by Alexandros VYZIKIDIS and Maître Constantin KARAGOUNIS, Karagounis & Partners, Greece

I. INTRODUCTION

I.i. The publication of Presidential Decree P.D. 62/2025 marks a major reform of labor law in Greece. This text repeals P.D. 80/2022, entitled “Individual Labor Law Code,” and replaces it with a new Code. This regulatory intervention is not limited to a specific amendment: it constitutes a systemic overhaul of the legal framework applicable to labor relations.

I.ii. P.D. 62/2025 undertakes a vast codification and rationalization effort. It brings together in a single instrument all the rules relating to individual labor law (Articles 1 to 367), collective labor law (Articles 368 to 490), and occupational health and safety (Articles 491 to 560). Provisions concerning individual contracts, the organization and functioning of trade unions, collective bargaining, the exercise of the right to strike, worker participation at union level, and mechanisms for the prevention of occupational risks and digital supervision of activity are thus integrated into a coherent framework.

I.iii. Beyond codification, the new Code is based on eight major guidelines that structure the entire reform. It emphasizes the acceleration and simplification of recruitment procedures, reducing bureaucracy, modernizing labor relations, strengthening employee protection, improving occupational health and safety conditions, harmonizing with the International Labor Organization’s international conventions, institutionally strengthening the Labor Inspectorate, and coherently integrating social security rules. These priorities reflect the desire to update labor law, consolidate the guarantees offered to workers, and promote a more transparent working environment that is better suited to contemporary requirements.

I.iv. As a follow-up to this reform, Parliament adopted Law No. 5239/2025, entitled “Fair work for all: simplification of the legislative framework – support for employees – effective protection – provisions relating to pensions and other measures.” This Law introduces a series of amendments designed to supplement and adjust the provisions of P.D. 62/2025, particularly with regard to the organization of working time, social protection, leave, and the governance of pension institutions.

I.v. Taken together, Presidential Decree 62/2025 and Law No. 5239/2025 thus constitute a comprehensive reform of Greek labor law, combining administrative simplification, strengthening of employee rights, digital modernization, and alignment with international standards, with a view to achieving a balance between economic efficiency and social protection.

II. INDIVIDUAL LABOR LAW

II.1.i. Simplification of hiring and reduction of administrative formalities: The applicable law, as resulting from the recent reform, introduces a substantial simplification of hiring procedures and a significant reduction in the administrative burden on employers. From now on, the declaration of a new employee can be made using a single document, the Digital Declaration of Commencement of Employment, replacing the multiple forms previously required. All information relating to the employee is centralized in a digital file integrated into the ERGANI II system, which can be accessed and updated in real time.

II.1.ii. It is no longer necessary to submit a digital version of the employment contract or any amendments thereto: the declaration of employment, accompanied where applicable by a declaration of changes to the terms of employment, is sufficient to notify any changes. The platform also allows notifications to be sent automatically via myErgani, while a mobile app dedicated to employers offers features equivalent to those already available to employees, facilitating the day-to-day management of professional relationships.

II.1.iii. In the same spirit of digitization, several redundant obligations have been eliminated. The staff table, the leave register, the annual leave table (E11), and the annual staff table (E4) no longer need to be kept in paper form or displayed in the workplace, as they have been replaced by the digital organization of working time. In general, the obligation to keep printed documents, individual contracts, pay slips, or work schedules on site no longer applies when these documents exist in electronic format.

II.1.iv. In addition, a fast-track hiring procedure has been introduced for fixed-term, full-time or part-time contracts of up to two days per week, designed to meet urgent needs. This procedure, managed by a specific digital application, allows for immediate hiring and aims to enhance transparency and operational efficiency in companies.

II.1.v. Finally, employees are now able to declare the voluntary termination of their contract themselves via ERGANI II. The employer is automatically informed. An unjustified absence of more than three consecutive working days may be considered as resignation, provided that an additional period of two working days has elapsed after formal notice has been given, declared in the system and notified by any appropriate written means, with the employee being informed at the same time via myErgani. At the end of this period, the abandonment of the position must be declared electronically without the employee’s signature being required.

II.2.i. Overtime and organization of working time: The reform modernizes the overtime system by broadening the scope for organizing work while maintaining protective guarantees. The daily working time may be up to 13 hours with a single employer, under the same conditions as those previously allowed in the case of multiple employers, subject to compliance with mandatory rest periods. Employees may work up to 4 hours of overtime per day, up to an annual limit of 150 hours per employer. Each hour of overtime is paid at a rate 40% higher than the normal hourly rate.

II.2.ii. Employees nevertheless retain the right to refuse to work overtime when such refusal is made in good faith. Any termination of the contract based exclusively on such a refusal is expressly null and void.

II.2.iii. Overtime is also permitted in the context of shift work or intermittent work, a form of employment characterized by work performed on a reduced number of days, weeks, or months per year, while still working a full day.

II.3.i. Working time arrangements and four-day week: The new legal framework provides for a working time arrangement mechanism designed to increase organizational flexibility. Employers and employees may agree on a period of increased activity during which employees work up to two hours of overtime per day in addition to the normal eight-hour working day. These hours are not paid as overtime, as they are compensated by an equivalent reduction in working time during a subsequent “light” period.

