How Greek Employers Must Comply with Law 5275/2026: Immigration Compliance Checklist for 2026

Last reviewed: 18 May 2026

Greece’s new Immigration Code, Law 5275/2026, published in Government Gazette A’ 17 on 6 February 2026, represents the most substantial overhaul of immigration compliance in Greece in over a decade. For every HR manager, General Counsel and mobility team responsible for hiring non-EU workers in Greece, the reform reshapes work permit sponsorship duties, introduces new visa categories, tightens reporting deadlines and significantly raises the penalties for non-compliance. This guide translates the legislation into an actionable, employer-focused checklist covering pre-hire clearance through to post-termination record-keeping, so that organisations operating in Greece can build, or update, a defensible compliance programme before the next inspection cycle.

What Changed Under Law 5275/2026, Employer-Facing Summary

Law 5275/2026 consolidates and amends Greece’s existing Immigration and Social Integration Code (formerly governed by Law 4251/2014 and its numerous amendments). The new law transposes key EU directives on seasonal workers, intra-corporate transferees and highly qualified employment into a single, modernised framework. For employers, the practical effect touches every stage of the hiring lifecycle, from vacancy advertising through to permit cancellation after termination.

The principal changes that affect employer obligations Greece-wide include the following:

• Digitalised processing. Residence and work permit applications can now be submitted and tracked through the Ministry of Migration & Asylum’s online portal, reducing in-person appointments and accelerating decision timelines.
• New visa categories. The Z.15 national visa (the “talent” visa, valid for 12 months) and the Z.16 student/traineeship visa are introduced, each carrying distinct employer sponsorship requirements, as outlined in PwC’s Legalflash briefing on Law 5275/2026.
• Seasonal visa adjustments. Seasonal work visa Greece provisions are tightened: employers must pre-register seasonal positions, provide accommodation evidence and submit return-travel guarantees before a visa is issued.
• Extended initial permit durations. Standard initial residence permits for employment may now be granted for up to three years (previously two), with corresponding changes to renewal windows.
• Heavier sanctions. Administrative fines for employing third-country nationals without a valid permit are increased, and criminal facilitation exposure has been broadened, according to the Machas & Partners legal snapshot on the amendments.
• Employer reporting duties. Notification deadlines for commencement, change or termination of employment are shortened, and failures to report trigger standalone penalties.

Key Dates and Legislative References

Which Permits Are Affected

The following permit types are directly impacted by the reforms and carry specific employer obligations under immigration compliance Greece rules:

• Standard employment residence permit (dependent employment for third-country nationals)
• EU Blue Card Greece (highly qualified employment)
• Seasonal work permit (agriculture, tourism, hospitality)
• Intra-corporate transferee (ICT) permit
• Z.15 talent visa (national visa, 12 months)
• Z.16 student/traineeship visa
• Independent economic activity permits (where an employer-sponsor relationship applies)

Top 10 Employer Obligations Under Law 5275/2026, Immigration Compliance Greece Checklist

This section consolidates the core duties every employer must fulfil when hiring non-EU workers Greece. Use the numbered items below as a working checklist. Each obligation is mapped to the phase of the employment lifecycle in which it arises.

1. Pre-Hire Clearance and Labour Market Considerations

• Confirm that the position is open to third-country nationals under current labour market needs, as published periodically by the Ministry of Labour.
• Check whether a labour market test (vacancy publication and evidence that no EU/EEA candidate is available) is required for the specific permit type. EU Blue Card and Z.15 talent visa routes may have reduced or waived labour market testing, as noted in the Bernitsas Law overview of Law 5275/2026.
• Retain evidence of the recruitment process (advertisements, applicant logs, rejection rationale) for potential inspection.

2. Document Verification and Certified Translations

• Collect and verify the prospective employee’s passport, educational qualifications, professional licences and, where applicable, apostilled or consular-legalised documents.
• Ensure all foreign-language documents are accompanied by certified Greek translations from a Greek consulate or authorised translator.
• Retain certified copies, do not rely on the employee’s originals remaining available after onboarding.

