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ERGANI: registering employment terms in Cyprus

The short answer

Get one employee’s paperwork wrong and you face a fine of up to €5,500. As a Cyprus employer you must register the essential terms of each person’s employment (including the agreed working-day and working-week schedule) in the Cyprus «ΕΡΓΑΝΗ»/ERGANI information system, the platform run by the Ministry of Labour and Social Insurance. [1] [4] The duty comes from Law 25(I)/2023, the Transparent and Predictable Working Conditions Law, which transposes EU Directive 2019/1152 and, in section 11, requires every employer to inform employees of those essential terms. [2] [3] A decree opened a one-off window (2 January to 28 February 2025) to back-register your existing workforce, and that window has closed. [4] Here is the part many owners miss: the duty did not close with it. Registration is a standing obligation, so every new hire and every change to terms still has to be declared. [2] And keep the boundary this guide returns to in view: ERGANI records what the contract says, not the hours each person actually works day to day. That is a separate duty, and we cover it below.

What ERGANI actually is

ERGANI («ΕΡΓΑΝΗ») is the electronic information system of the Cyprus Ministry of Labour and Social Insurance. Through it, employers notify the recruitment and termination of employees and declare their terms of employment. [1] One point deserves precision, because the name trips people up: this is the Cyprus system, run by the Cyprus Ministry, under Cyprus law. Greece operates a separate system that also happens to be called ERGANI: a different platform in a different jurisdiction, and nothing here concerns it. Think of the Cyprus ERGANI as the government’s register of the employment relationship: who is employed, on what essential terms, and from when. It is not a time clock. What it holds is declarations by the employer, not a live feed of attendance.

What Law 25(I)/2023 requires

The governing statute is Law 25(I)/2023, the Transparent and Predictable Working Conditions Law of 2023, whose preamble states that it harmonises Cyprus law with Directive (EU) 2019/1152 of 20 June 2019. [2] Section 11 carries the core duty: every employer must inform its employees of the essential terms of the employment contract or relationship. [2] What counts as “essential”? The Directive it transposes is specific. Article 4 lists, for work with a predictable pattern, the length of the worker’s standard working day or week and any arrangements for overtime and its remuneration among the essential aspects of the relationship. [3] So the agreed working-hours schedule is not an optional extra here: it is one of the essential terms you have to communicate. That is the thread tying an employment-terms duty to the subject of working hours: what you register is the contracted schedule, the hours the parties agreed, as part of the essential terms of the relationship. [3] [4]

The 2025 window closed: the duty behind it did not

Section 11(6) of Law 25(I)/2023 empowers the Minister of Labour and Social Insurance to require the essential terms to be registered in an electronic system, and Decree K.D.P. 455/2024, published in the Official Gazette on 20 December 2024, did exactly that. It required every employer to register the essential terms of employment of all its employees in ERGANI during the period from 2 January 2025 to 28 February 2025. [4] That was a one-off exercise to bring the existing workforce onto the system, and its window has passed. If you completed the back-registration, it is behind you. If you did not, regularise the position with advice: a closed date is a gap to fix, not a live emergency. [4]

What has not passed is the underlying obligation. Section 11 is a standing duty to inform employees of their essential terms, not a task discharged once and for all in February 2025. [2] In practice, the register has to stay current. Take on a new employee, and their essential terms fall to be registered. Change an existing employee’s terms, and the change has to be reflected. The mistake to avoid is treating ERGANI as a one-time chore rather than a live record: the window was the starting line for your standing workforce, not the finish line for the duty. [2]

The €5,500 that hangs on getting it wrong

The Law has teeth. Under section 27, an employer who contravenes any provision of Law 25(I)/2023 is guilty of an offence and, on conviction, is liable to a fine not exceeding €5,500. [2] Keep two points of proportion in view. First, that figure is a ceiling (“not exceeding” €5,500), so it describes the maximum exposure on conviction, not a fixed penalty that lands automatically on any slip. [2] Second, the sanction covers breaches of the Law’s obligations generally, and the section 11 duty to inform employees of their essential terms is one of them; it is not a standalone “ERGANI fine” cut loose from the wider statute. [2] The practical takeaway is calm: keep the essential-terms register accurate and current, and the fine never enters the picture. This is a reason to be organised, not a reason to panic.

