Observation (CEACR) - adoptée 2025, publiée 114ème session CIT (2026)

Convention (n° 81) sur l'inspection du travail, 1947 - Grèce (Ratification: 1955)

The Committee notes the observations of the Greek General Confederation of Labour (GSEE), received on 1 September 2023, 28 August 2024, and 29 August 2025. The Committee requests the Government to provide its comments in this respect.

Article 3(1)(a), (b) and (2) of the Convention. Labour inspection activities in the area of undeclared work and illegal employment, including in relation to foreign workers. The Government indicates in its report that the Labour Inspectorate carries out inspections to combat undeclared work and provides statistical data regarding the number of identified undeclared workers and the number of companies that employed them between 2021–23. The Government indicates that the Labour Inspectorate also monitors the observance and implementation of provisions on the legality of employment and the insurance coverage of third-country nationals and provides information on the number of illegally residing foreigners found to be employed, as well as the fines and administrative sanctions imposed in this respect, for the period 2021–23. In its observations, the GSEE indicates that the Division of the Supreme Labour Council on Undeclared Work has ceased to function for over three years and that the Register of Delinquent Employers in Matters of Undeclared Work is still not operational due to the lack of a required Ministerial Decision. Additionally, the GSEE indicates that no progress has been made on ratifying the Labour Inspection (Agriculture) Convention (No. 129). The Committee requests the Government to provide its comments in this respect. It once again requests the Government to provide information with regard to the development and the functioning of the Register of Delinquent Employers in matters of Undeclared Work. The Committee requests the Government to provide further information on the party liable to fines and administrative sanctions (workers, employers or both parties) in relation to illegal employment of foreign workers. The Committee once again requests the Government to provide information on the number of foreign workers in an irregular situation who have been granted their due rights (including recovery of wages and social security credits) or where their situation has been regularized.

Articles 4 and 5(b). Organization and effective functioning of the system of labour inspection. Supervision and control by a central authority. The Committee notes the Government’s indication that, following the adoption of Law No. 4808/2021, the Labour Inspectorate began to operate, from July 2022, as an independent authority separated from the Ministry of Labour and Social Security. It also notes that several provisions of this Law have been codified under the new Code of Labour Law, which was given effect to through Presidential Decree No. 62/2025. In this respect, the Government provides detailed information on the structure and organization of the Labour Inspectorate. In its observations, the GSEE indicates once again that the detachment of the Labour Inspectorate and its transformation into an independent authority through Law No. 4808/2021 took place despite the explicit opposition from the GSEE and without prior consultations. Furthermore, the GSEE indicates that the Labour Inspectorate implemented the EU-ILO project “Support to the operational modernization of the Labour Inspectorate” without consulting national social partners, and that the final report was kept confidential, contrary to requests from the GSEE to discuss and assess the outcomes. In addition, the GSEE indicates that the reorganization disrupted interaction between the Ministry of Labour and Social Security and the Labour Inspectorate, and led to the abolition of the state’s general responsibility, coordination and supervision of labour inspection policy. At the same time, the GSEE indicates that the Ministry of Labour and Social Security still exerts de facto control over labour inspection policies through circulars that guide inspections. The Committee requests the Government to provide its comments in this respect. It requests the Government to indicate the measures taken or envisaged to ensure meaningful consultations with national social partners in the restructuring of the system of labour inspection, including on the implementation of relevant projects affecting the Labour Inspectorate. The Committee requests the Government to provide more information on the relationship between the Ministry of Labour and Social Security and the Labour Inspectorate.

Article 5(b). Collaboration with representatives of employers and workers. The Government indicates that section 89(7) of Law No. 4808/2021 (as codified under section 382 of the new Code of Labour Law) allows union representatives to attend and comment during inspections, while section 122(5) of the same law (as codified under section 569 of the new Code of Labour Law) permits representatives from trade unions and employers’ organizations, to attend labour dispute procedures alongside legal advisers. In its observations, the GSEE recalls its previous observations regarding the lack of participation of social partners. According to the GSEE: (i) the Governing Board of the Independent Authority does not provide for institutional representation of workers and employers and this has deprived of social partners of the rights to express their opinion on the functioning, the programming and the accountability of the Labour Inspection and (ii) the Social Control Council of Labour Inspectorate (SKEEE), the central institutional body for social dialogue and control, has ceased to exist, and the Ministerial Decree required for its reactivation and the activation of regional councils has not been issued. The Committee requests the Government to provide its comments in this respect. The Committee requests the Government to take the necessary measures in order to ensure collaboration between officials of the Labour Inspectorate and employers and workers or their organizations. Noting that in reply to the previous GSEE observations, the Government indicated that Law No. 4808/2021 did not abolish the SKEEE, the Committee requests the Government to provide detailed information on the operation of the SKEEE in practice (for example minutes of sessions, reports or documentation adopted).

Article 6. Status and conditions of service of labour inspectors. Independence of inspectors. The Committee recalls that section 114 of Law No. 4808/2021 defines the powers of the Governor which include, inter alia, the authority to define the service status, the salary status, the disciplinary procedure, the organizational structure of the staff positions, as well as the power to set up the Executive and Disciplinary Boards and to lay down the rules for their decision-making. The Committee takes note of the Government’s indication that Decisions Nos 344805/21-06-2024 and 344778/21-06–2024 of the Governor provided for the establishment and operation of the Authority’s disciplinary and staff council with exclusive competence to exercise disciplinary authority over the employees of the Labour Inspectorate. The Committee requests the Government to adopt the necessary measures in order to ensure that labour inspectors have the status and conditions of service that are necessary to assure them of stability of employment and independence of changes of government and of improper external influences. The Committee also requests the Government to provide information on any decision adopted by the Governor of the Labour Inspectorate in the implementation of section 114 of Law No. 4808/2021 concerning arrangements for personnel matters.

Articles 17 and 18. Adequate penalties imposed and effectively enforced. The Committee notes that the labour inspection reports for 2022 and 2023 provide detailed information on the activities of the Labour Relations Inspectorate and the OSH Inspectorate, including the type of inspections conducted, the fines imposed, labour disputes brought and resolved, amount paid to employees, number of cases brought to courts, lawsuits and complaints, and types of violations. In its observations, the GSEE indicates that the enforcement of penalties remains a concern. The Committee requests the Government to provide its comments in this respect and to indicate the measures taken or envisaged to ensure that adequate penalties for the violation of legal provisions are enforced by labour inspectors. The Committee requests the Government to continue to provide detailed information on the number of violations detected, the amount of fines imposed and collected, the number of cases brought to the courts, and the penalties subsequently imposed.

The Committee is raising other matters in a request addressed directly to the Government.