Intra‑company Transfer (ICT) to Greece: Employer’s Guide to Seconding Non‑eu Staff Under the Greek Immigration Code

Intra company transfer Greece arrangements continue to evolve as Greece updates its labour‑migration framework. For HR teams, global mobility functions and in‑house counsel, the practical consequence is a structured and increasingly supervised framework governing the interplay between the national D‑visa, the EU‑derived single permit and a set of employer compliance obligations. This guide translates the legal framework into an implementation roadmap: who qualifies, which pathway applies, what timelines to expect, and the duties employers must discharge before and during an assignment. It is written for practitioners who need to move people compliantly without delay.

Because immigration legislation and its implementing measures are amended periodically, every procedural statement below should be verified against the current statutory text and official ministry guidance before acting.

Executive summary: Key takeaways for employers

• A dedicated ICT route exists. Greek immigration law preserves an intra‑company transfer pathway for intra‑group managers, specialists and trainees, aligned with the EU framework for intra‑corporate transferees.
• Two parallel entry mechanisms. Most long‑stay secondments require a national long‑stay D‑visa issued by a Greek consulate, followed by or combined with a residence/work authorisation processed by the Ministry of Migration and Asylum.
• Employer obligations are front‑loaded. Pre‑assignment due diligence, written secondment documentation, pay and working‑condition parity, and social security notifications to EFKA now sit squarely with the sponsoring or host employer.
• Timelines demand early planning. Realistic planning assumes several weeks for consular processing and residence/work permit issuance; complex cases take longer.
• Non‑compliance carries penalties. Breaches can trigger fines, refusal or withdrawal of permits, and in serious cases criminal exposure.
• Documentation is decisive. A well‑drafted secondment agreement and a disciplined compliance checklist are the single most reliable protections against delay and sanction.

Who this guide is for and what it covers

This guide addresses HR managers, global mobility specialists and in‑house counsel planning to move non‑EU personnel into a Greek entity within the same corporate group. It focuses on the lawful mechanics of an intra company transfer Greece assignment: eligibility, the D‑visa and residence/work permit pathways, timelines, and the employer duties under Greek immigration law. It is a practical compliance resource rather than an exhaustive tax or social security manual. Where cross‑border taxation, EFKA contributions and detailed employment‑law questions arise, we flag the issue and point to specialist advice. Every procedural statement below should be read alongside the current statutory text and official ministry guidance, and bespoke legal advice should be sought for any specific assignment.

Legal framework: the Greek Immigration Code and related instruments

The domestic framework, overview

Greece’s treatment of labour‑migration pathways, including intra‑company transfers, is governed by its codified immigration legislation and its implementing measures. The authoritative text of any statute or amendment is published in the Government Gazette (Εφημερίδα της Κυβερνήσεως, FEK) by the National Printing House, and employers should always verify the operative provisions and effective dates against the official FEK publication rather than secondary summaries. The legislation addresses who may be seconded, the documentation required, and the obligations placed on the employer that hosts or sponsors the transferee.

In practice, the primary statute sits at the centre of a wider regulatory ecosystem: ministerial decisions and implementing circulars issued by the Ministry of Migration and Asylum give operational detail to the headline provisions, and these are updated periodically. Because implementation guidance evolves, any intra company transfer Greece project should begin with a check of the latest circulars alongside the primary FEK text. The practical effect of recent reforms has been a framework that is more explicit about employer responsibilities and more structured in how it interacts with EU‑derived instruments, which is why early legal review is essential.

Relevant EU instruments

Greek law on intra‑company transfers operates against the backdrop of two key EU directives. Directive 2014/66/EU on the conditions of entry and residence of third‑country nationals in the framework of an intra‑corporate transfer establishes the EU‑level categories of transferee, managers, specialists and trainee employees, and the baseline conditions for their admission within a corporate group. Separately, Directive 2011/98/EU, the Single Permit Directive, underpins the concept of a combined work and residence authorisation granted through a single application procedure, together with a set of equal‑treatment guarantees for third‑country workers. Greek national law transposes and supplements these directives.

Understanding the EU layer matters for employers because it explains the structure of the Greek categories and the rationale behind the single permit, and because it provides interpretive context where national guidance is silent or ambiguous.

