Greece's Pay-transparency Reform, What Employers Must Do to Disclose Pay Before the Interview

Greece is set to require employers to disclose pay before the interview under the national law transposing the EU pay-transparency Directive into Greek law. The reform brings a fundamental shift to recruitment: candidates must be told the starting salary or its range before they sit down to interview, and employers can no longer probe an applicant’s salary history. The operational obligations that most affect day-to-day hiring give HR teams, in-house counsel and immigration advisers a window to update templates, retrain recruiters and prepare reporting data.

This guide explains who is in scope, what must be disclosed and when, the staggered gender pay reporting deadlines, the joint pay assessment trigger at a 5% unexplained gap, and the practical steps every employer should take now. It is written for organisations that hire in Greece, including international employers and those recruiting third-country nationals, who need clear, authoritative direction ahead of the deadline. Because the precise transposition dates and figures are set by the implementing Greek legislation, employers should confirm the current position against the official Government Gazette and their legal advisers before acting.

Background, the EU Directive and Greek transposition

The reforms flow from a coordinated European effort to close the persistent gender pay gap through transparency. Greece’s requirement that employers disclose pay before hiring decisions is a direct consequence of implementing this EU framework, and understanding the parent Directive helps employers interpret the Greek measures correctly.

Directive (EU) 2023/970, core aims

Directive (EU) 2023/970 was adopted to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms. Its central instruments are pre-employment pay transparency, a prohibition on asking candidates about their pay history, the right of workers to information on pay levels, and mandatory gender pay gap reporting for employers above set thresholds. Where reporting reveals an unjustified gap of at least 5% that is not remedied, the Directive requires a joint pay assessment carried out with worker representatives. Member states were required to bring the Directive into national law by 7 June 2026, and Greece is implementing it through domestic legislation.

Greek transposition, what changes

The Greek transposing legislation carries the Directive’s obligations into Greek employment law, translating the EU principles into concrete duties for employers operating in Greece. The operational obligations that reshape recruitment, the duty to disclose starting pay and the ban on asking about salary history, are the most immediate practical concern. The legislation also sets out the gender pay gap reporting cadence by employer size, the mechanics of the joint pay assessment, and the shift in the burden of proof in equal-pay disputes. Because the reform requires employers to disclose pay before candidates are interviewed, the practical impact begins at the very first stage of hiring, which is why compliance work must be completed ahead of the operational date.

Employers should verify the exact statute number, publication date and commencement dates against the official Government Gazette (Ethniko Typografeio) and current guidance.

Who is in scope? Employers, agents and job types

The obligations apply broadly. All employers who recruit in Greece must observe the pre-employment disclosure rules and the ban on pay-history questions, regardless of size. The size-based thresholds matter chiefly for the separate gender pay gap reporting duties, which are phased in over several years.

Employers by headcount thresholds

Reporting obligations are calibrated to workforce size. The disclosure duty itself is universal, but the frequency and timing of gender pay gap reporting depend on how many workers an employer has. The thresholds below follow the structure set out in Directive (EU) 2023/970 and reflected in the Greek transposition; employers should confirm the precise national dates against current official guidance.

Regardless of where an organisation sits on this table, the pre-interview disclosure duty and the prohibition on requesting pay history apply to all employers. Smaller employers that are exempt from mandatory reporting are not exempt from the transparency obligations at the recruitment stage.

Persons acting on behalf of employers

The obligations extend beyond the direct employer. Recruitment agencies, staffing firms and any person acting on the employer’s behalf are bound by the same rules. When an agency advertises a role or corresponds with candidates about access to employment, it must disclose the starting salary or range and must not ask about a candidate’s pay history. In practice this means employers should update their contracts and instructions to external recruiters, because a breach committed by an agent can expose the employer to the same compliance risk as a direct breach.

What must be disclosed and when, practical rules on disclosing pay before hiring

The disclosure duty is designed to give candidates pay information early enough to inform whether they pursue a role and to level the negotiating field. Getting the timing and content right is the single most important operational change for recruitment teams.

Disclosure before interview or before contract, format and documentation

Employers must disclose the starting salary or its range before the interview takes place. Where there is no interview, for example, a direct hire or an internal appointment made without a formal interview stage, the disclosure must be made before the employment contract is concluded. Employers should treat documentation as essential: a written record protects the organisation if a candidate later alleges the information was withheld or misstated. The most robust approach is to include the pay information directly in the vacancy notice so that the obligation is discharged transparently and consistently. Because the reform requires employers to disclose pay before candidates are assessed, recruiters should never schedule an interview until the pay information has been communicated and recorded.

Pay-range methodology, what counts as “starting salary”

The rules require disclosure of the initial pay or its range. A range must be genuine and defensible, not so wide as to be meaningless. Employers should base ranges on objective, gender-neutral criteria such as the role’s grade, the market rate for equivalent positions, internal pay bands and experience requirements. The methodology used to set the range should be recorded so that it can be produced if challenged. A transparent, criteria-based band both satisfies the disclosure obligation and reduces the risk of an unexplained gender pay gap emerging later, because pay decisions are anchored to gender-neutral factors from the outset.

