Greece's Pay Transparency Law Is Now in Force: Will This Year's Bonuses and Gift Card Rewards Show Up in Your 2027 Pay Gap Report?

What changed on November 1

Greece wrote Directive (EU) 2023/970 into national law with Law 5316/2026, published in the Government Gazette on July 6, 2026, a month after the EU's June 7 transposition deadline. Most of the operational duties were deferred to November 1. Ahead of that date the Ministry of Labour and Social Insurance issued a circular (No. 26923 of October 7) with instructions, a model pay structure and links to calculation tools, and announced it on October 8. Greek media ran the start date again over the weekend, with Greek City Times reporting the ministry's position via the Athens-Macedonian News Agency on November 2.

According to the ministry, the circular applies to employees, employers and job candidates in the private sector that fall under its remit. From November 1, four things apply:

• Written pay structures for every employer. Regardless of headcount, employers must have and apply pay structures that guarantee equal pay for equal work or work of equal value. They must be documented in writing, allow jobs to be compared, include a review procedure and identify the pay elements of each category of worker. Criteria must cover skills, effort, responsibility and working conditions, and may add seniority and relevant soft skills. Employers bound by a collective agreement can use its job categories and pay scales. (Lewis Silkin notes that employers with fewer than 50 staff are exempt from providing pay-progression information.)
• Pay before the first interview. Candidates are entitled to the starting pay or its range, and the collective-agreement terms for the role, before the first interview. Job ads may not mention sex or family status, and employers may not ask about pay history.
• Pay information on request. Employees can ask in writing for their own pay level and the average pay, by sex, of colleagues doing equal work or work of equal value. The answer is due within two months, and employers must remind staff of this right every year.
• Gap reporting for 100+ employees, on the timetable below, and a joint pay assessment with employee representatives where an average gap of at least 5% in any category is unexplained by objective, gender-neutral criteria and not corrected within six months.

Why reward teams should care: variable pay is reported on its own

Most coverage of the law has focused on salary ranges in job ads. For anyone who runs bonuses, recognition or gift card programs, the more important part is the list of seven indicators that employers with at least 100 employees must send to the Greek Ombudsman. Four of them are about “complementary or variable” pay, which is reported next to, not inside, base salary:

1. the overall gender pay gap;
2. the gender pay gap in complementary or variable pay;
3. the overall median gender pay gap;
4. the median gender pay gap in complementary or variable pay;
5. the share of women and of men who receive complementary or variable pay;
6. the share of women and of men in each pay quartile;
7. the gender pay gap by category of worker, split into ordinary basic pay and complementary or variable pay.

Whether a given reward counts is a legal question for Greek counsel, but the definition is broad. In Lewis Silkin's summary of the law, pay covers basic or minimum salary plus “any other cash or in-kind consideration received directly or indirectly in respect of work”, including variable remuneration. Benefits in kind sit inside that wording. Neither the ministry's announcement nor the law-firm summaries we read mention gift cards or vouchers by name, so the safe working assumption is that a gift card given for performance, a milestone or a sales result is variable pay unless an adviser tells you otherwise.

The practical consequence is that indicator 5 is a simple head count: how many women and how many men received any variable pay at all. A recognition program where awards cluster in one team, one shift pattern or one level can move that number even when the amounts are small.

The reporting timeline

Sources differ on emphasis rather than substance here. DLA Piper's July summary describes reporting as applying to employers with 150 or more employees from 2027; the ministry's announcement adds the 100–149 tier with its first deadline in 2031. On request, the Labour Inspectorate or the Ombudsman can also ask for indicator 7, with an answer due within two months and up to four years of past data where it exists.

The open question is the period the first report covers. Lewis Silkin reads the text as running from July 6 to December 31, 2026, but notes the Ministry of Labour has unofficially pointed to November 1 to December 31, 2026, pending further circulars. Either way, the window includes this year's holiday season.

Enforcement and the burden of proof

Fines run from €300 to €50,000 per violation, imposed by the Labour Inspectorate, according to both Lewis Silkin and DLA Piper; Lewis Silkin adds that repeated serious breaches can lead to temporary closure and that the Inspectorate keeps a register of sanctioned employers. The ministry stresses judicial and administrative routes for workers, full compensation for those affected, and protection against retaliation. Lewis Silkin highlights two points that shift risk onto employers: if an employer does not provide the requested pay-setting information within 15 days in a dispute, that counts as a failure to justify the difference, and compensation is uncapped, explicitly covering bonuses and payments in kind.

Quick questions

We have five employees in Athens. Does any of this apply? Yes, in part. Written pay structures, pay ranges for candidates and the right to request pay information apply regardless of headcount. Gap reporting starts at 100 employees.

Does the law cap or ban gift cards and bonuses? No. It does not limit what you pay or give; it requires you to be able to explain differences with objective, gender-neutral criteria and to report them.

Is the rest of the EU live too? Not yet everywhere. The directive's transposition deadline was June 7, 2026; Greece passed its law a month later, and each member state sets its own start dates. Our pay transparency statistics for 2026 collect the wider evidence, and the CFO framework for a rewards budget shows how to document award rules alongside the money.