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January 16, 2023

Kelly Papadaki, Ioanna Kyriazi and Panagiota Petropoulou

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Digital work card

A new system of monitoring employees’ working time is currently introduced under Greek labor law. In accordance with the relevant provisions, all companies / employers in Greece are obliged to operate an electronic system which will be directly connected with the ERGANI II platform (electronic platform of the Ministry of Labor) in real time; working time will be monitored through the use of a digital work card.

Phase A of the implementation process of the digital work card includes the registration before the electronic platform of the Ministry of Labor (i.e. the ERGANI II platform) of all details regarding their employees’ employment relationships. As of 11 January 2022 and until the end of 2022, all employers (except for banks and supermarkets which already have implemented the relevant procedure as of July 2022) are obliged to register all their employees to the updated ERGANI II platform. Each company shall submit a “declaration for the amendment of information related to the employment relationship”, declaring all details related to each employee’s working time and each employee’s working schedule in a digital form. As of the completion of this registration process for each employee, the employees’ working schedule will appear digitally in the form of a calendar.

Within the following year 2023 and following the completion of Phase A (registration process), Phase B of the implementation process of the digital work card will be enacted. The digital work card will then be implemented gradually to different business sectors, taking into account the particularities and the operational needs of the relevant sectors and following relevant consultation with the employers’ and the employees’ representatives. According to a recent announcement of the Greek Ministry of Labor, the first business sectors to implement the digital employment card within the next few months will be insurance and security companies.



Indisputably, whistleblowing is one of the most effective ways to expose fraud and unearth useful information on financial crimes and general acts of corruption in both the public and private sector. Greece recently introduced the new Law No. 4990/2022 (enacted in November 2022) in compliance with the provisions of the European law and in particular the Directive (EU) 2019/1937 regarding whistleblowing.

The purpose of the new Law No. 4990/2022 is to ensure a comprehensive framework for the protection of persons who report violations of Union law, transposing the corresponding Directive (EU) 2019/1937 of the European Parliament and of the Council into the Greek legal framework. To this end, the Law establishes a system for internal and external reporting of violations of Union law, the protection of reporting persons, the organization of the procedure for the submission, receipt and follow-up of reports and the sanctions to be imposed in case a violation occurs.

In accordance with the newly introduced provisions, private sector companies are expected to establish internal reporting channels by appointing an Officer for Receipt and Follow Up on Reports. In particular, companies with 50 or more employees are required to appoint an Officer and companies employing fewer than 50 employees may optionally appoint an Officer. Companies operating in financial sector services, products and markets, transport and environment sectors, as well as companies operating under an environmental permit decision, or whose activities may, by their nature, pose a risk to the environment and public health, must appoint an Officer regardless of the number of employees.


Transparent working conditions

The increase of the number of workers in precarious and non-standard forms of employment including zero-hour contracts, part-time, temporary, platform and on-demand work in combination with the latest changes and developments in labor markets in general underline the need for more transparent and predictable working conditions. In light of the abovementioned, on the EU level the Directive (EU) 2019/1152 on transparent and predictable working conditions has been adopted. The Directive (EU) 2019/1152 provides more extensive and modernized rights for all workers in the EU. In particular, the relevant provisions include a right to receive certain written information on the essential aspects of the employment relationship, a limit to the length of probationary periods, a duty for the employer to provide cost-free mandatory training to workers, restrictions on the use of restrictive covenants and the right to be informed in advance in case of provision of additional work. The Directive requires Member States to bring into force the laws and regulations necessary to comply with same by 1 August 2022.

In light of this development, it can be reasonably expected that within the next months, increased legislative activity in the area of transparent and predictable working conditions laws will take place across EU Member States, including Greece. In the Greek legal framework, there are several actions that must be taken in terms of compliance with the relevant Directive. For example, the existing law, which requires employers to inform employees of the conditions applicable to their employment relationship, will need to be updated in order to reflect the increased standards set by the new EU Directive.

With thanks to Kelly Papadaki, Ioanna Kyriazi and Panagiota Petropoulou of KG Law Firm for their invaluable collaboration on this update.




Impact of #Metoo movement and developments in law to prevent sexual harassment

The global #Metoo movement seems to be motivating more and more individuals, both women and men, to reveal their personal stories linked to sexual abuse, both within and outside the workplace. This trend is expected to continue into 2022.

Νewly introduced employment law 4808/2021 (enacted in June 2021), which ratified the convention concerning the elimination of violence and harassment in the world of work, extends the scope of cases falling under the framework of sexual harassment and provides victims with specific fighting options and rights, while introducing more responsibilities on employers to prevent unlawful behaviour.

