Can the employer be the safety technician?
In small category B and C businesses, yes, under conditions. Since 1 January 2026 the limit has dropped to 20 employees (from fewer than 50) and training is required. In category A the business needs a safety technician with full qualifications, and the risk assessment is always written by a qualified person.
What applies from 1 January 2026
Law 5239/2025 amended Article 502 of the Greek Labour Code (formerly Article 12 of Law 3850/2010). The changes apply from 1 January 2026:
| Category | Employees | Who may carry out the safety technician duties |
|---|---|---|
| A | up to 50 | A safety technician with the qualifications set by law (Article 501) |
| B | up to 20 | A qualified safety technician, or a full-time employee with training; the employer personally only up to 5 employees, with specific formal qualifications or ten years in the activity, plus training |
| C | up to 20 | A safety technician, or the employer or an employee after training |
| B / C | over 20 | A safety technician with the qualifications set by law |
Legal basis: Article 502 of P.D. 62/2025, as amended by Article 30 of Law 5239/2025 (Government Gazette A' 178/2025). The table is simplified; the exact conditions are examined case by case.
What it means in practice
Many employers with 21 to 49 employees who had taken on the duties themselves until 2025 must now appoint a safety technician. If this is your case, it is worth sorting out before an inspection.
Even where the employer may take on the role, two things remain: the written occupational risk assessment must be prepared by a qualified person, and the employer carries full responsibility for applying the measures. That is exactly where we can help without taking on the whole contract.
Questions we are asked
I have 25 employees in category C. Can I carry on by myself?
Not after 1 January 2026. The limit for the employer or an employee to take on the duties is now up to 20 employees. You need to appoint a safety technician with the qualifications set by law.
Is the training enough for me to write the risk assessment too?
No. The written risk assessment is prepared by a person with safety technician qualifications and the right specialisation for the activity.
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