Gender-neutral job titles and vacancy wording

Vacancy notices and job titles must be gender-neutral, and the recruitment process must be conducted in a non-discriminatory manner. Employers should review standard job titles, advertisement templates and application forms to remove gendered language and ensure the wording does not deter applicants of either sex.

Prohibition on asking pay history, scope and examples

A cornerstone of the reform is the ban on asking candidates about their remuneration history. This prohibition is intended to stop historic pay inequities from being carried forward into new roles.

Communications concerning access to employment

Employers and their agents must not ask candidates about their current or previous pay in any communication concerning access to employment. This covers application forms, screening questionnaires, telephone pre-screens, interviews and correspondence handled by external recruiters. A recruiter cannot, for instance, ask “What is your current salary?” or “What were you earning in your last role?” as a filtering question. Permitted follow-ups instead focus on the candidate’s expectations relative to the disclosed range, for example, confirming whether the advertised range meets the candidate’s requirements, rather than extracting a figure tied to past employment.

Where a candidate volunteers pay history

If a candidate voluntarily mentions their previous pay, the employer has not breached the prohibition simply because the information was disclosed. However, employers should be cautious about relying on volunteered pay history to set the offer, since doing so risks reproducing the very inequities the law seeks to eliminate. The safer course is to anchor the offer to the objective pay-range methodology and to note in the record that any figure supplied by the candidate was unsolicited.

Reporting obligations and timelines by employer size

Alongside the recruitment changes, the reform introduces gender pay gap reporting. These duties are staggered so that the largest employers report first, and they rest on a defined reference period of pay data.

Reference periods

Reporting draws on data from a defined reference period. Employers should treat their current pay data as reporting-critical: it must be clean, complete and structured by worker category so that gender pay gap calculations can be produced accurately. Preparing this data early, rather than immediately before a deadline, avoids a scramble ahead of the first reporting cycle. Employers should confirm the applicable reference period against current official guidance.

Reporting cadence by employer size

The timing and frequency of reporting depend on headcount, following the structure below. Employers should verify the exact first-reporting dates applicable under the Greek transposition, as these are fixed by the implementing legislation and may be updated.

Employers with 250 or more workers face the most demanding regime: annual reporting. Those with 150–249 workers report every three years. Employers with 100–149 workers benefit from a longer lead time before their first report is due.

Voluntary reporting for employers with fewer than 100 workers

Employers below 100 workers are not required to report but may choose to do so voluntarily. Voluntary reporting can be a useful way to demonstrate a commitment to equal pay, identify emerging gaps early, and reassure candidates and staff, particularly for organisations competing for skilled talent.

What happens if a gender pay gap of 5% or more appears?

The 5% threshold is the operative trigger in the reporting regime. Where reporting reveals a gap of at least 5% in any category of workers that the employer cannot justify and does not remedy, the law sets in motion a structured corrective process.

Objective, gender-neutral justifications

A pay gap is not automatically unlawful. It may be justified where it rests on objective, gender-neutral criteria, for example, differences in seniority, responsibility, qualifications required for the role, or the market conditions attaching to particular functions. The burden, however, is on the employer to demonstrate that the criteria are genuine, applied consistently and free from indirect discrimination. Vague or unevidenced explanations will not suffice. This is precisely why documenting the pay-range methodology from the recruitment stage is so valuable: it provides the contemporaneous evidence needed to justify any residual gap.

Joint pay assessment, steps, participation and timeline

Where a gap of 5% or more in a category of workers cannot be justified by objective gender-neutral criteria, and the employer has not remedied it within a reasonable period after the report, the employer must carry out a joint pay assessment in cooperation with worker representatives. The assessment analyses the categories of workers affected, the causes of the gap, and the measures required to close it. It is a collaborative process: worker representatives participate directly, which means employers should identify and engage the appropriate representatives, share the relevant data, and approach the exercise as a genuine remediation rather than a formality.

Employer obligations if the gap is not corrected

If the employer does not correct an unjustified gap within the period set by the applicable law, the obligation to conduct the joint pay assessment crystallises. Employers should therefore monitor gaps continuously rather than waiting for a reporting cycle, so that any gap can be investigated and remedied before the joint assessment obligation is triggered.

Enforcement, equal-pay claims and burden of proof

The transparency measures are backed by enforcement mechanisms and a claims regime that materially strengthens the position of workers alleging unequal pay.

Burden of proof shifts in equal-pay disputes

In equal-pay disputes the burden of proof operates in the worker’s favour. Where a worker establishes facts from which unequal pay may be presumed, it falls to the employer to prove that there has been no breach of the equal-pay principle. This reversal makes documentation decisive: an employer that has recorded its pay-range methodology, its criteria for pay decisions and its justifications for any differentials is far better placed to discharge that burden than one relying on recollection. The transparency obligations also make it easier for workers to identify potential disparities, which increases the practical likelihood of claims being brought.

