Greece’s new pay transparency law is already changing the rules for employers, and the tourism industry may be among the sectors with the most work to do before the first mandatory reporting deadlines arrive.
Law 5316/2026, published on July 6, 2026, incorporates the EU Pay Transparency Directive into Greek law and introduces new requirements covering how employers determine, document, and communicate pay. The law applies broadly to employers, while the separate obligation to report gender pay gap data is linked to workforce size.
That distinction matters for tourism businesses. A small hotel is not automatically exempt from the new pay-transparency rules simply because it falls below the reporting threshold.
What Tourism Employers Must Do Now
Employers must have documented pay structures based on objective, gender-neutral criteria, enabling comparisons across jobs and employee categories. The criteria must take into account factors such as skills, effort, responsibility, and working conditions, and must be accessible to employees.
The recruitment process is also changing.
Job applicants must receive information about the initial pay or pay range in good time before an interview or, where there is no interview, before an employment contract is concluded. Employers and anyone acting on their behalf are also prohibited from asking candidates about their current or previous salary history.
Employees can request written information about their own pay level and the average pay levels, broken down by sex, for workers performing the same or work of equal value.
Why Tourism Faces a Challenge
The new framework could be especially significant for hotels and other tourism businesses given the sector’s structure.
Housekeeping, reception, and other traditionally female-dominated occupations can coexist with predominantly male roles in maintenance, technical services, and some kitchen positions. The law requires employers to have a system capable of assessing work of equal value using objective, gender-neutral criteria rather than simply comparing identical job titles.
Variable pay is another important issue.
The calculations for employers required to report pay-gap information include gross annual pay, combining basic salary with supplementary and variable remuneration. The calculation rules also cover part-time and temporary workers.
For tourism businesses that use temporary agency workers, the indirect employer must include those workers in its reporting, while the temporary employment agency must provide the necessary pay data.
The Seasonal Workforce Problem
Seasonality makes the timing particularly important for tourism.
The law determines the size category for pay-gap reporting based on the average number of employees during the previous calendar year, rather than simply counting how many people happen to be working at the hotel on a single day.
That means a business that expands dramatically during the summer cannot assume that its winter workforce tells the whole story.
For businesses approaching the reporting thresholds, this year’s employment data therefore deserves attention now.
Who Has to Report the Gender Pay Gap?
The mandatory reporting obligation applies to employers with at least 100 employees.
Businesses with:
- 250 or more employees must submit their first report by June 7, 2027, and then annually thereafter.
- 150 to 249 employees must submit their first report by June 7, 2027, and then every three years.
- 100 to 149 employees must submit their first report by June 7, 2031, and then every three years.
- Fewer than 100 employees may submit the information voluntarily every three years.
The reports cover much more than a single headline percentage. They include the overall gender pay gap, the median gap, differences in supplementary and variable pay, the proportion of women and men receiving variable remuneration, the distribution of men and women across pay quartiles and the pay gap within employee categories.
The 5% Threshold
A significant issue arises when reported data shows an average pay difference of at least 5% between women and men in an employee category, where the difference cannot be justified using objective, gender-neutral criteria and is not corrected within six months.
In that situation, the employer must carry out a joint pay assessment with employee representatives.
The law also strengthens employees’ ability to seek information and challenge unexplained pay differences, while shifting important aspects of the evidentiary burden toward employers in discrimination cases.
Tourism Businesses Should Not Wait for 2027
The biggest mistake for a tourism business would be to treat June 2027 as the start of preparation.
For businesses subject to the first reporting deadlines, the law requires information concerning the previous calendar year. The workforce count itself is also based on the previous year’s average.
In practical terms, tourism businesses should already be looking at how they classify jobs, set salaries, distribute bonuses and other variable payments, and can explain differences between employee categories using objective criteria.
For smaller businesses, the formal reporting obligation may not apply, but the wider pay-transparency requirements do.
From Compliance Problem to Recruitment Tool
For an industry that relies heavily on seasonal recruitment, transparent pay could eventually become more than a legal requirement.
Hotels and tourism businesses that can clearly explain how they determine salaries, bonuses, and career progression may have an advantage when competing for workers.
The new law does not require every tourism business to publish its entire payroll.
It requires employers to explain how they determine pay, demonstrate that their system is based on objective, gender-neutral criteria, and provide workers with access to pay information.
For Crete’s tourism industry, this is a change worth paying attention to before the next season begins.
