Εργασίας και Κοινωνικής Ασφάλισης

Δικτυακός Τόπος Διαβουλεύσεων

• Σχόλιο του χρήστη 'Remote Greece S.M.P.C.' | 17 Ιουνίου 2026, 20:24

  Μόνιμος Σύνδεσμος

  ### Explanatory note 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. The defining feature of the model, and the reason for this submission, is that the characteristics of the employment relationship differ materially from the traditional model on which the draft is built. Under the Employer of Record service, the Remote entity engaged an employee to perform a defined role connected to a specific client engagement. The scope and budget of that role originate from the client’s service requirements; the Remote entity enters into and holds the employment contract, agrees the remuneration with the employee, and carries the full range of employer responsibilities, including payroll, tax and social security, and statutory compliance. Because each engagement responds to a distinct client project, the remuneration applicable to a given employee is fixed by reference to that specific engagement rather than to any single pay policy operated by Remote across its workforce. A single Remote entity is therefore, at the same time, the employer of many employees engaged on unrelated client engagements, across different sectors and roles, whose remuneration is fixed by reference to each separate engagement. The draft transposition is constructed, understandably, around the traditional model of a single employer that determines pay for its own workforce under a unified pay policy. It does not contemplate an employer whose workforce is distributed across many separate client engagements, each with its own role scope and pay basis. The obligations governing pay-structure design, comparator identification, gender pay-gap reporting and joint assessment each assume a coherent pay policy set a single employer for a single workforce. Applied to the EOR model without adaptation, these obligations may produce distorted results. Aggregating employees engaged on unrelated client engagements into a single comparator group, or into a single report, yields figures that correspond to no single pay policy. Apparent pay differences so produced are attributable to the distinct client engagements - an objective, gender-neutral factor - rather than to any single pay policy of the employer, and risk being mischaracterized as discrimination. The same aggregation generates reporting and remediation duties that cannot be meaningfully discharged, because the resulting figures reflect multiple separate client engagements rather than a unified pay structure. 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. As suggested by the public consultation launched here by the Greek Government, Remote is submitting its formal contribution, article by article, on the topics relevant to its activities in the country.