Employer's Checklist for Hiring Non‑eu (third‑country) Nationals in Greece, Visas, Payroll & Law 5275/2026 Compliance

Employing third-country nationals in Greece has entered a new regulatory era. Law 5275/2026, which transposes the recast EU Single Permit Directive (Directive (EU) 2024/1233) into Greek law, restructures the way employers sponsor, onboard and manage non‑EU workers, from the mandatory national (Type D) visa stage through single‑permit issuance, payroll registration and ongoing renewals. For HR directors, in‑house counsel and global mobility managers, the practical consequence is a longer compliance chain that links immigration sponsorship directly to social security, tax and labour‑law obligations. This guide provides a step‑by‑step employer checklist covering every stage of hiring non‑EU workers in Greece under the 2026 framework, with document lists, timelines and actionable templates.

Last updated: July 20, 2026. This article reflects the provisions of Law 5275/2026 as published in the Official Government Gazette (FEK). Implementation details, particularly exact processing windows and contribution thresholds, remain subject to ministerial decisions and administrative guidance. Employers should verify current requirements with the relevant authority or qualified Greek immigration counsel.

Executive Summary, At‑a‑Glance Employer Checklist

Before diving into the detail, use the checklist below as a quick reference for hiring non‑EU workers in Greece. Each item maps to a full section later in this guide.

• Confirm employer eligibility and complete the labour‑market test (LMT). Verify that the role qualifies for third‑country national hiring and, unless an exemption applies, obtain clearance from the Hellenic Ministry of Labour.
• Prepare the employment contract with mandatory clauses. Include role description, salary (meeting minimum thresholds), working hours, duration and termination provisions.
• Sponsor the employee’s national (Type D) visa. Compile the D‑visa sponsorship package, employer invitation letter, contract, proof of LMT compliance, company registration documents, and support the employee’s consular application.
• Ensure the employee enters Greece on the D‑visa. Entry on a tourist/Schengen visa does not satisfy the single‑permit pathway under Law 5275/2026.
• File the single‑permit application via the Ministry of Migration portal. Upload the full dossier through applications.migration.gov.gr within the prescribed window after the employee’s arrival.
• Register the employee with EFKA and AADE. Obtain the employee’s social security number (AMKA/PAAYPA) and tax identification number (AFM), ideally within the first days of employment.
• Set up compliant payroll. Configure withholding for income tax, employee social security contributions and employer contributions from month one.
• Monitor renewal deadlines, role changes and termination triggers. Diarise permit expiry dates, notify the migration authority of any employment changes, and comply with exit‑reporting obligations if the contract ends before the permit expires.

If any step in this checklist is unclear or the role falls into an unusual category, seasonal, investor, intra‑company transfer or digital‑nomad arrangement, seek specialist immigration advice early in the process.

What Changed in 2026, Quick Guide to Law 5275/2026 for Employers

Law 5275/2026 represents the most significant overhaul of Greece’s employer obligations for immigration since the original Immigration Code (Law 4251/2014). The legislation transposes Directive (EU) 2024/1233, the recast Single Permit Directive, into Greek national law, while simultaneously updating visa categories, permit durations and procedural requirements that directly affect employer workflows.

Key Legislative Changes

• Single‑permit pipeline. Greece now operates a unified application procedure: the employer or employee files one application that is assessed jointly for both the residence and work authorisation, replacing the previous multi‑step process that required separate work‑permit approvals in many cases.
• Mandatory D‑visa entry requirement. For most employment‑based categories, the employee must enter Greece on a national (Type D) visa specifically issued for the purpose of employment. This pre‑entry step is now a formal prerequisite for single‑permit issuance.
• Extended initial permit duration. Standard skilled‑employment single permits may now be issued for an initial period of up to three years (previously shorter initial periods applied in many categories), reducing the administrative burden of early renewals.
• Reworked seasonal and investor categories. The law introduces updated seasonal‑worker rules aligned with EU requirements and refines the investor/entrepreneur residence pathway, each with distinct employer obligations.

Can You Hire Non‑EU (Third‑Country) Nationals? Legal Preconditions for Employing Third-Country Nationals in Greece

Greek law permits employers to hire third‑country nationals provided specific preconditions are met. These preconditions exist to protect the domestic labour market while allowing employers to fill genuine skills gaps.

