New Labour Framework: Reduction of Bureaucracy in Employment Relations
(Articles 5, 17, 18, 19, 20 & 21 of Law No. 5239/2025)

From the introductory article of the present section of our publications, it was already apparent that the recent labour law (Law No. 5239/2025) constitutes one of the most significant interventions in modern labour legislation. Its objective is, evidently, the regulation of important labour issues; also, the shaping of a new institutional framework for the operation of undertakings and their employment relations, with digital technology as a key tool; and, naturally, the reduction of bureaucracy.

Introduction

The relevant provisions of the law (Articles 5, 17, 18, 19, 20 & 21 of Law No. 5239/2025) lay the foundations for reducing bureaucracy, the substantive integration of digital tools into the day-to-day operation of undertakings and the modernisation of the organisation of employment relations. In other words, they constitute the necessary groundwork for the necessary and long-awaited/valuable flexibility in this field. The aim is, in essence, to eliminate the multitude of paper-based procedures that have burdened employers and accountants for decades while, at the same time, enhancing transparency and accessibility in terms of information regarding employment terms.

Article 5 – Information of employees through digital means

It is well established that the employer is obliged to provide employees with written information regarding the essential terms of their employment contract. The same applies to any changes thereto.

Under the previous legal framework, such information was provided:

(a) by delivery of a hard copy; or
(b) by use of electronic means, provided, however, that the employee had access to, and the ability to store and print, such information, while the employer was required to retain proof of dispatch or receipt by the employee.

Article 5 of Law No. 5239/2025 amended the relevant provision of Article 75 of Presidential Decree No. 62/2025. The employer’s obligation to inform may now be fulfilled by notifying the employee through the electronic application “MyErgani”, by means of the Digital Declaration of Commencement of Employment and the Digital Notification of Changes to Employment Relationship Data.

Under the new provision, the essential terms of employment (indicatively: information concerning remuneration, working hours, position of employment, leave) and any changes thereto are communicated immediately to the employee. The latter obtains permanent and easy access to the relevant information. Employers are relieved from the burden of managing physical files and documents. The employer–employee relationship becomes more transparent.

Article 17 – Abolition of the maintenance of physical registers and documents

Until now, every undertaking was required to maintain at the workplace a number of documents, such as personnel lists, internal work regulations, leave registers, etc. These documents had to be available in the event of an inspection by the competent Labour Inspectorate.

Article 17 of Law No. 5239/2025 reduces the relevant bureaucratic burden; it no longer constitutes grounds for the imposition of a fine:

(a) the non-posting of personnel lists and working time schedules, provided they are accessible in the ERGANI II Information System,
(b) the non-production of a leave register, which is abolished,
(c) the non-production of documents setting out the essential terms of individual employment contracts of staff, since (as already noted) these may now be communicated to the employee electronically, and
(d) the non-production of payslips of employees’ remuneration for at least the last three months, as wages are mandatorily paid by bank transfer and the relevant data are readily available upon request.

In practical terms, the abolition of the obligation to maintain the above documents entails a reduction in bureaucracy, relief from the associated administrative cost, simplification of the inspection process and, evidently, the release of resources for more productive activities.

Article 18 – Digital registration in “ERGANI II”

With the new law (Article 18 of Law No. 5239/2025), another unnecessary obligation of the employer is abolished: namely, the obligation to upload to the ERGANI II Information System the individual employment contract and its amendments. Additionally, the employee gains access to every declaration submitted by the employer through the “MyErgani” system, which is accessible either via the relevant website or through a digital application that the employee may install on their mobile device. In this case, the employee receives immediate notification on their mobile device for every declaration submitted by the employer.

Article 19 – Creation of a new digital application

With the new law (Article 19 of Law No. 5239/2025), a new electronic application for undertakings is introduced under the name “Ergani”. Through this application and by using the ERGANI II Information System access credentials, the employer is able to upload documents and submit declarations and relevant amendments submitted to the ERGANI II Information System, thereby directly serving the needs of the undertaking as they arise.

Article 20 – Electronic notification of commencement of employment

Perhaps the most significant provision in terms of reducing the bureaucratic burden is that of Article 20 of Law No. 5239/2025. By this provision, Article 578 of Presidential Decree No. 62/2025 is replaced and:

(a) the obligation to post basic terms of employment is definitively abolished, in respect of which we had set out our numerous concerns in earlier publications,
(b) the obligation to submit the Digital Declaration of Commencement of Employment and the Digital Notification of Changes to Employment Relationship Data is maintained.

It is noted that the Digital Declaration contains all essential terms of employment (Article 73 of Presidential Decree No. 62/2025) and is accepted by the employee either by handwritten or electronic signature or by using the “MyErgani” application, thereby fulfilling the information obligation of Article 75 of Presidential Decree No. 62/2025. No co-signature by the employer is required, as the employer’s data have already been authenticated upon entry into the system using their personalised credentials.

Article 21 – Recruitment to meet urgent needs

With the relevant provision of the recent law (Article 21 of Law No. 5239/2025), the current phase of efforts to simplify notification procedures and modernise the institutional framework governing employment relations is completed. By the new Article 578A of Presidential Decree No. 62/2025, the possibility is provided to cover urgent staffing needs of undertakings. The employer is afforded the option to conclude fixed-term contracts of up to two (2) days per week through a special electronic “Fast Recruitment” application.

In this way, the engagement of personnel is facilitated without delay due to the obligation to comply with formal procedures. Undertakings are provided with tools to respond to unforeseen needs without reducing the level of employee protection.

From bureaucracy to the new digital era

It is evident that all of the above reforms contribute to saving (and freeing up) time and resources for undertakings, enhancing the transparency of the employer–employee relationship, preventing undeclared work and simplifying the inspection process.

The effort to reduce bureaucracy and the administrative burden on undertakings, as well as to make substantive use of digital tools introduced by the new labour law, is clear. It is to be hoped that the latter does not merely constitute a technical reform. The simplification of employment relations and the integration of technology and its capabilities create space and time for the utilisation of creativity—an essential element for a labour market that evolves and does not become trapped in bureaucratic rigidities.

The path towards the next day of entrepreneurship undoubtedly passes (also) through the digitalisation of processes—including those relating to employment relations. No (reasonable) person could adopt a different approach. It nevertheless appears paradoxical that we achieve significant progress in combating bureaucracy while “turning a blind eye” to other (highly significant) issues affecting entrepreneurship, such as the issue of the recall of employees of critical specialisation, which we have addressed in earlier publications. Let us, however, focus on the positive provisions (such as part-time and rotating employment), which will be the subject of a subsequent publication.-

Stavros Koumentakis

Managing Partner

Koumentakis and Associates Law Firm