October 22, 2026

How to Switch Employer of Record Providers in Greece

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Key Takeaways

  • Classify the switch as continued employment, a qualifying identity-retaining business transfer, or fresh employment before ending the outgoing arrangement; the provider contract does not decide this.
  • A new agency cannot be assumed to restart Greek placement limits; review the full same-user assignment history, 36-month cap and continued-use conversion rule.
  • Reconcile leave and Christmas-bonus liabilities according to the legal route, and verify incoming terms, permission, records and filings before exit.
  • Work during an employer-permit change depends on category and timing; a Blue Card employer change in the first 12 months has a 30-day suspension, so confirm effective permission before starting.

Before ending an existing Greek employment arrangement, identify the legal employer and determine whether the change is only a service-platform change, a protected business transfer, or a new employment relationship. Those routes affect the employee's rights, required filings and whether work may continue on the planned date. A provider contract alone does not decide the route.

For a client moving existing Greek workers from EOR A to EOR B, classify the arrangement, confirm B and any permission, agree fresh terms if needed, and pass the readiness gate before exit. Defer if records or permission are not ready.

What changes when you switch EOR in Greece?

Identify the employer in the signed contract, payroll record and applicable permit. A platform change alone may leave employment intact.

If the employer changes, PD 178/2002 may transfer rights when an organized economic entity passes with its identity. Similar services alone are insufficient. Assess activity, assets, workforce, customers and interruption under Greek transfer guidance and PD 178/2002.

SituationLegal mechanism to verifyEvidence requiredImplication
Same legal employer remainsEmployment may continueContract, payroll identity, permit and registrationReconcile records; no new start assumed
Different employer with an identity-retaining entity transferPD 178/2002 may applyTransfer documents, assets, workforce, functions and continuity factsRights may transfer by law
Different employer without qualifying transferAgreed fresh employment and lawful old-end routeEmployer identities, old contract, signed new terms, permission and required filingsSettle or expressly recognize balances

Temporary agency rules may also matter. A temporary employment agency employs workers for placement with an indirect employer under that user's supervision and direction. Greek Labour Code Article 118 limits a temporary-agency placement, including renewals, to 36 months; an overrun converts it to indefinite employment with the indirect employer. After placement and lawful renewals expire, continued work for that user without an interval of 23 calendar days, even through a new placement, is deemed indefinite employment with that user. A narrow short-event hotel/catering exception applies to this 23-day rule. Do not assume a provider reset. If B would make a placement, verify its lawful operation separately from entity registration. For a third-country worker whose permit depends on B, confirm any statutory TEA sponsor conditions before relying on B. Check the Greek Labour Code and full assignment history.

Without a transfer or other continuation basis, do not direct resignation before B's signed offer, effective permission and start arrangements. ERGANI II labels do not classify the legal event.

Review the existing service and employee position

Commercial notice does not replace employee rights or agreement to new terms.

Commercial agreement checklist

  • Confirm notice method, receipt date, exit fees, deposit/refund terms and post-exit cooperation.
  • Identify who supplies payroll, leave, benefit, filing and employment records, and when.
  • Confirm funding owners for payroll, bonuses and tax or contribution payments. Do not offset an expected refund against B's funding.

Employee arrangement checklist

  • Confirm legal employer, contract, collective terms, work location, role and any dispute or protected leave.
  • Reconcile notice, service, probation, pay, leave, bonuses, severance exposure and benefit coverage.
  • Check permit category, sponsor restrictions, notifications, approvals and effective dates.
  • Obtain assignment starts, renewals and expiry dates from every agency if the same user continues.
  • Explain statutory rights, settlements and any recognition B agrees to provide; name a question contact.

If a fresh contract is selected, the employee must agree to it. If transfer rules apply, providers cannot remove rights with a fresh-hire label. B should identify the employing entity and assign filing, payment, benefit and employee-support owners without promising eligibility before review.

Establish transfer and continuity treatment

Under PD 178/2002, rights and obligations pass to the successor; A and B share pre-transfer liabilities. Transfer alone cannot justify dismissal, subject to the workforce-change exception. Both employers inform representatives in good time; where measures are planned, consult early enough to seek agreement. If there are no representatives, provide required early written worker information. See Greek guidance and PD 178/2002.

