Stella Vasdeki

Our Employment Law Briefing Special Edition analyzes Circular No. 26923 on Pay Transparency, issued by the Ministry of Labor and Social Security on 7 October 2026.

Bernitsas advised Golden Age Capital at major steps of their journey from before the firm was incorporated through to the final closing of its first fund, Golden Age Capital Private Equity Fund I.

Our Employment Law: Special Edition Briefing analyzes the Interpretive Circular 25291/23-09-2026 on the application of the Digital Work Card system to new sectors of the economy, issued by the Ministry of Labour and Social Insurance. 

Law 5316/2026 was voted by the Greek Parliament on 2 July 2026 and transposes Directive (EU) 2023/970 into Greek law by amending several Articles of the Greek Labor Code. The aim of this Briefing is to present the other amendments introduced by the Law to the Greek Labor Code on employment and pension matters, independent of the provisions concerning the transposition of the Directive, and specifically to provide an overview of the Articles in Parts B and C of the Law, which took effect on 6 July 2026.

Law 5316/2026 was voted by the Greek Parliament on 2 July 2026. It transposes Directive (EU) 2023/970 into Greek law by amending several Articles of the Greek Labor Code. The purpose of the Directive is to eliminate the gender pay gap for equal work or work of equal value, create transparent conditions for pay determination and progression, strengthen enforcement mechanisms and ensure access to effective remedies and restoration for affected workers.

This Briefing is intended for non-EU citizens who wish to invest in Greece, with a minimum capital commitment of €500k. Through such an investment, investors gain two significant benefits:
1.   eligibility for a favorable alternative taxation regime; and
2.   a residence permit in Greece for a minimum period of five years, with the right to travel freely within the European Schengen Area.

Following Ministerial Decision 8934/2026 published on 27 March 2026, the statutory minimum salary and daily wage in Greece will be increased for employees and workers as of 1 April 2026. 

Greece has always been an attractive destination to individuals from all over the world looking to relocate and has a framework in place for EU and third country nationals to apply for a residence permit. 

This Briefing provides an overview of Law 5275/2026, entitled 'Promotion of Legal Migration Policies' which amends the Immigration Code to establish a modern and effective legal migration framework. 

EU Directive 2023/970 of the European Parliament and the Council entered into force on 10 May 2023 and introduces provisions 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 reinforced enforcement mechanisms. 

Joint Ministerial Decision No. 216169/2025 entered into force on 14 November 2025 and introduces provisions relating to residence permits issued to executives of companies or subsidiaries of foreign companies established in Greece that engage in commercial activities. 

On 11 November 2025, Joint Ministerial Decision No. 214926/2025 was published in the Government Gazette and took effect. The Decision specifies the supporting documents required for granting and renewing permanent residence permits for real estate investors, widely referred to as Golden Visas, and the methods of certifying real estate investments involving a change of use or a listed property.

The Action Plan for Promoting Collective Bargaining in Greece (2026-2030), effective as of 1 January 2026, for a period of five years, was officially published on 17 December 2025. Within that Action Plan, the Government records and reproduces the full text of a ‘Social Agreement for the Strengthening of Collective Labour Agreements’. The Action Plan is expressly framed as part of Greece’s implementation of the EU policy on collective bargaining.

This Briefing provides an overview of the new Law 5239/2025 entitled Fair Work for All: Simplifying Legislation – Supporting Workers – Protection in Practice (the Law) which among others amends the Labor Code1 by introducing significant reforms regarding working hours, overtime and flexible/rotational/part-time work arrangements. 

By way of Ministerial Decision 16973/2025 of the Minister of Labor and Social Affairs (the Ministerial Decision) and the new interpretative Circular 26606/2025, the Digital Work Card is now applicable to the wholesale, energy and financial services sectors, as well as to administrative and support activities.