Labour‑Market Test, When It Is Required

For most standard employment categories, the employer must demonstrate that the position could not be filled by a Greek, EU/EEA or already‑authorised resident worker. This labour‑market test (LMT) is administered through the Hellenic Ministry of Labour and Social Affairs. The employer submits a vacancy notification and, after the prescribed advertising period, obtains clearance confirming that no suitable domestic candidate was available.

Certain categories are exempt from the LMT. Industry observers expect the exemption list under Law 5275/2026 to include:

Employer Eligibility and Record Keeping

The employer must be lawfully established in Greece, current on social security contributions (EFKA) and tax filings (AADE), and free from outstanding sanctions for prior immigration violations. Maintaining clean compliance records is not optional, it is a prerequisite for the migration authority to accept the single‑permit application.

Sanctions for Non‑Compliance

Employing a third‑country national without a valid work authorisation exposes the employer to administrative fines, potential criminal liability for repeated or serious offences, and a bar on future sponsorship applications. The employee faces deportation and a re‑entry ban. Early legal advice is essential if any compliance gap is identified.

Pre‑Hire and D‑Visa Sponsorship, Employer Responsibilities

The D‑visa sponsorship stage is where employer obligations under Law 5275/2026 begin in earnest. The employer is not merely supporting a visa application, it is making a formal commitment that underpins the entire single‑permit pathway.

Step‑by‑Step Sponsorship Process

1. Define the role and complete the LMT (if required). Prepare a detailed job specification. Submit the vacancy to the Ministry of Labour. Retain evidence of the advertising period and clearance certificate.
2. Issue a compliant employment contract. The contract must state: the role title and duties; gross salary (meeting any applicable minimum‑wage thresholds); working hours and schedule; contract duration; probation terms; and termination provisions aligned with Greek labour law. The contract should be in Greek (and, as a practical matter, also in a language the employee understands).
3. Prepare the employer sponsorship letter. Address the letter to the Greek consulate in the employee’s country of residence. Key points to include: confirmation that the role is genuine; that the employer has completed the LMT (or that an exemption applies); that adequate accommodation will be available; and that the employer commits to registering the employee with EFKA and AADE.
4. Compile the D‑visa document package. The employer’s contribution to the consular file typically includes the items listed in the table below.
5. Support the employee’s consular appointment. The employee submits the D‑visa application at the competent Greek consulate. The employer should be prepared to respond to supplementary requests from consular staff.

D‑Visa Document Checklist (Employer’s Share)

Do Digital Nomads Need a D‑Visa?

The answer depends on the nature of the working arrangement. If a digital nomad is employed by a foreign employer, performs work remotely from Greece and does not enter a local employment relationship, a standard employment D‑visa may not apply, but that does not mean no visa is required. Greece introduced a digital‑nomad visa category in prior legislation, and Law 5275/2026 maintains a distinction between locally employed workers and remote workers serving foreign employers. Employers should not assume that a remote arrangement automatically exempts them from Greek immigration or tax obligations; each case requires individual assessment.

The Single Permit, Application, Issuance and Timelines for Employing Third-Country Nationals in Greece

Once the employee has entered Greece on a valid D‑visa, the next stage is the single‑permit application. This is the centrepiece of the Law 5275/2026 employer checklist and the point at which immigration and employment law intersect most closely.

When the Employee Arrives, Entry Formalities

On arrival, the employee should retain a stamped copy of the D‑visa and any border‑entry documentation. The employer should confirm the employee’s arrival date and immediately begin preparing the single‑permit application dossier for upload to the Ministry of Migration portal.

Filing the Single‑Permit Application

1. Access the Ministry of Migration portal. Applications are filed electronically through applications.migration.gov.gr.
2. Upload the required documents. These include: the D‑visa copy; the signed employment contract; employer registration and clearance certificates; the employee’s passport, photographs and medical certificate; proof of health insurance; and any category‑specific documents (e.g., degree apostilles for skilled roles).
3. Pay the application fee. Fee amounts are set by ministerial decision and vary by permit category.
4. Receive the filing confirmation and interim legal‑stay certificate. While the application is pending, the employee typically holds lawful status in Greece on the basis of the filed application and D‑visa.
5. Attend any biometric appointment. The employee may be required to attend in person for biometric data capture at the relevant migration office.