3. Work Permit Application Sponsorship Duties

• Prepare and submit the employer’s sponsorship declaration (often referred to as the “employer invitation” or “employer request”) to the competent Decentralised Administration or, where the digital portal is active, via the Ministry of Migration & Asylum’s online system.
• Include all employer-specific supporting documents: current tax clearance certificate, social security compliance certificate, proof of commercial registration and evidence of business activity.
• For seasonal work visa Greece applications, also submit the seasonal roster, accommodation proof and return-travel guarantee.

4. Residence Permit Submission and Communication Obligations

• Ensure the employee (or employer on their behalf, where permitted) files the residence permit application within the statutory window after arrival in Greece.
• Track the application number and monitor the status through the online portal or the regional migration directorate.
• Communicate any changes in the employee’s role, salary or work location to the migration authority promptly, the deadline under Law 5275/2026 is shorter than under prior rules.

5. Contracts, Salary Thresholds and Social Security Registration

• Execute a written employment contract in Greek (and, as good practice, in the employee’s language) before the employee commences work.
• For EU Blue Card Greece applications, verify that the offered salary meets the minimum threshold (typically 1.5 times the average gross annual salary in Greece, per the implementing provisions).
• Register the employee with EFKA (the Unified Social Security Fund) on or before their first day of work, late registration is an independent violation under Greek labour law and may also jeopardise immigration compliance Greece obligations, as highlighted by the Ministry of Labour’s guidance on third-country nationals.

6. Onboarding Steps, Right to Work Checks

• Conduct a formal right-to-work check: verify the employee holds a valid residence permit (or valid visa plus pending-application receipt) authorising employment before work begins.
• Record the permit type, permit number, expiry date and any conditions or restrictions.
• Store a certified copy of the permit in the employee’s personnel file and flag the expiry date in a centralised tracking system.

7. Ongoing Monitoring and Permit Renewal Workflow

• Set automated alerts no fewer than 90 days before each permit’s expiry date.
• Initiate the renewal application process in advance, under Law 5275/2026, timely filing preserves the employee’s lawful status while the renewal is pending, but late filings do not attract the same protection.
• Re-verify the employee’s right to work after each renewal and update internal records accordingly.

8. Record Keeping and Data Retention

• Maintain copies of all permits, sponsorship declarations, contracts, social security registrations and correspondence with migration authorities for a minimum of five years after the employment relationship ends.
• Payroll records should be retained for the standard Greek statutory retention period (currently a minimum of five years, with industry observers noting that tax-related records may require ten-year retention).
• Ensure records are stored in compliance with GDPR requirements, access restricted, retention justified and deletion procedures documented.

9. Reporting to Authorities, Notifications and Changes of Employment

• Notify the competent migration authority of the commencement of employment within the prescribed timeframe set out in Law 5275/2026.
• Report any material change (role change, salary adjustment, new work location, secondment) to the authority without delay.
• Report termination of employment promptly, failure to notify may result in the employer being deemed to have facilitated illegal stay.

10. Handling Terminated Employees and Permit Cancellation

• Upon termination, notify both the migration authority and EFKA of the employment’s end.
• Inform the former employee in writing that their residence permit may be affected and advise them to seek independent legal advice on their immigration status.
• Retain the terminated employee’s immigration file for the prescribed retention period, do not destroy records immediately after departure.

Document Checklist by Permit Type

Step-by-Step: Hiring a Non-EU Worker in Greece, Timeline and Templates

Understanding the typical sequence and duration of each step helps employers plan recruitment timelines and avoid costly delays. The table below maps the process from job offer to the employee’s first day of work, based on the procedures set out under Law 5275/2026 and the Ministry of Migration & Asylum’s published guidance.

Timeline Table

Industry observers expect that the digitalisation measures under Law 5275/2026 will gradually compress the review periods at Step 4 and Step 8 as the online portal matures, though early experience in 2026 suggests employers should still plan conservatively.

