The legislative framework for the transfer of third-country citizens for seasonal work

Article 66 of Law 5038/2023 outlines the procedure for issuing residence permits to third-country citizens for seasonal employment. Third-country citizens who have entered Greek territory based on employment approval from the competent one-stop service—covering one or more employment periods of up to nine (9) months within a twelve (12) month period—are eligible to apply for a residence permit.
The seasonal work residence permit is valid for up to five (5) years, depending on the employment contract provided by the third-country national. The application for the residence permit is submitted electronically to the locally competent Decentralized Administration. Along with the application, the required supporting documents must be submitted, including a valid employment contract for seasonal work, a fee of seventy-five (75) euros, and proof that the worker has suitable accommodation.
A third-country national holding a residence permit may change employers based on a new employment contract. In such cases, they must inform the competent one-stop service of the employer change by submitting the new contract. If the third-country national violates the obligations associated with the residence permit, they will be barred from obtaining a new national visa of any category for five (5) years from the date of the permit revocation decision.
The residence permit may be renewed if all legal requirements are met and the third-country national has fulfilled all obligations. However, the total duration of residence cannot exceed ten (10) years in total.
For the year 2025, the number of seasonal work positions available to third-country nationals who meet the requirements is determined by Ministerial Council Act No. 56, titled:
“Determination of the maximum number of positions for dependent and seasonal employment per job specialty and high-skilled employment of third-country nationals for the year 2025, definition of employment sectors for the admission of third-country nationals for seasonal work, and determination of the correlation between the employer’s cultivable land/livestock and the number of seasonal workers“.
Specifically, the maximum number of seasonal work positions for 2025 is set at 45,620 for the entire country (unlike the previous regulation, which allocated positions by geographic region). The positions defined in the Ministerial Council Act mainly include the following specialties:
- Unskilled agricultural, livestock, forestry, and fishing workers
- Hotel and tourism accommodation cleaning staff (cleaners/cleaning assistants/gardeners)
- Catering services in hotels and tourist accommodations (cooks/kitchen assistants/dishwashers/waiters)
- Other tourism-related personnel (porters/tourism animators/reception staff).
Maria Aikaterini Papadopoulou
Lawyer
LLM in History and Theory of Law, Law School of Athens, National and Kapodistrian University of Athens
LLM in Civil Law, Law School of Athens, National and Kapodistrian University of Athens
LLM in Commercial Law, Law School of Democritian University of Thrace
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