How to Follow Up Application Status

Employers and employees can track the progress of a residence‑permit application through the official portals. The Ministry of Migration’s main portal at applications.migration.gov.gr provides case‑status updates. Additionally, the Ministry of Interior portal at pf.emigrants.ypes.gr allows third‑country nationals to check the status of their applications using their case reference number.

Typical Processing Times

Industry observers report that standard skilled‑employment single‑permit applications are typically processed within a range of approximately six to twelve weeks, although times vary significantly depending on the migration office workload and the completeness of the dossier. Seasonal permits and investor‑category applications may follow different tracks with shorter or longer timelines. If processing exceeds the expected window, the employer should seek legal assistance to escalate the matter through formal channels.

Permit Categories, Eligibility and Employer Obligations

Payroll, Tax and Social Security Onboarding, EFKA, AADE and the Employer Checklist

The moment a third‑country national begins work in Greece, the employer’s payroll and social security obligations are identical to those owed for any Greek or EU employee, with the added requirement to verify and retain proof of the worker’s immigration authorisation. This section covers the critical first‑30‑day actions for employers hiring non‑EU workers in Greece.

EFKA Registration, Social Security

The Unified Social Security Fund (EFKA) is the single point of registration for social security in Greece. Employer steps:

1. Confirm employer registration. If the company is already registered with EFKA as an employer, no new registration is needed. New employers must register before hiring their first employee.
2. Obtain the employee’s AMKA/PAAYPA. The employee must obtain a social security registration number. For third‑country nationals, this may require attending a KEP (Citizens’ Service Centre) or EFKA office with their passport, D‑visa or residence‑permit receipt and tax number.
3. File the hiring notification (Ergani system). The employer must submit an electronic hiring declaration through the Ergani platform before the employee’s first day of work. Late filing triggers automatic fines.
4. Commence contribution withholding. From the first payroll cycle, the employer must withhold the employee’s social security contribution share and add the employer’s contribution share. Combined employer and employee contributions cover pension, healthcare, unemployment, and supplementary funds.

AADE Registration, Tax

The Independent Authority for Public Revenue (AADE) manages tax registration and payroll withholding obligations. Employer steps:

1. Ensure the employee obtains an AFM (tax identification number). Third‑country nationals apply for an AFM at the local tax office (DOY) or, where available, through an authorised representative. Required documents typically include the passport, D‑visa or permit receipt, and proof of address in Greece.
2. Configure income‑tax withholding. Greek employers are obligated to withhold income tax at source according to the progressive income‑tax scale. The withholding applies from the first salary payment.
3. File monthly and annual employer returns. Monthly payroll declarations and annual employer information returns must be filed electronically through the AADE myAADE platform.

First‑30‑Day Employer Timeline

Special Cases, Remote Workers and Secondments

Where a third‑country national is seconded to Greece by a foreign employer, the payroll and social security position depends on whether a bilateral or EU social security agreement applies (for secondments from the employee’s home country), whether the foreign employer registers a Greek branch, or whether a local co‑employment or employer‑of‑record arrangement is used. Each model carries different EFKA and AADE obligations. Remote workers serving foreign employers without a Greek establishment face a separate analysis, the employer must confirm whether a taxable presence (permanent establishment) is triggered in Greece, and whether the worker’s Greek tax‑residency status creates withholding duties.

Renewals, Transfers, Termination and Reporting Obligations

Employing third-country nationals in Greece is not a one‑off compliance event. Law 5275/2026 imposes ongoing obligations throughout the employment lifecycle, and failure at the renewal or termination stage can retroactively compromise the employer’s compliance record.

Renewal of Single Permits

The employer should diarise the permit expiry date and begin the renewal process well in advance, a minimum of two to three months before expiry is advisable. The renewal application is filed through the same Ministry of Migration portal. Required documents are substantially similar to the initial application but must reflect the current employment terms, updated EFKA and AADE clearances, and evidence that the employment relationship is continuing.

Transfer of Employment or Change of Role

If the employee changes employer or changes role within the same employer, the migration authority must be notified. Under the single‑permit framework, a change of employer typically requires a new or amended permit application. A change of role with the same employer may require notification depending on whether the new role falls within the same permit category. Employers should not assume that an existing permit covers a materially different position.