II.3.ii. The reference period during which the periods of increased and reduced activity are balanced can now range from one week to 12 months. This arrangement allows, in particular, for the introduction of a 4-day week comprising 10-hour days for the whole year, subject to agreement between the parties. This arrangement can be a tool for reconciling work and family life, particularly for employees with parental responsibilities.

II.4.i. Paid annual leave: With regard to annual leave, the applicable law allows for greater flexibility in the distribution of rest periods. Employees may request in writing that their leave be split into several periods, one of which must include more than 6 working days in a 6-day week, more than 5 working days in a 5-day week, or at least 12 working days for minors.

II.4.ii. The previous rule requiring a minimum period of 10 or 12 working days in the event of splitting has been removed, which increases the freedom to organize leave in agreement with the employer.

II.4.iii. In addition, the granting of leave must now be reported in summary form in the ERGANI II system during the calendar month following the month in which it was taken, as the previous requirement to report immediately within one hour of the start of leave has been abolished.

II.5.i. Allowances and enhanced protection for employees: The reform strengthens social protection for employees and consolidates certain guarantees relating to parenthood. Parental leave benefits enjoy preferential treatment: they are tax-exempt, unseizable, and non-transferable. The system for recognizing periods of insurance for maternity benefits has been unified, with no minimum duration requirement with a single organization, thus facilitating access to benefits for employees who have experienced professional mobility.

II.5.ii. Protection against dismissal is extended to foster mothers, in parallel with the extension of postnatal maternity leave to employees in this role. This applies to workers registered in the national register of prospective foster parents to whom a minor has been entrusted by virtue of a competent judicial or administrative decision.

II.5.iii. Finally, any reduction in remuneration linked to the company’s integration into the digital work card system is considered an unfavorable change in working conditions and is therefore legally prohibited.

II.6.i. Digital work card: The reformed framework specifies the practical terms and conditions for the application of the digital work card. Companies that have integrated this system may enter into a written agreement providing for flexibility of arrival of up to 120 minutes per day. Digital clocking in and out must be carried out at the beginning and end of the declared working hours, after and before the period of preparation necessary for starting and finishing work.

II.6.ii. The maximum duration of this preparation period is set at 30 minutes for industrial companies and 10 minutes for other sectors. Three isolated recordings per month are tolerated when they are not the result of unjustified negligence. Beyond that, an inspection may be triggered if the irregularities cannot be justified by the nature of the work, the organization of working time, force majeure, or objective impossibility.

II.6.iii. All of these provisions are part of a drive to modernize labor law digitally, with the aim of ensuring better traceability of working time while preserving the fundamental rights of employees.

III. PROVISIONS RELATING TO HEALTH AND SAFETY

The applicable framework for health and safety at work is part of a strategy of enhanced prevention and systematic reduction of occupational risks. The reform consolidates existing institutional mechanisms, modernizes control tools, and strengthens the alignment of domestic law with international standards.

III.1.i. Strengthening of representative bodies: The role of Occupational Health and Safety Committees and their representatives is strengthened to ensure more active worker participation in prevention policies. The Internal Protection and Prevention Services also see their powers consolidated with a view to continuously improving working conditions and proactively managing risks.

III.2.i. Organization of prevention and employer responsibilities: The classification of companies by risk category, according to sector of activity, is updated to reflect contemporary production realities. The list of specialties authorized to perform the duties of safety technician and occupational physician is also updated, ending a system that had remained unchanged for several decades. The presence of a health and safety coordinator becomes mandatory in technical projects and on construction sites, depending on their size, with the explicit aim of preventing workplace accidents.

III.2.iii. The threshold below which the employer may personally perform the duties of safety manager is lowered to 20 employees (from 50 previously) for companies falling within the relevant risk categories. When these duties are assigned to employees or external service providers, the employer must send the Labor Inspectorate a detailed list of the material infrastructure available (personal protective equipment, instruments for measuring harmful agents, etc.) and the personnel responsible for ensuring compliance with health and safety obligations.

III.2.iv. The employer is also required to inform the safety technician and the occupational physician of any changes planned in the production process or in the organization of work (training, specialization, operating procedures, introduction of new equipment, or assignment of new employees to specific tasks). The observations and instructions issued by these professionals must be recorded exclusively in writing in a special register kept in electronic form within the Labor Inspectorate’s Integrated Information System, which facilitates controls and enhances traceability.

III.3.i. Reporting of occupational diseases: Employers are required to report any occupational disease to the Labor Inspectorate and the relevant social security body within five days of receiving information from the occupational physician or the presentation of a diagnosis by a physician from the national health system.

III.3.ii. The system also provides for improved recording of occupational diseases through the introduction of more precise criteria for recognition, contributing to greater statistical reliability and increased protection for workers.

III.4.i. First aid training: Particular attention is paid to training workers in first aid. The employer must provide training in cardiopulmonary resuscitation (CPR) and the Heimlich maneuver.

