From 1 November 2026, every private employer in Greece will have to show its pay structure. This applies to firms of every size. Law 5316/2026, which transposes EU Directive 2023/970 on pay transparency, takes effect in less than three weeks. A Labour Ministry circular has now explained how employers must apply it.

For HR teams, this is not a reporting task for some later date. It changes how roles are advertised and how offers are set. It also changes how pay decisions are defended. Some obligations start in November, and the first gender pay gap reports for larger employers are due by 7 June 2027.

What the law requires of every employer

The basic duty has no headcount threshold. Every employer must have pay structures that guarantee equal pay for equal work or for work of equal value. In practice, a 15-person company must be able to explain why two people in comparable roles earn different amounts, just as a large group must.

The circular sets out several day-to-day duties:

• Before the first interview, candidates are entitled to information on the starting pay or the pay range for the role.
• Job ads may not refer to gender or family status.
• Written pay requests from employees must be answered within two months at most.
• Every year, employers must remind staff that they have the right to request pay information.
• Retaliation against employees who act to secure equal pay is prohibited.

Gender pay gap reporting: who reports, and when

Firms with at least 100 employees have an extra duty: reporting their gender pay gap to the Greek Ombudsman. The deadlines depend on headcount:

• 250 or more employees: first report by 7 June 2027, then every year.
• 150 to 249 employees: first report by 7 June 2027, then every three years.
• 100 to 149 employees: first report by 7 June 2031, then every three years.

The figure that matters most is 5%. Suppose a report shows a gender pay gap of at least 5% in any category of workers. If the employer cannot justify that gap and does not correct it within six months, it must carry out a joint pay assessment. Six months is not long to fix structural pay differences, so the work has to begin before the report is filed, not after.

Smaller employers are not outside enforcement. If asked, any employer must give pay gap data by worker category to the Labour Inspectorate and the Ombudsman within two months. Data for the previous four years must be included where it exists.

What changes at the offer table

The biggest change for recruiters is timing. Candidates who know the pay range before the first interview start the conversation already informed. As a result, salary negotiation will focus on where someone sits within a range, not on whether the range is fair. Hiring managers need consistent reasons for placing candidates differently within the same band.

Existing employees are affected too. Once new hires join with published ranges, current staff can compare them with their own pay. Combined with the right to written pay requests and the annual reminder, this makes retention risk easy to see in teams where long-serving employees have fallen below the advertised starting pay.

Practical steps for HR before 1 November

• Map roles to categories of equal value. Employers covered by a collective agreement may use its job categories and pay scales as a starting point. The circular also refers employers to the EIGE toolkit for gender-neutral job evaluation.
• Run an internal gap analysis now. The circular refers employers to the FAIR PAY pay gap calculator. A test run done now shows where a 5% gap might appear before it has to be reported.
• Rewrite job ad templates. Remove references to gender and family status, and add pay ranges or starting pay to your recruitment process.
• Set up a response process for pay requests. Decide who answers, what data they can share and how the two-month deadline is tracked.
• Train managers. Managers need to be able to explain pay decisions using objective criteria and to avoid anything that could look like retaliation.

Pay transparency as a decision tool

Employers who treat Law 5316/2026 as only a compliance task will meet the deadlines. Employers who use it to audit pay decisions thoroughly will also find out early where their pay structures cannot be defended to candidates, employees or the Labour Inspectorate. It helps to compare internal bands with what employees actually report earning in the market. That comparison shows whether a published range will attract candidates or push them away.

There are three weeks until the law applies and eight months until the first reports are due. Employers who start the gap analysis this month will have time to correct problems before reporting them.