Pay Transparency from 1 November 2026
What businesses need to prepare during October
From 1 November 2026, the key provisions of Law 5316/2026 on pay transparency and equal pay for men and women performing the same work or work of equal value will come into force.
On 7 October 2026, the Ministry of Labour also issued Circular 26923/S.5/07-10-2026, providing further guidance on the practical implementation of the new framework.
The most important change is that all employers, regardless of the number of employees, must have and apply a documented pay structure.
A pay structure is essentially the framework through which a business determines remuneration. It should be based on objective, gender-neutral criteria, allow positions to be compared in a consistent way, and identify the elements that make up the remuneration of each category of employees.
The assessment of a role should not be based solely on its job title. Factors such as skills, effort, level of responsibility and working conditions must be taken into account, together with other relevant elements such as seniority where appropriate.
This does not mean that two employees must necessarily receive the same salary. It does mean, however, that where employees performing the same work or work of equal value are paid differently, the business must be able to justify that difference through objective criteria.
At the same time, the concept of “pay” is broader than basic salary. It may include bonuses, additional and variable remuneration, allowances and benefits in cash or in kind. Businesses should therefore also review how decisions are made regarding bonuses and other benefits, and whether those decisions are based on clear and objective criteria.
New rules during recruitment
The new framework also significantly affects recruitment procedures.
Job applicants must be informed of the initial pay or pay range for the position in good time before the first interview or, where no interview takes place, before the employment contract is concluded.
At the same time, employers or persons acting on their behalf are no longer permitted to ask candidates about their pay history in previous employment.
Job advertisements, job titles and recruitment procedures must also be gender-neutral.
New employee right to information
From 1 November, employees may request in writing information regarding:
- their own pay level; and
- the average pay levels, broken down by sex, for categories of employees performing the same work or work of equal value.
This does not mean that an employee has the right to know the individual salary of a specific colleague.
The employer must respond within two months and must also inform employees, on an annual basis, of the existence of this right and of the procedure through which it may be exercised.
Additional obligations for companies with 100 or more employees
Larger employers will also be subject to specific gender pay-gap reporting obligations.
Companies with:
- 250 employees or more must submit their first report by 7 June 2027 and annually thereafter.
- 150–249 employees must submit their first report by 7 June 2027 and every three years thereafter.
- 100–149 employees must submit their first report by 7 June 2031 and every three years thereafter.
Where a gender pay gap of at least 5% is identified within a category of workers, cannot be justified by objective and gender-neutral criteria, and is not remedied within six months, a joint pay assessment may be required.
Why preparation should start now
1 November is not a filing deadline. It is, however, the date from which the core obligations begin to apply.
October should therefore be used as a preparation period.
Businesses should start reviewing:
- their existing job roles and job descriptions;
- salary levels;
- bonuses, allowances and benefits;
- the objective criteria used to determine pay differences;
- salary ranges for future recruitment;
- recruitment procedures; and
- the process for handling employee information requests.
The Ministry’s circular also includes an indicative model for organising a pay structure, covering the recording, description, assessment, classification and ranking of positions.
The change is therefore substantial.
Payroll compliance will no longer be limited to whether an employee’s salary has been calculated correctly.
Increasingly, employers will also need to be able to demonstrate that the way in which pay was determined is objective, transparent and free from discrimination.
Early preparation is particularly important, as the new framework also provides for administrative sanctions, the possibility of full compensation for affected employees and, in certain cases, a shift in the burden of proof to the employer.
The objective is not to make all salaries identical. The objective is to ensure that every pay decision can be explained and objectively justified.
Update on the anticipated 120-instalment arrangement
According to the public announcements made to date, a new arrangement for the settlement of tax debts in between seventy (70) and one hundred and twenty (120) monthly instalments is expected in the near future. Based on the announcements so far, the arrangement is expected to cover debts assessed by 31 December 2024 that have not been included in an arrangement by 30 September 2026.
An arrangement allowing the payment of debts in up to seventy-two (72) monthly instalments is currently in force. The announced new arrangement of up to one hundred and twenty (120) instalments has not yet been incorporated into published legislation.
At present, neither the final legislative text for the new arrangement nor the relevant circular or other required implementing regulations and administrative guidance has been published. Accordingly, the announcements to date, including the range of between seventy (70) and one hundred and twenty (120) instalments and the above-mentioned time-related eligibility conditions, are not final. Based on the announcements to date, a transition from the current arrangement of up to seventy-two (72) instalments to the new arrangement of up to one hundred and twenty (120) instalments is expected to be available upon submission of a new application. However, the procedure, conditions and consequences of such transition have not yet been determined. It is not yet possible to confirm with certainty the debts that will qualify, the maximum number of instalments for each category of debt, any income or asset criteria, possible reinstatement conditions for previously lost arrangements, the minimum monthly instalment, applicable interest charges, or the deadline for submitting an application.
We are awaiting the publication of the relevant legislation and the implementing guidance of the Tax Administration in order to clarify the eligibility criteria, terms and application procedure. Until then, any reference to a specific number of instalments or particular eligibility requirements should be treated as indicative only and not as final.
Electronic Safety Technician Recommendations Book – What businesses need to know
A new procedure has been introduced regarding the Safety Technician and Occupational Physician Recommendations Book, which will now be maintained electronically through the Greek Labour Inspectorate’s information system.
In practice, recommendations made by the Safety Technician or Occupational Physician will now be entered electronically. The employer will be notified of new entries and will be required to electronically acknowledge that they have been received.