Sample Employer Template Checklist

Employers are encouraged to adapt the Greek immigration law employer checklist below into their internal onboarding workflow. A printable version can be downloaded and customised for each permit type:

• ☐ Labour market test completed (if applicable) and evidence filed
• ☐ Candidate documents collected, verified and translations certified
• ☐ Employer sponsorship declaration prepared and submitted
• ☐ Work permit approval received and filed
• ☐ Employee visa confirmed; travel arrangements coordinated
• ☐ EFKA registration completed on or before Day 1
• ☐ Employment contract executed (Greek language, signed by both parties)
• ☐ Right-to-work check completed; permit details logged
• ☐ Residence permit application filed within statutory window
• ☐ Permit expiry date flagged in renewal tracking system
• ☐ Migration authority notified of employment commencement
• ☐ Personnel file complete; document retention policy applied

Seasonal Work, Talent (Z.15) and Other New Visa Regimes, Practical Notes for Employers

Law 5275/2026 introduces and restructures several visa routes that carry distinct employer obligations. Understanding the differences is essential for work permit compliance Greece-wide.

Seasonal Work Visa, Employer Responsibilities and Documentation

The seasonal work visa Greece framework has been tightened under the new law. Employers in agriculture, tourism and hospitality must now pre-register each seasonal position with the competent migration authority before initiating recruitment. Key documentation includes a seasonal employment contract specifying the engagement period, proof of suitable accommodation arranged by the employer, and evidence of a return-travel guarantee (such as a pre-booked return ticket or financial bond). The employer must also submit seasonal rosters listing all anticipated seasonal hires for the period. Failure to pre-register or provide accommodation evidence may result in the application being rejected outright, according to the Zepos & Yannopoulos practical guide on the new immigration law.

Z.15 Talent Visa (12-Month National Visa), Who to Sponsor and How

The Z. 15 national visa is a new category introduced by Law 5275/2026, designed to attract specialised talent to Greece for projects or engagements lasting up to 12 months. According to PwC’s Legalflash briefing on the new immigration law, the Z. 15 is available to individuals with demonstrable specialist skills, including technology professionals, researchers and creative-industry workers. The employer’s role centres on issuing a formal invitation letter describing the project, the individual’s qualifications and the anticipated duration. Unlike the standard employment permit, the Z. 15 does not automatically convert to a multi-year residence permit, early indications suggest the likely practical effect will be that employers who wish to retain Z.

15 holders beyond 12 months will need to transition them to a standard employment permit or EU Blue Card route before the visa expires.

EU Blue Card and Alternative Routes, Comparison

The EU Blue Card Greece route remains the primary pathway for highly qualified employment. Under Law 5275/2026, the EU Blue Card framework is updated to align with the recast EU Directive, offering enhanced intra-EU mobility rights and reduced processing friction. Employers must ensure the offered salary meets the legally prescribed threshold and that the position genuinely requires higher professional qualifications. For roles that do not meet the Blue Card salary or qualification threshold, the standard employment permit or, for shorter engagements, the Z.15 talent visa may be more appropriate. A side-by-side assessment at the recruitment planning stage helps avoid mid-process route changes that delay onboarding.

Reporting, Inspections and Penalties Under Law 5275/2026

One of the most consequential areas of the reform for employers is the strengthened enforcement regime. Law 5275/2026 increases both the frequency and severity of penalties for immigration non-compliance, while also streamlining the inspection process for labour and migration authorities.

Employers should be aware that inspections may be triggered by routine audits, employee complaints, social security discrepancies or cross-referencing between the migration authority and the labour inspectorate. The Machas & Partners legal snapshot on Law 5275/2026 highlights that the amendments broaden the definition of “facilitation of illegal stay” to capture negligent as well as intentional employer conduct, a significant expansion of criminal exposure.

The European Commission’s overview of migration management in Greece provides additional context on EU-level enforcement expectations that underpin several of these penalties.

Immigration Compliance Greece, Employer Policies, Retention and Audit Steps

Establishing a documented compliance programme is no longer merely best practice, under Law 5275/2026, the ability to demonstrate a proactive compliance programme may serve as a mitigating factor during inspections and penalty proceedings. Industry observers expect that regulators will increasingly differentiate between employers who have structured programmes and those who treat compliance as an afterthought.