For fresh employment, state any agreed service or probation recognition and settle accrued claims under applicable law. Have both payroll owners reconcile each worker's ledger before exit. For the wider obligations, see our Greece employment-law guide.

ItemStatutory treatment to verifyRecognition or settlement neededWho confirms
Employer and serviceDepends on employer identity and legal routeRecord route and effective dateReviewer, client, A and B
Service and probationApply statutory service rules for each entitlement; transfer preserves qualifying rightsDistinguish mandatory service credit from additional agreed recognition and any lawful probationB and client, with worker agreement
Wages and leaveDue amounts follow applicable rules; transfer may carry rightsReconcile periods, balances and payments without duplicationA and B payroll
Bonus and other compensationLiability depends on employer and route; extras may be contractualAllocate periods and document any agreementEmployers and plan administrator
BenefitsPrivate coverage is not automaticVerify eligibility and effective dates before exitB and client benefits owner
Work permissionPermit category may restrict employer change or startComplete applicable notice/review before B workWorker and B
Notice and severanceDepends on transfer rules, contract and worker factsConfirm duty and amountA, B and reviewer
Protected leaveProtections depend on worker facts and routeConfirm status and pay/coverage effect before fixing datesEmployers and client HR
TEA placement and userStatus and history determine Article 118 consequencesVerify lawful operation and same-user chronologyB, client and reviewer

Private benefit continuity is not automatic. Verify the last coverage date under A and B's first covered date. For transfer, review obligations that pass; for fresh employment, record what B accepts. Contract terms cannot erase mandatory rights.

Set one coordinated cutover calendar

This hypothetical concerns a Greek citizen in an Athens office and assumes no applicable local or sector holiday. A owns the 1 to 30 November 2026 wage period; B owns 1 to 31 December. Assume A benefit coverage ends 30 November and B coverage starts 1 December, with written enrollment confirmation required before exit. Dates are scenario inputs, not statutory notice periods. Use the fresh-employment route only after confirming distinct employers, no qualifying transfer or other protected continuation, lawful end/start, and no unresolved TEA same-user expiry or 23-day consequence. Otherwise recalculate and defer exit.

MilestoneDependencyOutgoing EOR AIncoming EOR BClient or employee actionCompletion evidence
Mon 2 Nov 2026: assumed commercial noticeMSA allows 28 elapsed days through 30 Nov 2026A acknowledges and continues serviceB confirms proposal onlyClient checks fees, refund and cutoffReceipt and signed terms; not employee notice
Mon 16 Nov 2026: terms deliveredRoute and B employer identifiedA supplies available records securelyB sends terms, privacy, pay and benefit datesEmployee reviews changes and rightsTerms pack and question contact
Thu 19 Nov 2026: questions closedEmployee reviewed terms, pay and coverageA answers ledger questionsB answers terms and benefit questionsClient assigns discrepanciesIssue list, not a waiver
Fri 20 Nov 2026: readiness reviewRoute, permission, signed terms, benefits, filing plan and payroll ownership reviewedConfirms final pay and exit dutiesConfirms employer, start filing, coverage and payrollClient confirms written funding allocation or defersSigned terms, route and permission evidence, benefit confirmation, filing plan and funding approval
Mon 23 Nov 2026: records handoffLawful sharing confirmed; validation required before exitSends final/leave statement, YTD and required recordsValidates records and explains pay dateEmployee checks identifiers, dates and benefitsSecure transfer log; receipt is not waiver
Fri 27 Nov 2026: final readiness gateAll route, permission, coverage, worker agreement and validated-record conditions confirmedA settlement stays separateB confirms assumed €6,000 receivedClient authorizes cutover only if every dependency passes; otherwise defersCleared funds and final sign-off; fictional amount
Mon 30 Nov 2026: A endsOnly after lawful route and readiness; no permission gapPays through 30 Nov 2026 and validated settlementNo B work/pay yetClient checks final pay and coveragePayment evidence; end filing by Fri 4 Dec, four working days after departure, assuming no holiday
Tue 1 Dec 2026: B startsAccepted terms, effective permission and accepted start filing before workA closes live payroll, retains correction accessB owns live pay from 1 Dec 2026Employee starts only when authorizedERGANI and acceptance evidence; coverage active
Mon 21 Dec 2026: Christmas bonusSeparate liability under fresh routeA pays its amountB pays its amountClient checks bothSeparate calculations and proof; not ordinary wages
Thu 31 Dec 2026: B payrollAssumed payday, separate from bonusA has no unpaid November wagesB pays 1 to 31 Dec 2026 earningsEmployee checks payslip and YTD historyPayment proof; A November APD/contributions due 31 Dec 2026
Fri 29 Jan / Mon 1 Feb 2027Confirm B's category and extensionsA owns November filingsB pays December contributions by 29 Jan; APD window ends 1 FebClient checks receiptsPayment and filing proof

