On 1 November 2026, Greek workplaces cross a line that reshapes how salaries are set, disclosed, and defended. Law 5316/2026, published in the Government Gazette on 6 July 2026, transposes EU Directive 2023/970 on pay transparency, and the core obligations under articles 8 to 20 and 27 switch on that November date.

If you work in Greece, or you run an HR function here, the practical questions land in two very different inboxes. Employees and candidates get new rights to ask about pay, and a hard stop on employers digging into their salary history. HR teams get a compliance cliff, a reversed burden of proof, and uncapped damages if things go wrong. The rest of this piece splits those two views cleanly, because the same law reads very differently depending on which side of the desk you sit on.

What the law actually does

Law 5316/2026 is Greece's national version of the EU pay-transparency directive. It puts three big ideas into Greek labour law at once: candidates must be told the salary or salary range for a role before the interview, employers cannot ask about a candidate's pay history, and workers can formally request information about how they are paid relative to colleagues doing the same or equivalent work.

Layered on top are reporting duties tied to company size, a joint pay-assessment mechanism when a 5% gender pay gap shows up in any employee category, and a new specialised unit inside the Labour Inspectorate that will monitor equal-pay compliance.

Who is in scope, and when

The interview rules and the individual right to ask about pay apply broadly from 1 November 2026. Reporting obligations stagger by headcount:

• Employers with 250 or more employees, and those with 150 or more, must submit pay-gap data from 7 June 2027.
• Employers with 100 to 149 employees start reporting from 7 June 2031.
• Businesses with fewer than 50 employees are exempt from the obligation to publish criteria for pay progression under article 8.

For employees and candidates

If you're applying for a job in Greece from 1 November 2026 onwards, the recruiter has to tell you either the starting pay or the pay range for the role before you sit for the interview. That's article 9. It also means they cannot ask what you earned in your previous job, a question that used to anchor salary negotiations in the employer's favour.

If you're already employed, you gain a right most Greek workers have never had: you can ask your employer, in writing, for information about your individual pay level and the average pay levels, broken down by sex, for categories of workers doing the same job or work of equal value. The employer has to respond within a reasonable time, and in any case within two months.

Where there is no trade-union representation in the workplace, the law says workers are represented by the three employees with the longest service. That matters because collective information rights, and the joint pay-assessment process, run through those representatives.

Two practical points before you use these rights. First, the request has to go through whatever internal workflow your employer sets up, so ask HR how the process works before you file. Second, if you believe you've been underpaid on gender grounds and your employer hasn't kept up with the transparency duties, article 18 flips the burden of proof: the employer has to justify the pay difference, not you.

For HR and employers

The compliance work for HR teams is heavier than it looks, and 1 November 2026 is not a soft deadline. Chrysiida Poulakou, Managing Partner at Ad Hoc Legal, framed the shift at a Greek People Management Association workshop on the law: employers now have to be able to document and defend the logic behind pay differences. Equal pay is no longer the whole test; the ability to prove and justify each pay decision is.

In practical terms, this hits three things HR owns: the recruitment workflow, the reward framework, and the internal information-request process.

Recruitment workflow

Job adverts and interview scripts need a rewrite. From 1 November, the initial salary or salary range must be communicated to the candidate before the interview, and any reference to prior compensation, in application forms, screening calls, or interview questions, has to come out. Recruiters and hiring managers need briefing, because a well-intentioned question about a candidate's current package is now a compliance breach.

Reward framework

The reward framework itself becomes an object of inspection, documentation, and potential challenge, as Poulakou put it at the workshop. That means written criteria for how pay is set, how progression works, and how bonuses and benefits are distributed, all defensible against the equal-value test. For employers with 50 or more employees, the criteria for pay progression have to be made accessible to staff.

The sharpest pressure point sits at the reporting threshold. Once an employer is in the reporting regime and the data shows a gender pay gap of at least 5% in any category of workers, that isn't objectively justified and isn't corrected within six months, a joint pay assessment kicks in. The employer, together with worker representatives, has to analyse the causes and design remediation. Corrective measures from that assessment must be applied within one year.

Information-request workflow

Poulakou's second workshop point is one HR teams should not underestimate: every business needs to be ready to respond to any candidate, employee, partner, authority, or worker representative exercising the right to pay information. The practical answer is a defined internal workflow, with named owners, a submission channel, a review step, and a two-month clock. Poulakou recommended setting up exactly that: a workflow through which the request will pass, defining who is responsible for handling it and the internal process for submission and management.

What non-compliance costs

Article 16 grants full compensation with no upper cap. It covers actual loss, loss of earnings, non-material damage, back pay, bonuses, benefits in kind, and default interest. Article 17 adds a recurring quarterly fine for failure to comply with Labour Inspectorate orders. And article 18's reversal of the burden of proof means that in litigation, the employer starts on the back foot whenever transparency duties haven't been met.

What else changed in the same law

Law 5316/2026 also extends paid annual leave to managerial staff and introduces new exceptions to the ban on Sunday and public-holiday work. Both changes sit alongside the pay-transparency provisions in the same act, so HR teams reviewing the law should not treat it as a single-topic reform. A dedicated unit within the Labour Inspectorate has been established under article 26 to monitor equal treatment and equal pay, which signals the enforcement lens Greek employers should expect from 2027 onwards.

Where to start this quarter

If you're an employee, the useful moves are small and specific. Know that from 1 November you can ask, in writing, about how your pay compares to colleagues doing equivalent work. If you're job-hunting, expect a salary range in the advert or before the interview; treat its absence as a signal. And if you're negotiating, remember the recruiter cannot legally anchor the conversation to what you used to earn.

If you're in HR, the near-term checklist is short but heavy: audit the pay structure against the equal-value test, rewrite job adverts and interview guides before 1 November, publish pay-progression criteria to staff, and stand up an information-request workflow with named owners. If you're inside the reporting regime, model the gender pay gap now, category by category, so 5% surprises don't land in June 2027 as compliance emergencies.

The law shifts the default in Greek workplaces from opacity to documentation. The employers who move first will spend the next twelve months building defensible reward frameworks. The ones who wait will spend them answering worker requests they weren't ready for.