III.4.ii. In companies with up to 50 employees per facility, this training may be provided using educational materials and videos made available free of charge by the competent authority. In companies with more than 50 employees at the same facility, face-to-face training provided by certified first aid organizations is mandatory for at least half of the staff every three years. These measures reflect a preventive approach aimed at enhancing everyday safety in the workplace.

III.5.i. Information systems and institutional cooperation: An Integrated Information System, called “IRIDANOS,” has been set up to document, centralize, and monitor all issues related to occupational health and safety.

III.5.ii. Companies may directly entrust the implementation of preventive measures to External Protection and Prevention Services, the Hellenic Institute for Occupational Health and Safety (ELINYAE), as well as higher education institutions or research centers, thereby promoting enhanced institutional and scientific cooperation.

III.5.iii. At the same time, the applicable framework provides for the operational strengthening of the Labor Inspectorate. The protection of its agents is consolidated, in particular by increasing penalties for acts of violence or obstruction of inspections. Organizational and logistical adjustments aim to improve the effectiveness of interventions throughout the country, including in island areas.

III.6.i. Harmonization with international standards: Finally, the reform enshrines the alignment of domestic law with international standards through the ratification of major International Labor Organization instruments: Convention No. 155 concerning Occupational Safety and Health and the Working Environment, Convention No. 191 recognizing occupational safety and health as a fundamental principle, and the 2014 Protocol to Convention No. 29 concerning forced or compulsory labor. Through this normative integration, the national legal framework gains increased international legitimacy and strengthens the coherence of its protection system.

IV. PROVISIONS RELATING TO SOCIAL SECURITY

The applicable social security framework is being adjusted to clarify the rules for calculating benefits, modernize the functioning of the competent bodies, and ensure a more equitable allocation of benefits.

IV.1.i. Exemption from contribution surcharges: An exemption from social security contribution surcharges is provided for when the increase in remuneration results from overtime, additional work , night work, or work on Sundays and public holidays.

IV.1.ii. This exemption is extended to additional remuneration provided for in collective agreements and to increases granted voluntarily by the employer. The aim is to prevent the actual increase in remuneration from being offset by a disproportionate contribution burden, while preserving the balance of the system.

IV.2.i. Pensioners’ Solidarity Contribution: The basis for calculating the Pensioners’ Solidarity Contribution and the Special Contribution for Pensioners to Supplementary Insurance is adjusted for pensioners who are in employment.

IV.2.ii. It is expressly provided that when a retired employee acquires the right to an increase in their pension as a result of their activity, this additional benefit is not taken into account in determining the applicable Solidarity Contribution rate. As a result, the pension increase cannot automatically lead to a decrease in the net amount received.

IV.2.iii. In addition, organizational measures are being introduced to modernize the governance of pension organizations, in particular by allowing postal voting in their internal operations.

IV.3.i. Maternity benefits and insurance periods: With regard to maternity benefits (pregnancy and postpartum), all insurance periods completed as an employee with the competent national body are now taken into account when verifying whether the required insurance period has been met.

IV.3.ii. This unification of the calculation of insurance periods aims to ensure greater continuity of rights, particularly for employees who have changed employers or had discontinuous career paths.

V. CONCLUSION

V.i. The reform of labor law in Greece constitutes a major and structural transformation of the national legal framework, aimed at modernizing and simplifying all the rules applicable to work. It offers greater flexibility in the organization of working time, notably allowing for the adoption of a 4- -day week and the free distribution of annual leave in agreement with the employer.

V.ii. Occupational health and safety are strengthened through the formalization of the role of safety technicians and occupational physicians, the requirement to record observations in writing and digitally, the mandatory presence of safety coordinators on construction sites, and the increased role of health and safety committees and internal prevention services. Mandatory first aid training, systematic reporting of occupational illnesses, and alignment with ILO international conventions ensure a safe working environment that complies with international standards.

V.iii. In social matters, the rights of employees and retirees are consolidated: exemption from social security contributions on overtime, night work, public holidays, and extra work, including those provided for in collective agreements or voluntary agreements with employers, guarantees fair net pay. Protection relating to parental leave and dismissal has been strengthened, while insurance periods are fully recognized for the calculation of maternity and postnatal benefits, including for adoptive mothers.

V.iv. At the same time, businesses benefit from a substantial reduction in administrative burdens thanks to the elimination of redundant formalities and the introduction of digital tools such as the ERGANI II system and the digital work card. The modernization of the classification framework for companies and safety engineer specialties, as well as the possibility of delegating certain measures to research institutes or centers, enhance the efficiency and flexibility of obligation management.

Overall, this reform reflects the desire to create a balanced, safe, flexible, and digitally integrated working environment that reconciles employee protection with business competitiveness and efficiency, while ensuring compliance and international harmonization.

Athens, February 27, 2026

Alexandros VYZIKIDIS
Attorney at Law, Piraeus Bar Association
Graduate in French law

Constantin KARAGOUNIS
Attorney at Law
Member of the Paris and Athens Bars
Advisor to the French Embassy