In accordance with these new provisions, private companies employing more than 20 employees are expected to adopt preventive policies in fighting violence and harassment (including sexual harassment) and create internal channels for handling relevant claims, which must be further included in the Employees’ Internal Regulation. In addition, the employer is burdened with extra obligations to prevent and deal with incidents of harassment at the workplace, to inform employees, and assist the authorities in handling relevant complaints. Employers should therefore adapt their internal policies and procedures to comply with these new requirements.


Increased legislative activity relating to whistleblowing

Whistleblowing is one of the most effective ways to expose fraud and unearth useful information on financial crimes and general acts of corruption in both the public and private sector. Currently, there is no specific legal regime in Greece protecting whistleblowers from reporting corruption and related wrongdoings. Civil society groups are urgently calling for reforms.

At EU level, the Whistleblower Directive (EU) 2019/1937 has been adopted, which establishes certain obligations upon large private companies with regards to the implementation of internal reporting policies and other measures to protect whistleblowers. The Directive required Member States to bring into force the laws and regulations required to comply with the same by 17 December 2021, however we understand that this deadline was not observed.

Employers will be required to adopt internal measures and procedures for dealing with whistleblowers’ claims and protecting whistleblowers against reprisals and/or dismissal. Although the Directive refers to wrongdoing relating to EU law, such as tax fraud or money laundering, it remains to be seen whether Greece will extend such protection to other offenses as well.


Legislative support for hybrid/flexible working arrangements

The COVID-19 pandemic has demonstrated that work from home and other flexible working arrangements can be indeed a feasible alternative for office employees. During the past few months, in view of the further easing of COVID-19 restrictions, many companies have been shifting to hybrid working models, combining remote work with office time. It seems that hybrid working is becoming a popular option for both employees and businesses.

In this context, recent Law 4808/2021 provided for a more comprehensive framework regarding teleworking and alternative working arrangements, securing certain employee rights, such as the right to disconnect. In 2022, an increase in employment contracts providing for a hybrid work week is expected. An important anticipated development in this regard is the introduction of the electronic work card; a key measure to help ensure that working time limits are respected and related rights are complied with (i.e. the right to disconnect). At first, it is anticipated that a pilot scheme will be implemented in big companies (such as banks and supermarkets), which will gradually become mandatory for all private sector businesses.




Teleworking and flexible working arrangements

Teleworking remains a key topic for Greece. During the past months, many employees have been relegated to work from home. The experience has demonstrated that teleworking can be a feasible alternative for office employees. When talking about "the new normal," flexible working arrangements (i.e., work from home arrangements) are a cornerstone of such conversation. Hence, a subsequent increase in employment contracts providing for a hybrid work week (i.e., a work week divided between workplace and home) are expected the following year.


Employees' well-being and the right to disconnect

Employees' mental health and work life balance constitutes a rising concern in the Greek labour market. To that end, companies are increasing cooperation with therapists and support lines and organizing wellness sessions and initiatives for their employees. Especially now, with the rising trend to shifting to teleworking arrangements, employees' right to disconnect is anticipated to turn into a much-debated topic.


Digitalization and cybersecurity

The employment landscape is being reshaped driven largely by the requirement of digital transformation. As digitalization advances, a growing concern will follow as to cybersecurity and the protection of corporate and employee data. Key topics include employees' online monitoring and information and personal data security related measures.




Teleworking in the COVID-19 era

Although teleworking has been regulated in Greece since 2006, it has not been very common in practice until recently. However, teleworking is expected to become more popular as a result of COVID-19.


Digital transformation

The megatrend of digitalisation, as well as related trends, such as digital consultation meetings between employers and employee representatives and 'digital terminations', is beginning to have a significant impact on the Greek labour market. Recent legislative changes set out a general framework for digital working.


Ongoing consideration of employee data protection issues

The EU General Data Protection Regulations 2016/679 (GDPR) remains a key topic in 2020. Employee data protection has a particular impact on areas, such as employees' access control and monitoring of work time. The Greek Data Protection Authority has issued guidance (in line with the relevant European Union Agency Cybersecurity recommendations) on best practices for working from home in order to mitigate the cybersecurity and data privacy risks associated with remote working.

With thanks to Ioanna Kyriazi, Kelly Papadaki, Alkistis Vallianatou and Theodora Liameti of Kyriakides Georgopoulos Law Firm for their invaluable collaboration on this update.

For More Information

Image: Suzanne Horne
Suzanne Horne

Partner, Employment Law Department

Image: Kirsty Devine
Kirsty Devine

Associate, Employment Law Department

Image: Aashna Parekh
Aashna Parekh

Associate, Employment Law Department

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