The Minister of Labour has, on 20 December 2024, issued a decree (RAA 455/2024) (Decree) pursuant to section 11 (6) of the Transparent and Predictable Employment Terms Law, L. 25 (I)/2023, as amended (Law) (which itself transposes Directive (EU) 2019/1152 (Directive)) according to which all employers are required to submit in the governmental platform "ERGANI" all essential terms of their employees' employment agreements.

Employers must complete the registration process between 2 January 2025 and 28 February 2025.

The Decree outlines the specific details that must be registered in the "ERGANI" platform.

These include:

1. Employer details
• Employer identification/information.
• Registered office address.
• Type of business (in case of retail business).
• In case of temporary work agencies, the identity of the user undertakings.
2. Employee details
• Personal identification/information.
3. Employment terms
• Employee job description and specialisation.
• Employment commencement date.
• Employment end date (in case of a fixed-term employment relationship).
• Place of employment as specified in the employment agreement and the actual place of employment at the time of registration.
• Conditions and duration of the probation period.
• Annual leave amount and allocation methods.
• Remuneration (including salary/wages, payment frequency (daily, weekly, monthly, or hourly)).
• Standard working hours per day/week (where the employee's work schedule is unpredictable this should also be mentioned).
• Other allowances, commissions, cost-of-living adjustments, and others.

It must be noted that there are several disparities between the language used in the Decree and the corresponding language in the Law and Directive in the listed essential employment terms. It remains to be seen whether or not said discrepancies could open the legality of the Decree to any potential legal challenges.

To comply with the Decree, employers must ensure that:

1. They maintain an “ERGANI” account.
2. Their employees have employment agreements in place in full compliance with Cypriot employment laws.
3. Undertake the registration of the employment terms for every employee on the “ERGANI” platform within the deadline referred to above.

It should be noted that, according to the Ministry of Labour, the “ERGANI” platform is currently undergoing updates to enable the submissions as per the Decree and, therefore, employers to discharge their corresponding statutory duty under the Law.

While the duty placed on employers under section 11 (6) of the Law and the Decree is not derived from the Directive but rather appears to be a gold-plating measure by the Cypriot government, the Decree still represents an important step towards enhancing transparency and standardising employment practices in Cyprus.

Given the administrative workload anticipated, employers are encouraged to prepare proactively in order to ensure timely compliance with the specified deadlines and to seek professional assistance where required.

Update: As of 2 January, 2025, the "ERGANI" platform has been updated and employers are now able to proceed with registering their employees' essential employment terms. The Ministry of Labour and Social Insurance also released an Information Note with detailed instructions and guidance in relation to the registration process. The Information Note (available in Greek only) can be downloaded here.