Remedies and sanctions

Non-compliance carries both administrative and litigation risk. Workers who succeed in equal-pay claims may be entitled to remedies including recovery of pay owed and compensation. Beyond individual claims, failure to meet the disclosure, reporting or joint-assessment obligations can expose employers to administrative consequences under the applicable penalty regime. The reputational dimension should not be underestimated either: because the reform requires employers to disclose pay before candidates are interviewed, breaches are visible at the recruitment stage and can quickly become public. The practical effect is that compliance is not merely a legal formality but a matter of talent attraction and corporate reputation.

Immigration and cross-border considerations

The pay-transparency rules intersect directly with immigration and international recruitment, which is why they are of particular concern to employers hiring third-country nationals.

Effect on sponsored workers and recruitment of third-country nationals

Employers recruiting foreign nationals must disclose the starting salary or range before the interview in the same way as for domestic candidates. This dovetails with immigration processes, where salary levels frequently feature in residence-and-work permit and visa criteria. Transparent, documented pay bands help employers demonstrate consistency between the remuneration offered to a foreign worker and the pay applied to comparable domestic roles, reducing the risk of both immigration and equal-pay challenges. Organisations recruiting overseas talent should align their immigration and recruitment documentation so that the disclosed range, the offer and the residence-permit paperwork are mutually consistent.

Cross-EU interplay for multi-state employers

Employers operating in several member states will encounter parallel transpositions of Directive (EU) 2023/970, each with national variations in thresholds and timing. A coordinated group-wide policy that meets the strictest applicable standard is often an efficient way to manage compliance across borders while respecting each jurisdiction’s specific rules.

Practical compliance checklist, immediate actions

With the reform approaching, employers should work through a structured set of actions. The following checklist prioritises the changes that must be in place before the first affected vacancy is advertised.

Audit vacancy templates and job descriptions

• Add a starting salary or defensible pay range to every vacancy template.
• Remove gendered language and ensure job titles are gender-neutral.
• Strip out any question or field that asks about current or previous pay.
• Ensure external recruiters use compliant templates and instructions.

Fix pay-range methodology and document the calculation

Establish a clear, written methodology for setting pay ranges based on objective, gender-neutral criteria such as role grade, market data, required qualifications and internal pay bands. Record how each range is derived so the calculation can be produced if a candidate or worker challenges it. A documented methodology serves a dual purpose: it satisfies the disclosure obligation and provides the evidence needed to justify any residual pay gap under the 5% trigger.

Clean and prepare reference-period data

Pay data must be organised by worker category, complete and accurate. Reconcile pay records, categorise roles consistently, and identify any gaps of 5% or more so they can be investigated and, where unjustified, corrected before a joint pay assessment becomes mandatory.

Train recruiters and HR on the pay-history ban

Brief everyone involved in hiring, including agency partners, that they must not ask candidates about pay history. Provide scripts for permitted questions focused on whether the disclosed range meets the candidate’s expectations, and explain how to handle a candidate who volunteers salary information. Employers should also coordinate this work with their wider hiring and immigration obligations and their internal legal advisers.

Model templates and record-keeping

Consistent documentation is the backbone of compliance. Employers should standardise the following records so that disclosure and decision-making can be evidenced. The samples below are examples only, seek legal advice before use.

Example job ad with pay disclosure

A compliant vacancy notice should state the role, its gender-neutral title, and a line such as: “Starting salary: €X–€Y per year, determined by experience and role grade.” Placing the range in the advertisement itself discharges the disclosure obligation transparently and creates a durable record.

Negotiation log and documentation template

Maintain a negotiation log capturing the date the pay range was disclosed, the format of disclosure, the points discussed, any figure volunteered by the candidate, and the final agreed pay with the criteria applied. Retain vacancy notices, the pay-range methodology and the reference-period data alongside the log. Together these records support both reporting and the defence of any equal-pay claim, where the burden falls on the employer to justify pay decisions.

Conclusion, key steps and next actions

Greece’s pay-transparency reform will require employers to disclose pay before candidates are interviewed, and the compliance work must be completed before the operational rules take effect. The immediate priorities are updating vacancy templates and job titles, embedding a documented pay-range methodology, ending all pay-history questions across internal and agency recruitment, and preparing reference-period data for the first gender pay reports. Employers must also be ready to justify any pay gap of 5% or more and to conduct a joint pay assessment where an unjustified gap is not corrected in time. Because the burden of proof in equal-pay disputes rests with the employer, rigorous record-keeping is not optional.

Organisations recruiting third-country nationals should align their immigration and pay documentation now, and should confirm the precise statutory dates and thresholds against the official Government Gazette. For advice on implementing these obligations, employers can consult a qualified immigration and employment lawyer in Greece.

Sources

1. Directive (EU) 2023/970 (Official Journal)
2. Government Gazette (Ethniko Typografeio)
3. European Commission, pay transparency policy overview
4. Hellenic Republic, central government portal (gov.gr)
5. OECD, gender wage gap data and analysis
6. International Labour Organization, equality at work resources