Other reforms affecting worker regimes

Recent reform packages have touched more than intra‑company transfers. Parallel changes have affected other labour‑migration regimes, including seasonal worker arrangements, with the broad policy thrust being tighter employer accountability and clearer documentation requirements across categories. Employers managing mixed workforces should not assume that the rules for one regime map onto another: the eligibility tests, permitted durations and compliance obligations differ by route. Where a business uses both seasonal labour and intra‑group secondments, treat each pathway on its own terms and confirm the applicable provisions in the current FEK text and ministry guidance.

Eligibility: which employees and roles qualify for an intra company transfer Greece assignment

Eligible transferees

Consistent with the EU intra‑corporate transfer framework, the Greek route is designed for three categories of intra‑group personnel. Managers are senior staff who direct the host entity or a department, exercising supervisory authority and significant decision‑making latitude. Specialists possess specialised knowledge essential to the host entity’s activities, technical expertise, proprietary knowledge of the group’s systems, or a high level of qualification relevant to the role. Trainee employees are university graduates transferred for career development or to acquire training in the group’s business techniques or methods, typically for a defined and limited period.

For each category, the transferee must have an existing employment relationship within the corporate group before the transfer, and the receiving Greek entity must belong to the same undertaking or group. These common threads, prior group employment and a genuine intra‑group link, are the foundation of any compliant intra company transfer Greece application.

Exclusions and pitfalls

Several situations fall outside the ICT route or create risk if mishandled. Direct hires with no prior intra‑group employment relationship do not qualify as transferees and must use another route. Assignments dressed up as secondments to circumvent local recruitment rules invite scrutiny. Roles that cannot credibly be characterised as managerial, specialist or trainee may be refused. A frequent pitfall is inadequate documentation of the pre‑existing group employment relationship, or a mismatch between the role described in the application and the duties actually performed. Another is treating a short consultancy engagement as if it were a long‑stay transfer when a different authorisation applies.

Cross‑border posting versus genuine transfer test

A recurring analytical question is whether an arrangement is a genuine intra‑corporate transfer or something closer to a cross‑border posting or remote working arrangement. The distinction turns on where the work is performed, the duration, the locus of the employment relationship and the degree of integration into the host entity. A genuine transfer involves the employee physically working at and being integrated into the Greek host entity within the group. Where work is performed remotely from abroad, or where the “assignment” is in substance service provision by one group company to another, a different legal characterisation, and different authorisations, may apply.

Getting this test wrong is a common source of refusals and later compliance problems, so it should be settled at the planning stage.

Practical pathway: D‑visa vs single permit, step‑by‑step comparison

The D‑visa (consular) pathway

For most long‑stay intra company transfer Greece assignments, a non‑EU national must first obtain a national long‑stay visa, the D‑visa, from the competent Greek consulate in the country of residence. The D‑visa authorises entry and initial stay for the purpose of taking up the authorised activity, and it is the gateway to subsequent residence authorisation on Greek soil. A typical consular document set includes a valid passport, the completed national visa application form, photographs meeting specification, proof of the intra‑group employment relationship and the host entity’s details, the secondment or assignment documentation, evidence of accommodation and sufficient means, and health insurance cover.

Consular steps run broadly as follows: book an appointment with the competent Greek consulate; submit the application and biometrics in person; respond to any requests for additional documents; and collect the visa once approved. Employers should confirm the precise, up‑to‑date requirements on the Ministry of Foreign Affairs visa pages and with the specific consulate, because document lists and appointment practices vary by post.

The residence/work permit (combined authorisation) pathway

Greek law provides for a combined work and residence authorisation granted through a single application procedure, reflecting the EU Single Permit Directive. For an intra company transfer Greece assignment, the residence/work permit is the authorisation that governs the transferee’s lawful residence and work during the posting, and it is processed by the Ministry of Migration and Asylum through the relevant residence‑permit procedures. The application generally requires the underlying employment and secondment documentation, proof of the intra‑group relationship, the host entity’s corporate particulars, evidence that pay and conditions meet applicable standards, and payment of the prescribed fees.

In many long‑stay cases the residence permit follows lawful entry on a D‑visa; the transferee then regularises residence and receives the residence card through the ministry process. Employers should treat this authorisation as mandatory for the residence and work phase of a long‑stay assignment and should verify the current portal, forms and document requirements directly with the Ministry of Migration and Asylum.