Sample Document Retention Policy

At minimum, employers should retain the following categories of records for the prescribed periods. Where official guidance has not yet specified exact durations for all document types under the new law, the retention periods below align with established Greek labour and tax law practice and the requirements flagged in connection with Greece’s 2026 migration law changes:

• Residence and work permit copies. Retain for a minimum of five years after the employment relationship ends.
• Employer sponsorship declarations and correspondence with migration authorities. Retain for five years post-termination.
• Employment contracts (including amendments). Retain for five years post-termination, consistent with the Greek Civil Code limitation period.
• Payroll records and social security registration evidence. Retain for a minimum of five years; retain tax-related payroll records for ten years to cover potential tax audit periods.
• Right-to-work check records. Retain for five years post-termination or five years after the permit’s expiry, whichever is later.
• Seasonal rosters, accommodation evidence and return-travel guarantees. Retain for five years after the seasonal engagement ends.

Internal Audit Checklist, Quarterly Items

• ☐ Review permit expiry tracker, confirm all permits are current or renewal applications are pending
• ☐ Verify that every active third-country national employee has a valid right-to-work record on file
• ☐ Confirm all commencement, change and termination notifications have been filed with the migration authority
• ☐ Check EFKA registration status for all permit-holding employees
• ☐ Review any changes to ministerial decisions or implementing regulations issued since the last audit
• ☐ Test record-retrieval procedures, ensure immigration files can be produced within one business day for inspection
• ☐ Escalate any identified gaps or discrepancies to legal counsel immediately

Responding to Suspected Non-Compliance or Inspection

When an employer identifies a potential immigration compliance gap, whether through an internal audit, an employee report or a notification of an upcoming labour inspectorate visit, the response must be immediate and structured. Delays compound risk.

• Suspend the affected employee’s work activity (not employment, but active duties) pending verification of their permit status. This limits continued exposure while preserving the employment relationship.
• Engage legal counsel before responding to any inspection notice or producing documents to authorities. Counsel can advise on privilege, scope and procedural rights.
• Preserve all records. Issue an internal litigation hold if an investigation is anticipated. Do not alter, delete or backdate any immigration or personnel files.
• Cooperate with authorities within the scope defined by counsel. Voluntary disclosure and prompt remediation are generally treated as mitigating factors.
• Conduct a root-cause analysis after the immediate issue is resolved. Update SOPs, training and the audit checklist to prevent recurrence.

Employers with operations across multiple Greek regions should also consider the related implications of the 2026 property law changes where employee accommodation or corporate premises are involved.

Reporting Obligations by Entity Type, Comparison Table

The scope of reporting duties under Law 5275/2026 varies depending on the employer’s relationship with the third-country national worker:

For further background on residency routes that may interact with employer obligations, see the guide to Greece’s 2026 golden visa changes.

Conclusion, Building a Defensible Immigration Compliance Programme

Law 5275/2026 has fundamentally reset the baseline for immigration compliance Greece-wide. Employers who treat compliance as a one-time filing exercise rather than an ongoing programme face escalating financial and criminal risk. The practical steps outlined above, from pre-hire clearance and document verification through to quarterly audits and inspection-response protocols, provide a framework that HR teams and General Counsels can implement immediately. Use the Greek immigration law employer checklist provided in this guide as a starting point, adapt it to your organisation’s size and sector, and ensure legal counsel reviews the programme at least annually or whenever implementing regulations are updated.

Sources

1. Ministry of Migration & Asylum (Greece)
2. Gov.gr, Ministry page for Migration
3. Ministry of Labour, Work for third-country nationals in Greece
4. European Commission, Migration management in Greece
5. IOM Greece, Migration legal guide
6. Bernitsas Law, Overview of Law 5275/2026
7. Machas & Partners, Legal snapshot on Law 5275/2026
8. PwC Legalflash, New immigration law briefing
9. Zepos & Yannopoulos, Key provisions and practical implications