Once a recommendation has been officially submitted, it cannot simply be amended or deleted. If a correction is required, a new entry must be made, ensuring that a complete record of recommendations is maintained.
If your business works with an external Safety Technician, we recommend that you contact them and confirm that they are aware of the new procedure and that future recommendations will be recorded electronically.
If you personally act as the Safety Technician for your own business, this particular update does not apply to you in relation to this procedure.
There is no reason for concern. This is primarily a change in the way the relevant records and recommendations are maintained and communicated between the Safety Technician and the employer.
For any clarification regarding how this change affects your business, please reply to this email, so that our team can review your specific case and assist you accordingly
End of the Tourist Season: What Seasonal Businesses Should Prepare for in Advance
As we gradually approach the end of the tourist season, it is important for seasonal businesses to start preparing now for the end dates of their employees’ contracts, any possible extensions, and the increased payroll cost that usually comes with the closing of the season.
The end of a seasonal employee’s employment does not simply mean calculating their final monthly salary. At the end of their contract, all final payroll calculations must be completed and their employment and payroll records must be properly settled.
The end of the season usually brings increased payroll costs
Depending on each employee’s individual circumstances, the following may need to be calculated when their employment ends:
- the proportional Christmas Bonus,
- holiday allowance,
- any compensation for unused annual leave,
- overtime, additional working hours or other outstanding remuneration,
- as well as the corresponding social security and tax liabilities, where applicable.
For this reason, the total payroll cost in the month when seasonal contracts end may be significantly higher than during an ordinary month of operation.
In addition to the amounts paid directly to employees, the company’s obligations towards EFKA and payroll withholding tax may also increase, depending on the final remuneration calculated.
Businesses should therefore plan their cash flow in advance and should not treat the final month of the season as an ordinary payroll month.
The above mainly applies to businesses where bonuses and allowances are calculated upon termination of employment. In cases where certain amounts are already calculated proportionally throughout the season, the additional cost at the end of the season will naturally be different.
Please inform us in advance about both contract terminations and extensions
One of the most important things we ask our clients is not to wait until the employee’s final working day before informing us that their employment is coming to an end.
Please send us an email with the exact last working day of each employee, so that our payroll team has sufficient time to complete all the necessary procedures.
It is equally important to inform us in advance of any extension or renewal of a fixed-term employment contract.
If an employee is going to continue working beyond the end date originally declared, you must inform us before the existing contract expires, so that the relevant change can be submitted on time.
It should not be assumed that, simply because an employee continues to work, the extension is automatically reflected in the relevant systems. We must receive the information in good time and preferably in writing, so that the actual employment relationship corresponds to what has been officially declared.
For this reason, businesses should inform us promptly about both:
- contract terminations, and
- contract extensions or renewals.
Timely notification is essential in order to avoid late submissions, corrective procedures and unnecessary exposure for the business.
Ending a contract involves several procedures
The end of seasonal employment involves much more than simply submitting one form to ERGANI.
We need to review working days, annual leave, remuneration, bonuses and allowances, Digital Work Card records where applicable, social security obligations and the employee’s final payroll calculation.
The earlier we receive the information, the more accurately and efficiently we can complete the entire process.
What you should know about unemployment benefits for seasonal employees
After the end of their employment contract, many employees may wish to apply for unemployment benefits through DYPA.
Our team can also assist employees with this procedure, if they wish.
However, particular attention should be paid to the fact that the end of an employment contract does not automatically mean that an employee is entitled to unemployment benefits.
For employees working in seasonal businesses, one of the basic requirements is generally to have completed at least 100 days of insured employment within the relevant reference period examined by DYPA. The exact requirements may differ depending on whether the employee has worked for one or two consecutive seasons, whether they are applying for unemployment benefit for the first time or have received it previously, as well as their overall insurance and unemployment benefit history.
For a seasonal employee who has already received unemployment benefit in the past, approximately four full months of actual employment can serve as a first practical indication that they may be approaching the required number of insured days.
However, this does not guarantee eligibility, as DYPA assesses each employee individually, based on their actual insurance history and the applicable reference periods.
For this reason, neither the employer nor the accounting office can know in advance, without reviewing the employee’s individual insurance record, whether that employee will ultimately qualify for unemployment benefits.
We can assist your employees with their unemployment benefit applications
If you would like us to assist your employees with the submission of their unemployment benefit applications, please let us know in the same email in which you inform us of their contract end dates.
If any additional documents or information are required for an unemployment benefit application, we will let you know so that everything can be provided in good time.
For security reasons, we do not recommend sending employees’ personal TAXISnet credentials by ordinary email. Where access or representation is required, our team will advise you on the appropriate and secure procedure.
Start preparing for the end of the season now
The end of the tourist season creates a significant volume of payroll work within a very short period of time each year. For this reason, timely and accurate communication between the business and the payroll department is extremely important.
Our main recommendation is simple:
Please inform us in good time, by email, which employees will be ending their employment, what their actual final working day will be, and which contracts will be extended or renewed.
In particular, any extension must be communicated to us before the originally agreed contract end date, so that the relevant change can be submitted within the required deadline and unnecessary problems can be avoided later.
This allows us to prepare the final payroll correctly, inform you of the expected cost, complete all required declarations and, where requested, assist your employees with their unemployment benefit applications.
The payroll team of ETERON BUSINESS SOLUTIONS remains at your disposal for any clarification or assistance you may need during the closing of this year’s season.
