Cyprus regulates telecommuting by statute. An employer who lets staff work from home owes them a written statement of the differentiated terms, the cost of the equipment and connection, and a right to disconnect. These are the obligations, and the points on which employers are most often exposed.
An employer who allows staff to work from home in Cyprus is not simply being flexible. Telecommuting is regulated by statute, and the arrangement carries obligations that arise whether or not anyone has written anything down: a duty to pay the costs of working remotely, a duty to set out the changed terms in writing, and limits on how the employee may be monitored. The governing statute is the Regulation of the Framework for the Organisation of Telecommuting Law of 2023, Law 120(I)/2023, published in the Official Gazette on 1 December 2023. The exposure for an employer who has done none of this is a live one.
Who the law applies to
The law works through the definition of employee in section 2, which covers a person working for another under a contract or relationship of employment, full time or part time, for a fixed or indefinite period, and includes a person working for a legal person of public law or for a local authority. Excluded from that definition are public servants, teachers in the public education service, staff of the public emergency services, members of the armed forces and the police, judges, investigators and staff of other law enforcement services.
It applies to the arrangement, not to the job title. Telecommuting is defined by reference to work provided remotely with the use of technology, and it is not confined to a particular form of contract or to full-time remote working. An employee who works from home two days a week is telecommuting on those two days, and the obligations attach.
Telecommuting is voluntary, with two exceptions
Neither side can impose remote work on the other, except in two situations. Section 3(1) provides that telecommuting is optional and is agreed in writing between employer and employee, either on recruitment, by amendment of the contract of employment, or by collective agreement. It cannot adversely affect any term of employment, and section 3(2) prohibits discrimination against an employee who does not consent to it. An employer who unilaterally directs an office-based employee to work from home is on unsafe ground unless one of the exceptions applies.
There are two, and both require that the work is capable of being provided remotely. The first is a decision of the employer on public health grounds, which operates only where a Decree of the Minister of Health has been issued under the Quarantine Law and only for the period the Decree specifies. The second is a request by the employee where there is a documented risk to their health that is avoided by working remotely, for as long as that risk lasts. Where the employer disputes the risk, the law contemplates certification by an approved doctor and examination by a Medical Board.
What the employer has to pay for
Section 4(1) puts the cost of telecommuting on the employer, not the employee. It covers the cost of the equipment, unless it is agreed that the employer's own equipment will be used, the telecommunications, the use of the home working space, the maintenance of the equipment and the repair of faults. The obligation extends to devices belonging to the employee, unless the contract provides otherwise or the fault is the employee's own doing, and the employer must provide technical support.
Section 4(2) requires the Minister, after a cost study and consultation with the representatives of employees and of employers, to fix by decision the minimum amount the employer pays the employee, published by notification in the Official Gazette. Section 4(3) is worth knowing: these sums are not remuneration, they are a deductible expense for the employer, they are not subject to tax or duty, no social insurance contributions are payable on them, and they are calculated proportionately by reference to the frequency and duration of the telecommuting and to whether equipment is supplied.
The practical point is that a home working arrangement in which the employee uses their own laptop and their own internet connection at their own expense does not comply. Where an employer wants to keep a bring-your-own-device policy, it needs a costs allowance behind it and a record of what the allowance is meant to cover.
If you are at this point
The written statement has a deadline, and it is earlier than most employers assume. Send us your current terms or write to office@kleanthousplatis.com.
The written statement, and what goes in it
This is the obligation employers most often miss. Section 5(1) requires the employer, within eight days of the date on which telecommuting begins, to inform the employee in writing of the terms of employment that are differentiated because of it. The statement has to cover, at least:
- the right to disconnect under section 10;
- an analysis of the section 4 costs the employee periodically bears, including telecommunications, equipment and its maintenance, and how the employer will meet them;
- the equipment required, whether it is the employee's or the employer's, and the arrangements for technical support, maintenance and repair;
- any restriction on the use of the equipment or of IT tools, including the internet, and the sanctions for breaching it;
- the arrangement for remote availability, its time limits and the periods within which the employee is to respond, subject to the Organisation of Working Time Law;
- the risks and the protection and prevention measures, based on the written risk assessment required by section 9;
- the obligation to protect professional data and the employee's personal data, and the steps taken to discharge it; and
- the supervisor from whom the employee will take instructions.
