Complying with the Greek transposition of the EUPTD

Greece formally passed its transposition of the EU Pay Transparency Directive (EUPTD) on July 2, 2026, with the law entering into force upon its official publication in the Government Gazette on July 6, 2026. This regulation introduces a comprehensive compliance framework for employers operating in Greece, spanning recruitment transparency, structural pay equity, employee information rights, and gender pay gap auditing.

While the legal architecture is officially live, Greece has adopted a staged implementation approach. The foundational anti-discrimination definitions took effect immediately upon publication, while the core operational obligations that directly impact daily HR workflows are deferred until November 1, 2026. This article details the objective compliance timelines, highlights where Greek law deviates from or aligns with the broader EU Directive, and explains how to utilize beqom’s PayAnalytics solution to align your compensation frameworks before the autumn deadlines.

Compliance timeline & effective dates

Greece splits its implementation timeline into an immediate alignment of legal definitions and a near-term launch of strict employer mandates.

Requirements effective on July 6, 2026

The following foundational rules entered into force immediately upon publication in the Government Gazette:

Broad legal definitions: "Pay" is formally expanded to encompass the ordinary basic or minimum wage alongside any other cash or in-kind consideration a worker receives directly or indirectly from employment. "Pay level" is defined as gross annual pay and its corresponding gross hourly equivalent.
Institutional governance: The Greek Ombudsman is designated as the primary equality and monitoring body, supported by a newly established enforcement department within the Labor Inspectorate.

Requirements effective on November 1, 2026

The core compliance protocols that employers must actively execute go live on November 1, 2026:

Pre-employment transparency: Employers must inform job applicants of the initial starting salary or its corresponding range based on objective, gender-neutral criteria. This must be provided before the interview stage (or before the conclusion of an employment contract if no interview occurs), and including these details in a published job advertisement satisfies the requirement. All vacancy notices and job titles must be strictly gender-neutral.
Salary history ban: Employers are prohibited from inquiring about a candidate's current or historical compensation, whether directly during selection or through recruitment agencies.
Accessibility of pay criteria: Organizations must implement and maintain transparent, objective, and gender-neutral pay structures and job evaluation systems. Employees must be granted easy access to the criteria used to determine pay levels and pay progression.
Individual right to information (RTI): Employees gain the right to request and receive in writing information regarding their individual pay level, alongside the average pay levels of workers performing the same work or work of equal value, disaggregated by gender. Employers must provide a substantiated written response within a two-month statutory window.

Mandatory reporting deadlines

Formal gender pay gap reporting data must be compiled and submitted directly to the Greek Ombudsman according to organization size:

Employers with 250+ employees: The initial annual report is due by June 7, 2027, and annually thereafter.
Employers with 150–249 employees: The initial triennial report is due by June 7, 2027, and every three years thereafter.
Employers with 100–149 employees: The initial triennial report is due by June 7, 2031, and every three years thereafter.

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Employers with fewer than 100 employees may provide data on a voluntary basis.

A Joint Pay Assessment becomes mandatory if a formal gender pay gap report reveals an average variance of 5% or more within any category of workers performing work of equal value, the gap cannot be justified by objective criteria, and the employer fails to remedy the variance within a six-month window. Corrective measures must then be legally implemented within one year of the assessment's notification.

Alignment and deviations from the EUPTD

While the Greek framework mirrors the primary statistical boundaries of Directive (EU) 2023/970, it incorporates unique local legal protections and evidentiary shifts to integrate with the Greek Labor Code.

Strategic alignments

Headcount brackets: Greece utilizes the standard headcount groupings (100, 150, and 250 employees) and reporting frequencies established by the EU.
The 5% threshold: The mathematical trigger for an unexplainable gap initiating a Joint Pay Assessment tracks the EU's 5% variance cap.
Candidate rights: The combination of candidate pay range rights and a strict salary history inquiry ban aligns precisely with European baselines.
Voiding of pay confidentiality: Contractual clauses, company regulations, or non-disclosure agreements that prevent employees from discussing or disclosing their remuneration are automatically null and void if the disclosure is intended to safeguard the principle of equal pay.

Local deviations & specificities

The November 1 staged operational buffer: While the law is technically enacted, Greece granted employers an operational buffer by delaying the enforcement of active obligations (such as job postings and RTI processing) until November 1, 2026.
The Collective Bargaining Agreement (CBA) presumption: In Greece, if employers are bound by a collective labor agreement, they may use the categorizations and salary scales of the collective labor agreement. Categories of workers are created by the employer of the employees or result from existing collective agreements provided that they are non-discriminatory.
Abusive exercise of the right to information: The employer has the right to refuse to provide the information if the request is manifestly disproportionate or abusive, in particular due to its repetitive nature. In this case, the employee has the right to request the information through the Ombudsman, who shall decide on the validity of the request.
Deadline for additional clarifications on pay gap data: Employees, workers' representatives, the Labor Inspectorate and the Ombudsman have the right to ask employers for additional and reasonable clarifications and details about the data provided, including explanations about any gender pay gaps. Employers are obliged to respond to these requests within two months from the date of submission of the request.
Reference period for the first reporting: The reference period for the first pay gap reporting in 2027 (for employers with 150+ employees) stretches from the entry into force of the law until December 31, 2026.
Employees’ representation in Joint Pay Assessments: If there is no trade union of employees, for the purposes of joint evaluation of remuneration, the employees are represented by the three employees who have the most time of service in the company, unless they choose another way of representation.