Termination Checklist and Final Reporting

When an employment relationship ends before the permit expires, the employer must:

• File an Ergani termination declaration within the prescribed timeframe.
• Notify the migration authority. The employer is obligated to inform the competent migration office that the employment has ended. This is essential because the single permit is linked to the specific employment relationship.
• Complete final payroll obligations. Pay any outstanding salary, accrued leave and statutory severance. Remit final EFKA contributions and income‑tax withholding.
• Retain records. Greek labour law requires employers to retain payroll and employment records for a minimum of five years. Immigration‑related records (permit copies, sponsorship letters, LMT evidence) should be retained for the same period or longer, as they may be required in the event of a compliance audit.

Audits and Record Retention

The Labour Inspectorate (SEPE) and migration authorities may audit employer records at any time. Maintaining a complete, well‑organised file for each third‑country national employee, covering immigration, payroll, social security and tax documentation, is the single most effective compliance safeguard.

Practical Templates, Red Flags and Employer Best Practices

Structured internal processes reduce the risk of compliance gaps. The following template elements and red‑flag indicators are drawn from the practical requirements of Law 5275/2026 and the employer obligations described in the preceding sections.

Template Clause Snippets (Non‑Exhaustive)

Employment contracts for third‑country nationals should include, at a minimum, the following clause elements (adapted to Greek labour law requirements):

• Immigration‑status clause. “This contract is conditional upon the Employee holding and maintaining a valid residence and work authorisation for Greece throughout the term of employment.”
• Cooperation clause. “The Employee shall cooperate fully with the Employer in obtaining and renewing any required visa, residence permit or work authorisation, including providing documents and attending appointments as reasonably required.”
• Termination trigger. “The Employer may terminate this contract if the Employee’s residence and work authorisation is revoked, expires without renewal, or becomes invalid for any reason, subject to applicable Greek labour law protections.”
• Data‑processing notice. “The Employer will process the Employee’s personal data, including immigration documents, for the purpose of compliance with Greek immigration and employment law, in accordance with the General Data Protection Regulation (GDPR).”

Employer Red‑Flag Checklist

• Expired or missing D‑visa at entry. Do not allow the employee to commence work if entry was not on the correct visa type.
• Delayed Ergani filing. Filing the hiring declaration after the employee has started work triggers automatic fines.
• No AMKA/PAAYPA obtained. Payroll cannot run compliantly without a social security number.
• Permit expiry missed. If a permit expires without a pending renewal application, the employee is working without authorisation, immediate legal advice is essential.
• Role change without migration notification. A material change in duties or employer without updating the permit can invalidate the work authorisation.

Conclusion, Building a Compliant Employer Framework for Hiring Non‑EU Workers in Greece

Employing third-country nationals in Greece under Law 5275/2026 demands a structured, end‑to‑end approach that begins well before the employee boards a flight and continues through every payroll cycle and permit renewal. The single‑permit framework simplifies the immigration application itself, but it raises the stakes for employers: the employment contract, EFKA registration, AADE compliance and ongoing migration reporting are now tightly coupled steps in a single compliance chain. Employers who invest in robust internal processes, compliant contracts, timely Ergani filings, proactive renewal tracking and clean record keeping, will find the system manageable. Those who treat immigration as a one‑off HR task risk fines, sponsorship bars and operational disruption.

For complex cases, specialist Greek immigration counsel can provide the case‑specific guidance that no checklist can replace. To connect with an experienced immigration lawyer in Greece, visit the Greece lawyer directory.

Change log: This article was first published on July 20, 2026, reflecting Law 5275/2026 as published in the Official Government Gazette (FEK). It will be updated as ministerial decisions, implementing decrees or significant administrative guidance are issued. Readers should verify current requirements with the relevant Greek authority or qualified counsel.

Sources

1. EUR-Lex, Directive (EU) 2024/1233 (Single Permit Directive)
2. Ministry of Migration & Asylum, Applications Portal
3. Ministry of Interior, Third-Country National Application Status Portal
4. Hellenic Ministry of Labour & Social Affairs
5. EFKA, Unified Social Security Fund
6. AADE, Independent Authority for Public Revenue
7. European Commission, Migration & Home Affairs
8. IOM Greece