Employment Terms Under The Microscope: Department Of Labour Relations Launches Compliance Review

The Department of Labour Relations is contacting employers across Cyprus requesting the written employment terms for all their employees by 31 July 2026.

What does the Department actually require?

This requests stems from a compliance review being conducted by the Department under the Transparent and Predictable Working Conditions Law 25(I)/2023 (“2023 Law”), which came into force in April 2023 and requires employers to inform employees in writing of their essential terms of employment. For more information on the relevant 2023 Law, please refer to our previous newsletter HERE.

Following its letters to employers requesting the information, the Department has published a practical guidance to clarify some aspects of this exercise. In short, the guidance says:

• A template employment agreement or an employee handbook will not be accepted.
• Registration of employment terms in the ERGANI system alone is not sufficient. Εmployees do not have access to ERGANI, and the Department requires proof that each employee has been individually and personally informed.
• Acceptable documents include a signed individual employment agreement, a signed offer letter, a copy of a collective agreement signed by the employee (if applicable), or a printed ERGANI extract reflecting the updated terms, signed by the employee.
• An email confirmation of acceptance by the employee is also acceptable where terms were sent electronically.
• The documents must be submitted electronically only. For large files, a cloud link (OneDrive, Google Drive, Dropbox) may be shared, provided it remains active without an expiry date.

Although the Department's letter does not itself refer to signed documents, the guidance published does make reference to "signed" documents as the acceptable form of evidence. It is worth noting, however, that the 2023 Law, from which this exercise stems, requires written notification together with proof of transmission/receipt by employee but does not explicitly mandate a signature.

What is the risk of not responding?

Employers who do not respond within the deadline are likely to receive a follow-up from the Department prompting compliance. Failure to comply may result in criminal proceedings and a fine of up to €5,500.

Do you need to act?

If you have received the Department's letter, you should check now whether you have the underlying employment documentation in place for each employee and whether you can demonstrate they have been individually informed of their terms.