Section 5(2) requires the employer to keep evidence that the information was sent and received, in printed form or in electronic form that the employee can access, store and print. Section 5(3) allows the items that are not individual to a particular employee to be given by notifying the employer's policy and posting it on the internal network.
Two of these deserve attention. The right to disconnect is not a policy statement: it defines the boundary of the working day, and an employer whose practice is to expect answers in the evening has created a record against itself. And the response times must be stated, because in the absence of a stated window the argument that an employee was unavailable is very hard to run.
The practical point is that a home working arrangement in which the employee uses their own laptop and their own internet connection at their own expense does not comply.
Monitoring, privacy and data
You may not watch a remote employee through a camera to check how they are working. Section 8, which deals with the evaluation of a telecommuting employee's performance, prohibits monitoring employees through the use of a camera or another application of a similarly intrusive character in order to check performance. This is an outright prohibition, not a balancing exercise, and software that takes periodic screenshots or images of the employee sits squarely in the risk it addresses.
Performance evaluation must respect the employee's privacy, and section 8(2) requires two steps before any system, technology, application, measure or tool for supervision, time control or evaluation of performance is put in place: a data protection impact assessment under Article 35 of Regulation (EU) 2016/679, and prior consultation with the Commissioner for Personal Data Protection under Article 36. That is a sequencing rule as much as a compliance one. The assessment comes before deployment, not after a complaint, and an employer who installs first has already breached the section whatever the tool turns out to do.
The right to disconnect carries a drafting obligation of its own. Section 10(1) gives the telecommuting employee the right to disconnect from the electronic means through which the work is provided, so that the Transparent and Predictable Working Conditions Law applies, and section 10(2) prohibits any adverse treatment of an employee who exercises it. Section 10(3) goes further: the technical and organisational means needed to secure disconnection are mandatory terms of the telecommuting contract, agreed between the employer and the representatives of the employees. Where there is no agreement, the employer determines them and notifies every employee. A handbook paragraph saying staff are not expected to answer at night does not discharge this; the means belong in the contract.
Enforcement
Compliance is supervised by inspectors appointed by the Minister under section 11, whose functions and powers are set out in sections 12 and 13 and include investigation, the examination of complaints, access to the workplace, questioning and the inspection of documents.
The penalties are criminal. Under section 21, an employer who contravenes any provision of the law is guilty of an offence and on conviction is liable to a fine not exceeding EUR 10,000. Under section 17(1), a person who obstructs an inspector in the exercise of a power under the law, refuses to answer or answers falsely, fails to produce a record or document required, or obstructs another person from appearing before or being examined by an inspector, is liable to imprisonment not exceeding six months or a fine not exceeding EUR 10,000 or both. Section 17(2) provides that where that offence is committed by a legal person, anyone holding the position of director, chairman, manager or secretary, or appearing to act in such a capacity, is treated as guilty of the same offence unless they prove that it was committed without their consent or connivance and was not attributable to their own neglect. That last point is what makes this a board-level issue rather than an HR one.
What to send us
The employment contract, any remote working policy or handbook, the written statement given to the employee if one was given, and details of any monitoring software in use. Where a dispute has already started, send the correspondence. Bringing an existing arrangement into compliance is straightforward. Defending one that was never documented is not.
Employment and technology matters sit within our corporate and commercial practice. Employers introducing generative AI tools for remote and office staff should also read what an employer must put in place before staff use AI. For non-residents working remotely from Cyprus, see Cyprus Reopens Digital Nomad Visa Scheme.