Which to choose and transitional cases

In practice, the two instruments are complementary rather than alternatives for most long‑stay transfers: the D‑visa enables lawful entry, and the residence/work permit governs ongoing residence and work. The choice of emphasis depends on assignment length, the transferee’s nationality and residence situation, and any transitional arrangements carried over from permits issued under earlier rules. For assignments and permits straddling a legislative transition, employers should confirm whether a prior authorisation remains valid, requires renewal under the current rules, or must be converted. The comparison table below summarises the core distinctions.

Employer obligations under Greek immigration law

Pre‑assignment due diligence and registration requirements

Recent reforms have shifted more responsibility onto the employer at the planning stage. Before an intra company transfer Greece assignment proceeds, the sponsoring and host entities should confirm that the corporate group link is documented, that the transferee genuinely falls within the manager, specialist or trainee categories, and that the host entity is properly constituted and registered to receive the transferee. Due diligence should capture the entity’s registration details, the role description, the proposed duration, and the evidentiary basis for each eligibility element. Because ministry circulars may impose specific registration or notification steps, employers should check the current implementing guidance from the Ministry of Migration and Asylum and build those steps into the project timeline rather than discovering them mid‑application.

Contractual and employment‑law checks (pay parity and working conditions)

Transferees working in Greece are protected by applicable Greek labour standards, and the legal framework reinforces the expectation that remuneration and working conditions meet the required parity benchmarks. Employers must ensure the assignment documentation reflects pay that is consistent with applicable standards for comparable work, together with compliant working time, leave and health‑and‑safety provisions. The Ministry of Labour and Social Security is the reference point for domestic employment obligations such as minimum pay and working conditions that bear on seconded workers. Contractual arrangements should be reviewed to confirm that the work to be performed in Greece does not fall below these protections, since gaps here are both a compliance risk and a frequent cause of application problems.

Social security and payroll notifications (EFKA)

Social security treatment during a secondment depends on the contractual structure and any applicable totalisation or EU coordination arrangements. In many cases the home employer remains the employer of record and home‑country cover continues under an A1 or equivalent certificate, but the assignment may nonetheless trigger Greek registration or reporting obligations. Employers should liaise with EFKA, the unified social security fund (e‑EFKA), to confirm registration, contribution and secondment‑reporting requirements for the specific case, and should coordinate payroll accordingly. Treating social security as an afterthought risks dual obligations and retrospective liabilities, so it belongs in the pre‑assignment checklist.

Data, reporting and penalties

Greek immigration law pairs its obligations with enforcement. Employers can face administrative fines, refusal or withdrawal of permits, and in serious cases criminal liability for significant breaches such as unauthorised employment of third‑country nationals. Reporting duties, including notifying relevant changes during the assignment, must be observed, and records should be retained to demonstrate compliance in the event of an audit. The precise penalty provisions and administrative sanctions are set out in the statute and its implementing measures, and the official FEK text and ministry circulars should be consulted for the operative detail. The practical lesson for mobility teams is that a disciplined paper trail is the most effective defence against enforcement exposure.

Application timelines, fees and realistic planning

Typical timelines

Timelines for an intra company transfer Greece assignment span three overlapping phases: consular processing of the D‑visa, the residence/work permit application with the Ministry of Migration and Asylum, and issuance of the residence card. Each stage is subject to variation by post, caseload and case complexity. As a planning assumption, employers should allow several weeks for consular processing and plan for the residence permit and card issuance to take several additional weeks, with complex cases extending further. Because published processing indications change, confirm current timelines on the ministry and consular pages and file early. Building slack into the start date is far cheaper than an assignment that stalls at the border.

Fees and budget checklist

Budgeting should account for the national visa fee, residence‑permit charges, document legalisation and translation costs, health insurance, and professional fees for legal review and submission. Employers should also budget for incidental costs such as appointment logistics and courier charges. Confirm the prescribed fees against the official sources, as amounts and payment procedures are set administratively and updated from time to time.

Contingency planning and expedited routes

Build contingency into every assignment plan: identify decision points where delays are most likely, prepare complete document sets to avoid requests for further information, and keep a reserve timeline for the start date. Where available, confirm with the relevant authority whether any expedited handling applies to the particular case.