ERGANI II has operated since 16 February 2026. File the ordinary fresh-start declaration before work. The current workflow requires a worker-signed/certified attachment or MyErgani acceptance after filing and before duties; confirm implementation with payroll. At the old employment end, the employer's ending declaration is due within four working days after departure, dismissal or expiry under Law 5239/2025, Article 14, which amended Labour Code Article 330(1). For a Monday 30 November 2026 end, that points to Friday 4 December assuming no applicable holiday. The filing deadline follows the lawful end; it does not create the right to end employment or replace required notice. The 2026 start declaration decision is the official Gazette source for the worker acceptance process.

For private enterprises, e-EFKA's calendar gives A's November 2026 APD window as 1 to 31 December, with contributions due 31 December. B's December 2026 APD window ends 1 February 2027; contributions are due 29 January. Public schedules differ. APD, contributions and withholding have separate deadlines.

Deliver terms 16 November 2026; close questions 19 November; confirm signed acceptance by the 20 November review. On 23 November A and B validate records and the client HR contact confirms pay periods, coverage and balances. A provides final payslip and settlement statement with 30 November final pay; B provides its first payslip with the assumed 31 December pay. Name A and B payroll contacts plus the client HR escalation contact. These internal dates do not waive rights.

Reconcile transition costs and cash

Keep a ledger separating service fees/refunds from wages, leave, bonuses and contributions. An expected refund is not payroll cash. Fees, deposits, overlap and severance depend on the case.

Fee, liability or funding itemWhen dueResponsible partyRefund or settlement treatment
Service notice and any exit feePer signed client-service terms; 28 days is assumed here onlyClient and AVerify invoice, notice receipt and any fee; no universal period
Final wages through 30 Nov 2026Agreed pay date and applicable wage rules; amounts corresponding to work become due at contract endAMatch to time worked and prior advances; do not duplicate in B's live payroll
Four validated unused leave daysWith A's termination settlement if the fresh route appliesAAssumed 4 × €100 gross daily remuneration = €400 gross leave-pay component; separate leave allowance remains to calculate
Incoming payroll funding€6,000 assumed cleared on 27 Nov 2026Client funds B under the fictional scenario termsNot a salary, tax, contribution or statutory deposit; do not reduce by an expected refund
Christmas bonus21 Dec; any lawfully retained final-period portion by 31 DecA and B for their respective periods if fresh employment appliesCalculate from actual worker pay and liable period; keep separate from 31 Dec 2026 wages
Notice, severance, benefit overlap or depositOnly if required by actual contract, route or benefit policyRelevant employer/client confirmsPrice only evidenced liabilities; keep any refund separate
Refund, credit or final service adjustmentActual contractual refund date and conditionsA pays; client reconcilesRecognize only when received; maintain a separate receivable

Greek Labour Inspectorate guidance says due annual leave pay and allowance are payable at termination when due leave has not been taken, subject to the worker's circumstances and applicable amendments. In the example, A's validated ledger shows four unused days and the worker's already validated gross daily remuneration is €100. The gross leave-pay component is 4 × €100 = €400. The leave allowance is separate, has its own calculation and cap, and is not included in €400. No withholding, net pay, other termination liability or monthly salary divisor is inferred. B does not pay the same four days again on this fresh-employment route unless the actual legal treatment or signed terms require recognition. Check the Labour Inspectorate leave guidance and actual payroll ledger.

Christmas bonus covers 1 May to 31 December. Article 149 sets 21 December payment, allowing the final-period portion to be retained until 31 December. This example assumes both employers pay their full liable shares on 21 December; B cannot defer the entire bonus to ordinary payday. Calculate shares under Ministry guidance.