ERGANI is not a record of hours actually worked

This is the distinction that matters most, and it is the easiest to blur. Registering employment terms in ERGANI is a declaration of the contracted terms of the relationship (including the agreed working-day and working-week schedule that the Directive lists among the essential aspects of employment). [3] [4] It answers one question: what did the parties agree the hours would be? It does not answer another: how many hours did this person actually work last Tuesday? Those are different questions with different legal homes. The duty to capture the hours each worker actually works, day to day, comes from a separate line of EU law. In CCOO v Deutsche Bank the Court of Justice held that the Working Time Directive requires Member States to oblige employers to set up an objective, reliable and accessible system enabling the duration of time worked each day by each worker to be measured. [5] Declaring a contracted schedule into a government register does not satisfy that measurement duty. ERGANI is not a time clock: it is not designed to log actual daily attendance, and it does not. Miss this and you make a real error: register your schedules dutifully in ERGANI and you have met the essential-terms obligation, but you have not touched the separate expectation about recording actual hours. That separate topic (what Cyprus law requires today on recording daily hours, and where EU law is heading) is covered in our guide to recording working hours in Cyprus.

What to do now

Steady maintenance beats a scramble. Three moves. First, confirm the essential terms of your existing workforce are registered in ERGANI; the 2 January-28 February 2025 back-registration window has closed, so if there is a gap, close it now with advice rather than leaving it to sit. [4] Second, fold registration into onboarding and change management: when someone is hired, or an existing employee’s essential terms change, register or update the terms: section 11 is a standing duty, not a one-off. [2] Third, make sure the working-hours schedule you declare is accurate, because the agreed working-day and working-week pattern is one of the essential aspects the framework expects you to communicate. [3] And hold on to the boundary: this is a declaration of contracted terms, not a substitute for recording the hours people actually work; the daily-hours recording question is a separate matter.

One practical connection is worth drawing, because it is where the paperwork and the day-to-day meet. The schedule you declare in ERGANI is the contracted version of the same working-hours reality your attendance records describe in fact. If your workforce and scheduling data (who works, on what pattern, from when) already sits cleanly in an attendance system such as Lemorange, the information you need to keep an essential-terms register current is close at hand rather than scattered, which makes ongoing registration less of a chore. That is a point about having your house in order, not a claim that any product performs the registration for you or relieves you of the legal duty. This guide is general guidance on the Cyprus position, not legal advice for your situation; each legal statement is footnoted to a primary source you can verify in our sources and references.

Common questions

Is this the Greek ERGANI?

No. This is the Cyprus «ΕΡΓΑΝΗ»/ERGANI information system, run by the Cyprus Ministry of Labour and Social Insurance under Cyprus law. Greece happens to operate a separate system of the same name, and it is not what this guide concerns. [1]

Have we missed the deadline?

The one-off window to back-register the existing workforce ran from 2 January to 28 February 2025 and has closed, but the obligation behind it has not. [4] Section 11 of Law 25(I)/2023 is a standing duty to inform employees of their essential terms, so if your registrations are incomplete, regularise the position with advice rather than treating a past date as an emergency. [2]

Does ERGANI count as recording our staff’s working hours?

No, and this is the key distinction. ERGANI holds a declaration of the contracted terms, including the agreed working-hours schedule; it does not record the hours each employee actually works, and it is not a time clock. [3] [4] The separate expectation that actual daily hours be measured comes from the Working Time Directive as interpreted by the Court of Justice in CCOO v Deutsche Bank (a duty addressed to Member States), and registering schedules in ERGANI does not discharge it. [5] We cover that separate topic in our working-hours guide.

Do we still have to register a new hire, or a change to someone’s terms?

Yes. Section 11 is a standing obligation, so a new employee’s essential terms fall to be registered, and a change to an existing employee’s terms has to be reflected: the duty is continuing, not spent. [2]

What happens if we get it wrong?

Under section 27, an employer who contravenes the Law is liable on conviction to a fine not exceeding €5,500: a ceiling, not an automatic charge. [2] Keep the essential-terms register accurate and current, and the question never arises.

References

  1. Πληροφοριακό Σύστημα ΕΡΓΑΝΗ (ERGANI Information System) . Ministry of Labour and Social Insurance (Cyprus), 2021-09-13 (CY)
  2. Ο περί Διαφανών και Προβλέψιμων Όρων Εργασίας Νόμος του 2023 (25(I)/2023), άρθρα 11 και 27 . Republic of Cyprus (via CyLaw), 2023-04-13 (CY)
  3. Directive (EU) 2019/1152 on transparent and predictable working conditions in the European Union, Article 4 . European Union (Official Journal L 186), 2019-06-20 (EU)
  4. Το περί Διαφανών και Προβλέψιμων Όρων Εργασίας (Ουσιώδεις Όροι Εργοδότησης για Καταχώριση σε Ηλεκτρονικό Σύστημα) Διάταγμα του 2024 (Κ.Δ.Π. 455/2024) . Republic of Cyprus, Minister of Labour and Social Insurance (Official Gazette, via CyLaw), 2024-12-20 (CY)
  5. Judgment of the Court (Grand Chamber), Case C-55/18, Federación de Servicios de Comisiones Obreras (CCOO) v Deutsche Bank SAE (ECLI:EU:C:2019:402) . Court of Justice of the European Union, 2019-05-14 (EU)