Discuss your own situation with us
Questions we are asked
Does telecommuting change the employment status?
No. Section 6 settles it: the telecommuting agreement changes the way the work is performed without affecting the employment status.
Can an employer in Cyprus simply tell staff to work from home?
Not as a rule. Section 3(1) of the Regulation of the Framework for the Organisation of Telecommuting Law of 2023, Law 120(I)/2023, provides that telecommuting is optional and agreed in writing between employer and employee, whether on recruitment, by amendment of the contract, or by collective agreement, and section 3(2) prohibits discrimination against an employee who does not consent. There are two exceptions, both requiring that the work can be provided remotely: a decision of the employer on public health grounds, which operates only where a Decree of the Minister of Health has been issued under the Quarantine Law and only for the period the Decree specifies, and a request by the employee where there is a documented health risk avoided by working remotely, for as long as that risk lasts.
Who pays for the laptop and the internet connection?
The employer. Section 4(1) puts the cost of telecommuting on the employer rather than the employee, covering the equipment unless it is agreed that the employer's own equipment will be used, the telecommunications, the use of the home working space, the maintenance of the equipment and the repair of faults. The obligation extends to devices belonging to the employee, unless the contract provides otherwise or the fault is the employee's own doing, and the employer must provide technical support. An arrangement in which the employee uses their own laptop and their own connection at their own expense does not comply, so a bring your own device policy needs a costs allowance behind it and a record of what the allowance covers.
Is the allowance treated as pay?
No. Section 4(3) provides that these sums are not remuneration: they are a deductible expense for the employer, they are not subject to tax or duty, no social insurance contributions are payable on them, and they are calculated proportionately by reference to the frequency and duration of the telecommuting and to whether equipment is supplied. Section 4(2) requires the Minister, after a cost study and consultation with the representatives of employees and employers, to fix the minimum amount by decision published in the Official Gazette.
What has to be put in writing, and by when?
This is the obligation employers most often miss. Section 5(1) requires the employer, within eight days of the date telecommuting begins, to inform the employee in writing of the terms of employment differentiated because of it. The statement must cover at least the right to disconnect under section 10; an analysis of the section 4 costs and how the employer will meet them; the equipment required and the arrangements for support, maintenance and repair; any restriction on the use of equipment or IT tools and the sanctions for breach; the arrangement for remote availability and the periods within which the employee is to respond, subject to the Organisation of Working Time Law; the risks and the protection measures based on the written risk assessment required by section 9; the obligation to protect professional and personal data; and the supervisor from whom the employee takes instructions.
Does the law apply to someone who works from home two days a week?
Yes. Telecommuting is defined by reference to work provided remotely with the use of technology, and it is not confined to a particular form of contract or to full time remote working. An employee who works from home two days a week is telecommuting on those two days and the obligations attach. The law works through the definition of employee in section 2, which excludes public servants, teachers in the public education service, staff of the public emergency services, members of the armed forces and the police, judges, investigators and staff of other law enforcement services.
Can we monitor remote staff with a camera or screenshot software?
No. Section 8, which deals with the evaluation of a telecommuting employee's performance, prohibits monitoring employees through a camera or another application of a similarly intrusive character in order to check performance. It is an outright prohibition rather than a balancing exercise, and software taking periodic screenshots or images of the employee sits squarely within it. Performance evaluation must respect the employee's privacy, and the processing of employees' personal data engages the supervision of the Commissioner for Personal Data Protection, so any monitoring tool should be assessed before it is installed rather than after a complaint.
Related Reading
This article is for general information only and does not constitute legal advice. Laws and their application can change, and individual circumstances differ. For advice on your own matter, contact Klitos Platis at klitos@kleanthousplatis.com or telephone +357 22 680 330.
Klitos Platis
Advocate, Partner
Kleanthous & Platis LLC, Nicosia · Revised 4 August 2026
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