Test the first payroll and close the old arrangement

Before live payroll, run a calculation-only comparison and assign an owner to every payment and filing. Keep YTD as history; B's live earnings begin on its start date. Each employer owns withholding, APD and contributions, including applicable bonus and leave-allowance contributions. File returns even when no tax is due and remit any withholding by the end of the second month after payment under AADE guidance. Rates and full hiring cost are outside this article.

Pass or fail before exit and first payroll

  • Route and permission: Confirm employer identities, transfer/TEA classification, same-user history, permission and lawful dates. Otherwise defer.
  • Terms: Signed B terms and required ERGANI acceptance precede work. A proposed offer is not acceptance.
  • Wages and YTD: One payer per live day; validate identifiers, YTD, leave and final adjustments. YTD is history, not new pay.
  • Benefits: Confirm last/first coverage dates, enrollment and employee contact.
  • Filings: Assign each employer withholding, APD and contribution dates. APD filing and contributions have separate deadlines.
  • Cash: B's approved funds clear before A's exit; assign final settlement and start/end filings.
  • Missing records: Reconstruct only from lawful, independently verified records sufficient for payroll. Otherwise defer or extend where lawful.

Minimum records are signed employment/assignment terms; employer registration, employee AFM tax and AMKA insurance identifiers; service dates; validated pay/YTD; leave and bonus ledger; payslips and filing receipts; benefit dates; permit/employer terms when relevant; and escalation contacts. Agree data roles, purpose, lawful basis, retention, an approved encrypted channel, named recipients and receipt logging. Handle health data separately. GDPR requires accuracy, minimization and security. The Greek DPA says employee consent is generally unsuitable because of the power imbalance. See DPA guidance.

If A delays or refuses records, the client names an escalation owner and deadline. B and the client may validate lawful independent evidence such as signed terms, payslips and filed declarations. Do not invent balances or file unverified values. If records cannot support correct payroll, or the route is unclear, defer exit and B's start, or extend A only where lawful. No work may continue through a permission gap.

Two employee situations that change the switch

Hypothetical case 1: Greek citizen, conditional fresh employment. Assume distinct employers, no identity-retaining transfer or other protected continuation, and a valid agreed end/new contract. Review actual operation and the user's full assignment history to rule out or resolve any TEA Article 118 issue. Only on documented facts may A end 30 November 2026 and B start 1 December 2026. A settles its period; B starts its payroll and assesses its bonus liability. This is not a universal termination/rehire rule.

Hypothetical case 2: Blue Card holder in the first 12 months. Do not assume a same-day start. Migration Code Article 40 requires notification and suspends the change for 30 days while admission criteria are checked; the authority may oppose it if admission criteria are unmet. After 12 months, notification is nonsuspensive. Verify the card, start date, B's criteria and notification before work. See the Greek Code. Other permits have separate rules. For a covered initial employment-invitation single permit, the first-contract restriction is capped at six months. Early-change exceptions include serious employer breach, documented mutual ending or employer-initiated termination. For an eligible employer change with valid notification, the statute permits work during the 45-day review. Confirm the applicable exception if changing during the restricted period. Check the actual permit and Law 5275/2026 before setting a start date.

Questions about switching EOR in Greece

Does changing EOR providers transfer the employee? Not automatically. Confirm same employer, qualifying identity-retaining transfer, or valid fresh-employment route. Similar services alone are insufficient.

Can a new agency restart the 36-month limit? Do not assume so. For TEA placement with the same indirect employer, review all renewals and expiry. Article 118 also covers continued work after expiry without a 23-day interval, even through a new placement.

Can work continue while a permit change is pending? It depends on permit and timing. A Blue Card change in its first 12 months is suspended for 30 days; an initial single permit has separate restrictions. Confirm effective permission before B's start.

Who pays accrued leave and Christmas bonus? It depends on route and balances. A settles due old amounts under fresh employment; each employer pays any bonus portion for which it is liable. Transfer may carry rights. Reconcile before payment.

What if payroll records are incomplete? Name an escalation owner and request verified records. Reconstruct lawfully only if sufficient for correct pay and filings; otherwise defer or extend where lawful.

Borderless AI's EOR services cover employment contracts, payroll and benefits. To discuss a Greece switch, request an arrangement assessment and confirm the employing entity and case eligibility before setting a transition date.

Rules checked 22 October 2026.

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