Templates and checklists employers can use

Secondment assignment letter checklist

A robust secondment assignment letter is the backbone of a defensible intra company transfer Greece file. At a minimum it should identify the parties and the corporate group relationship; describe the role and confirm the transferee category (manager, specialist or trainee); state the assignment location, start date and duration; specify remuneration and benefits, confirming parity with applicable standards; address social security and the employer‑of‑record position; set out governing law and dispute resolution; and define the conditions for variation and termination. Keeping this document aligned with the actual duties performed is essential, because discrepancies between paperwork and practice are a leading cause of refusals and audit findings.

Employer compliance checklist

• Verify eligibility. Confirm the intra‑group employment relationship and the correct transferee category.
• Confirm the host entity. Check registration, corporate particulars and capacity to receive the transferee.
• Choose the pathway. Determine the D‑visa and residence/work permit sequence for the assignment.
• Assemble documentation. Prepare the secondment agreement, pay and conditions evidence, and supporting proofs.
• Address social security. Resolve the EFKA position and any reporting obligations early.
• Observe reporting duties. Notify relevant changes during the assignment and retain records.
• Monitor guidance. Track ministry circulars and legislative amendments and update the file accordingly.

Case studies and common pitfalls

Case study one, the cross‑border manager. A group transfers a senior manager from a non‑EU subsidiary to lead a department in its Greek entity. The correct path is a D‑visa for entry followed by a residence/work permit for residence and work, supported by documentation of the manager’s existing group employment and the host entity’s details. Lessons: (1) document the prior intra‑group relationship from the outset; (2) ensure the role description genuinely reflects managerial authority; (3) confirm pay parity before filing; and (4) start the consular step early to protect the target start date.

Case study two, the specialist trainee. A graduate specialist is transferred to acquire training in the group’s proprietary systems for a defined period. The arrangement must be clearly characterised as a trainee transfer with a limited, documented duration, and the training content should be evidenced. Lessons: (1) do not blur the trainee category with a general hire; (2) set a clear, defensible duration; (3) retain evidence of the training purpose; and (4) check whether social security and reporting obligations apply during the engagement.

Managing taxation, social security and employment‑law interactions

An intra company transfer Greece assignment rarely raises immigration issues in isolation. Taxation, social security and employment law interact in ways that materially affect cost and compliance. Determining tax residence, the allocation of taxing rights, EFKA treatment and the continuing application of Greek labour protections requires coordinated advice from immigration, tax and employment specialists. This guide deliberately keeps that treatment at overview level; employers planning multiple or complex assignments should obtain a bespoke analysis on tax and social security for seconded employees, on drafting secondment agreements, and on employer penalties and compliance audits.

Where to get official advice and how to monitor updates

Because immigration legislation and its implementing guidance continue to develop, employers should monitor the official channels directly. Track announcements and procedural guidance from the Ministry of Migration and Asylum; consult the Ministry of Foreign Affairs visa pages for consular D‑visa requirements; verify the operative legal text through the Government Gazette (FEK) via the National Printing House; and check EFKA for social security registration and reporting. The Ministry of Labour and Social Security is the reference for domestic employment obligations. For qualified representation, the Athens Bar Association can assist in identifying immigration counsel. Checking these sources before each assignment is the simplest way to keep a mobility programme current.

Next steps and contact

Planning an intra company transfer Greece assignment rewards early, structured preparation: confirm eligibility, choose the D‑visa and residence/work permit sequence, assemble documentation, and resolve social security and reporting duties before you file. Given the enforcement focus of the current framework, a disciplined compliance file is your most reliable protection against delay and sanction. Employers who want tailored support can request a consultation to hire an immigration lawyer for assistance with their secondment programme, and should always seek bespoke advice for specific cases.

Sources

1. National Printing House / Government Gazette (Εφημερίδα της Κυβερνήσεως – FEK)
2. Hellenic Republic, Ministry of Migration and Asylum
3. Hellenic Republic, Ministry of Foreign Affairs: Visas
4. EUR-Lex, Directive 2014/66/EU on intra‑corporate transfers
5. EUR-Lex, Single Permit Directive (Directive 2011/98/EU)
6. e‑EFKA (Unified Social Security Fund)
7. Hellenic Ministry of Labour and Social Security
8. Athens Bar Association (Δικηγορικός Σύλλογος Αθηνών)