Greece's social security authority, e-EFKA, has issued Circular 19/2026, providing further clarification on the social insurance reporting requirements for lawyers who are remunerated through service invoices, commonly referred to in Greece as “blokaki.”

The circular focuses on how these professionals' social security contributions must be reported through the Analytical Periodic Declaration (APD), Greece's statutory social insurance reporting system.

The guidance is particularly relevant to lawyers operating under this arrangement, as well as businesses that engage legal professionals on a service-provider basis. So, who is affected, what does the circular clarify, and what should businesses pay attention to?

Who Is Affected by e-EFKA Circular 19/2026?

The circular applies to lawyers who receive remuneration through service invoices and fall within the provisions of Article 39, paragraph 9 of Law 4387/2016.

This specific social insurance framework applies, subject to certain legal conditions, to self-employed professionals whose income from providing services comes from one or two contracting parties.

For example, a lawyer who regularly provides legal services to a company and issues invoices for those services may fall under this framework, provided the relevant eligibility requirements are met.

However, not every lawyer issuing service invoices automatically qualifies. The nature of the professional relationship and the applicable social insurance provisions must be assessed individually.

What Does the Circular Clarify About APD Reporting?

Circular 19/2026 provides more detailed instructions on how the social insurance contributions of eligible lawyers should be recorded in the Analytical Periodic Declaration.

The aim is to ensure that contributions are correctly reported according to the relevant branches of social insurance coverage.

In particular, the circular addresses the separate reporting of contributions relating to:

• Main pension insurance and healthcare coverage, in accordance with the applicable contribution framework.

• Supplementary pension insurance, where such coverage is mandatory.

• Lump-sum benefit insurance, where the relevant statutory provisions apply.

Depending on the circumstances, the reporting process may require multiple APD entries, using the appropriate activity, occupation and insurance coverage codes.

Importantly, the circular does not introduce an entirely new social insurance framework for lawyers paid through service invoices. Instead, it clarifies how existing requirements should be reflected in statutory reporting.

How Are Social Security Contributions Calculated?

Lawyers covered by Article 39, paragraph 9 of Law 4387/2016 are subject to a specific social insurance contribution framework.

Contributions for main pension insurance and healthcare are shared between the insured professional and the contracting party, in accordance with the applicable legislation.

Separate rules apply to supplementary pension insurance and lump-sum benefit coverage, depending on the relevant insurance category and reporting period.

Circular 19/2026 provides guidance on how these contributions should be accurately recorded in the APD.

Special attention is also required in cases involving lawyers' advance-fee payment certificates, as specific provisions govern the treatment of social security contributions withheld through this process.

What Should Businesses Working with Lawyers Pay Attention To?

For companies engaging lawyers through service invoices, accurate social insurance administration is essential to reducing reporting errors and ensuring compliance.

There are four key areas businesses should review.

1. Confirm the Applicable Insurance Framework

Businesses should establish whether a lawyer they work with falls within the provisions of Article 39, paragraph 9 of Law 4387/2016.

2. Ensure Accurate APD Reporting

Social security contributions must be declared using the appropriate codes and in accordance with e-EFKA's reporting instructions.

3. Verify Contribution Calculations

Companies should review how contributions are allocated and whether any specific rules apply to the professional's insurance coverage.

4. Review Previous Insurance Periods

As the circular also addresses reporting requirements relating to earlier insurance periods, businesses may need to assess whether corrections are necessary, subject to the procedures established by e-EFKA.

Why Is Accurate APD Reporting Important?

The Analytical Periodic Declaration plays a central role in recording social insurance information and contributions in Greece.

Incorrect reporting may result in contribution discrepancies, the need for corrective declarations or inconsistencies in a professional's social insurance record.

For this reason, properly implementing e-EFKA's guidance is important for both legal professionals and the businesses engaging their services.

Regular reviews of social insurance obligations, together with effective coordination between accounting and payroll teams, can help businesses identify potential issues before they become more complex.

How AFS Can Support You?

Managing social security contributions and submitting accurate APD declarations requires specialist knowledge, consistency and an up-to-date understanding of Greek legislation.

At AFS – Athens Financial Services, our Payroll & HR team supports businesses and professionals in managing their payroll, employment and social insurance obligations.

From assessing the applicable insurance framework for external collaborators to ensuring accurate APD reporting, our team provides practical guidance tailored to each business's requirements.

Does your business work with lawyers who issue service invoices? Or do you need professional support with payroll and social insurance compliance in Greece?

Επικοινωνήστε με την AFS για να εξετάσουμε τις ανάγκες της επιχείρησής σας.

Τηλ.: 210 8317702 | www.afs.gr