An Interpretative Circular (No. 25291/23-09-2026) was issued on the implementation of the Digital Work Card in the following sectors:
I. Telecommunications, computer programming, consultancy, computing infrastructure and other information service activities.
II. Administrative and support service activities, including employment activities, combined support services, cleaning and landscaping services.
III. Human health and social work activities.
IV. Other service activities, including personal services, hairdressing salons, beauty centres, thermal spas and similar activities, funeral services and related activities, and intermediation services for the provision of personal services.
V. Water collection, treatment and supply; wastewater treatment; remediation activities; and waste collection, recovery and disposal.
VI. Warehousing and support activities for transportation.
VII. Activities of head offices, management consultancy, business consultancy and other management advisory services.
VIII. Advertising, market research and opinion polling, public relations and communication activities.
IX. Office administration, secretarial support and other business support activities, including call centres and the organisation of conventions and trade shows.
X. Gambling and betting activities.
XI. Repair and maintenance of computers and communication equipment, personal and household goods, motor vehicles and motorcycles.
The above Circular also includes provisions on special cases for the use of the Digital Card:
Special cases for clocking in and out using the Digital Work Card
- Employees who regularly work on third-party premises, outside their employer’s premises
Employees whose fixed workplace is outside their employer’s premises, in a space made available for the employer’s exclusive use, are required to clock in and out at the location where they regularly provide their services.
Examples include:
• Sales staff of a particular company who regularly work in a shop-in-shop within another company.
• A company’s technicians who regularly provide services at another company’s premises, in a space used exclusively by their employer.
• Employees of insurance agents who regularly, or for extended periods, work in a space rented by their employer within another company’s premises. - Employees who move between branches of the same company
Employees who, because of the nature of their work, do not have a fixed workplace but regularly move from one work location to another—during the day, from day to day, or at regular intervals during the week—are not required to clock in and out on days when they work away from the company’s fixed workplace and regularly move between locations, given the practical difficulty of using the Digital Work Card.
In these cases, where no clock-in and/or clock-out is recorded for work performed with physical presence on the company’s premises, the daily working hours declared in the ERGANI II Information System will be presumed to be the working hours for that day. Failure to clock in or out on those particular working days will be considered justified and will not result in penalties.
However, on days when these employees attend the company’s premises, even after they have started work, they must use their Digital Work Card.
Example:
An employee starts work at Branch A and finishes at Branch B of the same company. In this case, the employee must record two card punches during the day: the first punch (clock-in) at Branch A and the second punch (clock-out) at Branch B. The initial card punch at Branch A will be considered the start of work with physical presence on the company’s premises, and the final card punch at Branch B will be considered the end of that work. If the employee finishes work at Branch B, the second card punch at Branch B will also indicate the end of their working day. - Employees working for different companies within the same group
Employment by different companies within the same group, each with a different Tax Identification Number (AFM), generally involves the employee being hired by each respective group company.
Therefore, where those companies are covered by the Digital Work Card system, an employee working for them within the same day must clock in and out separately at each company. - Clocking in and out using the Digital Work Card for employees of service providers (contractors)
In sectors of economic activity covered by the Digital Work Card system, service providers (contractors) are often engaged by the project owner to carry out part of a project under contracts for the performance of work.
Where the work may be performed either on or off the contractor’s premises, the following applies:
• If the contractor operates in a sector covered by the Digital Work Card system, its employees must clock in and out using the Digital Work Card, whether they carry out the work on the contractor’s premises or on another employer’s premises. This obligation applies regardless of whether that other employer is covered by the Digital Work Card system.
• If the contractor operates in a sector that is not covered by the Digital Work Card system, its employees are not required to clock in and out using the Digital Work Card.
The above is an extract from the full text of Interpretative Circular No. 25291/23-09-2026. The full Circular, in Greek, is available for download below.