The Digital Work Card system in Greece is being extended to additional sectors in 2026, introducing new compliance requirements for businesses regarding working time recording and workforce management.
As part of this expansion, 12 practical, sector-specific guides have been published to help employers understand their obligations and prepare for the implementation of the system.
The guidance is particularly relevant ahead of 12 October 2026, when mandatory compliance and the associated penalties take effect for the first group of newly covered sectors. For the second group, the corresponding date is 16 November 2026.
What Do the 12 New Digital Work Card Guides Cover?
The 12 practical guides have been developed to support businesses brought within the scope of the Digital Work Card system under Ministerial Decisions 15441/28.05.2026 (Government Gazette B’ 3051) and 18047/24.06.2026 (Government Gazette B’ 3791).
They provide concise, practical guidance on implementing the system, taking into account the operational requirements of different industries.
For employers, the guides serve as a useful reference for understanding how the Digital Work Card works, how employees' clock-in and clock-out times should be recorded, and what is required to comply with the applicable labour legislation.
Which Sectors Must Comply from 12 October 2026?
The first phase of the expansion began on 2 June 2026, with a transitional period running until 11 October 2026.
From 12 October 2026, businesses falling within the designated sectors will be subject to full enforcement of the Digital Work Card requirements, including the applicable administrative penalties.
The sectors covered include:
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Telecommunications and certain information technology activities.
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Human healthcare services, including hospitals, treatment facilities and diagnostic centres, subject to specific exemptions.
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Employment support services.
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Building and outdoor cleaning services.
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Personal care services, including hairdressing salons and beauty centres.
Whether a business falls within the scope of the system is determined by the specific Business Activity Codes (KAD) set out in the legislation, rather than solely by its general industry classification.
Which Sectors Must Comply from 16 November 2026?
The second phase covers businesses brought within the Digital Work Card system in late June 2026.
For these activities, the transitional period ends on 15 November, with full enforcement beginning on 16 November 2026.
The sectors include:
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Consultancy, advertising and other office-based professional services.
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Warehousing and transport support activities, including logistics.
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Repair and maintenance services.
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Water supply, wastewater management and related activities.
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Gambling and betting activities.
Businesses operating in these sectors should use the remaining transitional period to review their internal procedures, prepare their workforce and ensure that the system is implemented correctly.
What Are Employers' Key Obligations?
Implementing the Digital Work Card involves more than introducing an employee time-tracking system.
It requires coordination between employers, employees and payroll teams to ensure that recorded working hours accurately reflect the time actually worked.
Businesses should pay particular attention to the following areas.
1. Recording Employee Clock-In and Clock-Out Times
Employees covered by the system must use the Digital Work Card correctly when starting and finishing work, in accordance with the applicable requirements.
2. Ensuring Consistency Between Scheduled and Actual Working Hours
Digital Work Card records must accurately reflect actual working time. Any discrepancies must be reviewed and addressed in accordance with the relevant legal provisions.
3. Managing Schedule Changes and Overtime
Employers must follow the required procedures for declaring and monitoring working hours, schedule adjustments and overtime, depending on the working-time reporting framework applicable to their business.
4. Employee Training and Awareness
Employees need clear instructions on when and how to record their attendance. Proper training helps reduce errors and supports consistent application of the system.
5. Monitoring Records Through ERGANI II
Regular monitoring of information recorded in Greece's ERGANI II employment information system can help businesses identify discrepancies promptly and manage their employment compliance obligations effectively.
What Should Businesses Check Before Mandatory Enforcement Begins?
Preparation for the Digital Work Card should be completed before the end of the applicable transitional period.
Employers should carry out a compliance review covering:
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Verification of their primary Business Activity Code (KAD) and whether the business falls within the system's scope.
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Identification of employees who are required to use the Digital Work Card.
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Confirmation that the working-time recording system is functioning correctly.
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Review of declared working schedules and procedures for reporting changes.
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Employee training on the correct use of the Digital Work Card.
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Coordination with payroll and HR teams to identify and resolve potential discrepancies.
Early preparation can help businesses minimise operational errors, streamline workforce administration and reduce the risk of non-compliance.
Digital Work Card: Administrative Penalties and Compliance Risks
Once the relevant transitional period has ended, businesses covered by the system become subject to the applicable inspection and administrative penalty framework.
Violations may include incorrect implementation of the Digital Work Card, inaccurate recording of working hours or failure to meet other statutory obligations.
The penalties imposed depend on the nature of the violation and the relevant provisions of Greek labour legislation.
For this reason, Digital Work Card compliance should not be treated simply as an administrative formality. It should form part of a business's broader workforce management and employment compliance strategy.
How AFS Can Support You?
Implementing the Digital Work Card correctly requires a thorough understanding of Greek labour legislation, well-structured internal processes and ongoing oversight of employment obligations.
AFS – Athens Financial Services, through its Payroll & HR services, supports businesses in managing their employment-related responsibilities and adapting to evolving regulatory requirements.
From assessing whether your business falls within the scope of the system to reviewing internal procedures and providing practical guidance on implementation, our focus is on helping businesses operate efficiently, consistently and with confidence.
Not sure whether the Digital Work Card requirements apply to your business, or whether your current procedures are fully compliant?
Contact the AFS team to discuss the requirements applicable to your business and the steps needed to prepare for implementation.