Managing the response pipeline – the on-request and right to refuse exception

Because pay confidentiality clauses are completely banned, employees are legally empowered to discuss compensation openly, especially for the purposes of equal pay.

Individual right to information requests operate on an on-request model. Employees have the right to request information in writing on their individual pay level and average pay levels, broken down by gender, for categories of workers performing the same work or work of equal value to them. They may request and receive the information personally or through the representatives of the employees, as well as through the Ombudsman.

Employers must provide the information within a reasonable period of time, but in any case within two months from the date of submission of the request, and must inform all employees on an annual basis of their right to receive the information and the steps they must take to exercise this right.

The Greek transposition law provides the employer with an exceptional measure: the employer has the right to refuse to provide the information if the request is manifestly disproportionate or abusive, in particular due to its repetitive nature. In this case, the employee can request the information through the Ombudsman, who judges the validity of the request for information.

Employers have a strict two-month window to deliver a written, substantiated response to an RTI query. In accordance with GDPR and local data protection rules (Law 4624/2019), if an equal-value category is exceptionally small and sharing the gender-disaggregated average would inadvertently reveal a specific colleague's salary, direct disclosure to the worker is restricted. In these small-sample cases, data must be routed confidentially through trade unions, employee representatives, the Labor Inspectorate, or the Ombudsman.

Employers should use company portals and intranets primarily to publish their core, gender-neutral pay architectures and progression criteria (satisfying the "accessibility of criteria" mandate), while handling actual comparative peer-data requests securely and reactively.

Meeting the requirements with PayAnalytics

beqom’s PayAnalytics solution is designed to help organizations audit their data and build defensible job frameworks before Greece's active obligations launch on November 1, 2026. The general EUPTD guidelines form the foundational workflows, which can be fine-tuned to match local Greek specificities. We recommend starting with the Getting ready for the EUPTD with PayAnalytics Help Center article.

Data preparation and configuration: Your payroll data must be mapped to support the expanded Greek definition of "pay" (capturing base wages, allowances, and all cash or in-kind bonuses). The PayAnalytics platform supports flexible configuration, letting you group your workforce into worker categories based on objective criteria (qualifications, effort, responsibility, and working conditions) while factoring in the baseline frameworks of applicable Greek Collective Bargaining Agreements.

For a detailed data setup walkthrough, see Preparing your data for the EUPTD.
Employee pay transparency reports: The built-in employee pay transparency report enables HR teams to communicate clearly to an employee how their compensation aligns with their specific role category. Having these report profiles pre-configured ensures you can hit the two-month statutory window with fully substantiated written disclosures whenever an RTI request is filed.

Consult the Employee pay transparency report and Pay explainability report Help Center articles for instructions.
Small group privacy monitoring: To safeguard individual data under Greek privacy guidelines, use the Compensation by category table in the PayAnalyticsWorkforce Analytics report to evaluate whether specific worker clusters feature low sample sizes that risk exposing individual salaries. This allows you to flag restricted rows that must be handled via union or inspectorate channels rather than printed directly for a worker. Apply a specific minimum threshold for group sizes in Greece within Settings > System parameters > Privacy threshold configuration.

More information is available in Workforce analytics and PayAnalytics - June 2026 feature release notes.
Proactive 5% gap auditing: Because failing to satisfy pay transparency rules shifts the legal burden of proof onto the employer, running predictive audits is critical. PayAnalytics automatically flags any job category approaching or exceeding the 5% adjusted gender pay gap threshold, allowing you to address variances long before they trigger a mandatory Joint Pay Assessment.

For a step-by-step guide, see Measuring & closing pay gaps by group in the Help Center.
Targeted compensation remediation: If an unexplainable gap is identified, the platform calculates objective, cost-effective salary modifications. This empowers HR teams to make data-driven adjustment decisions that close group gaps within the statutory six-month remediation window.

Learn how to calculate those adjustments in the Getting suggested remediation actions article.
Pre-employment pay ranges: PayAnalyticsCompensation Assistant is designed to help your hiring teams and people managers make decisions that align with both the main compensation drivers in your organization, and the individual’s characteristics at the time of hiring, promotion, transfer, or reemployment. It is essential to ensure equitable compensation decisions as your workforce evolves. While not designed specifically for the EUPTD pre-employment pay ranges, the tool can help generate equitable, data-backed salary ranges based on objective criteria, for use in Greek job advertisements.

You can find detailed guidance in Using the Compensation assistant.

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This article is for informational purposes only and does not constitute formal legal, financial, or compliance advice.

The transposition of the EUPTD into Greek local law is an actively evolving regulatory process. National legislation, administrative guidelines, and court interpretations may change frequently. While we strive to provide accurate, high-quality insights and intend to update this article periodically to reflect major changes, regulatory frameworks move fast, and we cannot guarantee that all information remains valid.

Our solution is designed to help organizations streamline and manage their compliance workflows based on current directive standards. However, because individual corporate structures and local enforcement nuances vary, we strongly recommend consulting with a qualified legal counsel or compliance specialist to ensure your specific implementation aligns fully with the latest Greek statutory requirements.