legislation is defined as the ‘ordinary basic or minimum wage or salary and any other consideration, in cash or in kind, which a worker receives, directly or indirectly, in respect of their employment from their employer.’ “Pay Level” is simply defined as ‘gross annual pay and the corresponding gross hourly pay.’
When considering these items and definitions, it is important to also be aware of the potential fines and penalties associated with non-compliance. Under this law, the Minister of Labour and Social Security will determine the calculation method for fines where entities are found to be in breach of equal pay principles. Additionally, a recurring fine will be imposed for every three months in which an entity fails to implement the equal pay provisions set in the Directive and this transposition. The size of the fine will depend on the size of the undertaking, gravity of the breach, and the degree of fault and re-offense committed by the employer. The method for calculating recurring fine amounts has also been delegated to the Minister of Labour and Social Security. As a note, administrative fines for labor law violations in Greece range from 300 to 50,000 Euros per infringement.
Organizations with employees in Greece should take steps to comply with pay transparency requirements as soon as possible given the November 1, 2026 timeline presented. DCI will continue to monitor enforcement activity for entities within Greece.
DCI Consulting helps employers turn complex EU Pay Transparency requirements into clear, defensible pay decisions before reporting becomes mandatory. We provide software and consulting solutions to organizations to establish or review worker categories, conduct required gender pay gap analyses, develop targeted remediation strategies, assess pay transparency compliance, and provide guidance on right to information requests. Visit our EU Pay Transparency Directive page to learn how your organization can prepare to confidently meet upcoming deadlines and subsequent reporting requirements.