• Σχόλιο του χρήστη 'Remote Greece S.M.P.C.' | 17 Ιουνίου 2026, 20:48

    Remote is a global HR platform operating in 180+ countries, offering Employer of Record, Global Payroll and Contract Management solutions through a single, compliant platform. Remote participates in this consultation as an Employer of Record (EOR) provider operating in Greece through its local entity, Remote Greece S.M.P.C., which directly employs individuals in Greece to deliver employment-related services to its clients (ΓΕΜΗ no. 159109403000; ΑΦΜ 801558204 / VAT EL801558204), with its registered seat at Alexandras Avenue 116A, 4th Floor, 11471 Athens. Remote fully supports the objectives of Directive (EU) 2023/970 and of the draft, and the purpose of this submission is to ensure that the new obligations apply to the EOR model in a way that produces accurate and meaningful data, thus supporting the monitoring objectives of the competent authorities as well as employers and workers. **Article 7 - Pay structures** **The provision:** Every employer must establish and apply written, objective, gender-neutral pay structures that permit comparison across roles and categories, and may rely on collective-agreement classifications where bound by one. The Regulatory Impact Analysis states that these structures are set at the level of the employer that concludes the contract and must reflect the value of work in the specific organization. - **Remote's recommendation:** As drafted, the obligation rests on the EOR employer. In the EOR model, the role and its value are defined by reference to the client's service requirements rather than by a pay structure operated by the Remote entity across its workforce. Remote recommends ****that the Ministry clarify, in the text or accompanying guidance, that an employer whose role values are referable to individual client engagements may discharge this obligation by documenting and applying the objective, gender-neutral pay-setting criteria applicable to each engagement, because ****the relevant organization, in the EOR model, is the client engagement to which the role relates - the standard the Regulatory Impact Analysis itself adopts when it requires structures to reflect the value of work "in the specific organization".