Monday, 12 October 2026 is an important date for employees and businesses in the first group of sectors added to Greece’s Digital Work Card in June. The adjustment period ends and the relevant administrative sanctions become applicable. Mandatory inclusion itself began on 2 June 2026. Businesses therefore need to distinguish the date when an obligation started from the date when the transitional protection against sanctions expires.

For an employee, the practical question is whether the system records the work actually performed. For an employer, it is whether schedules, card events and payroll are consistent. The card provides a valuable record, but it does not replace employment law or the examination of the circumstances surrounding a dispute.

Two phases, with different deadlines

Ministerial Decision 15441/2026, republished in Government Gazette B 3051 of 2 June, makes inclusion compulsory for employers covered by its first group of tables. The transitional period runs through 11 October. From 12 October, the relevant sanctions apply to breaches of the mechanism. Describing the earlier period as a pilot does not mean that undeclared or unpaid work was permitted during it.

The second group follows a separate timetable: mandatory inclusion from 29 June and full implementation with sanctions from 16 November 2026. The Ministry’s announcement of 23 September explains the two phases. It would consequently be misleading to present 12 October as a deadline for every newly included sector or every Greek business.

The principal activity code determines coverage

The first group concerns telecommunications, employment activities, services to buildings and outdoor areas, human health activities and specified personal services. Tables 8 to 11 list activity-code groups 61, 78, 81, 86 and 96 and their subdivisions. Examples include cleaning services, hospitals and diagnostic activities, hairdressers and beauty businesses. Coverage must be assessed using the employer’s principal activity code, known as KAD, registered in TAXIS and the applicable special provisions.

General sector labels require care. The heading of table 8 and the circular also mention computer programming, consultancy and computing infrastructure, whereas the numerical list in that particular Gazette contains telecommunications codes 61 and their subdivisions. Calling a business an “IT company” is not enough to establish its position. Its exact current principal code must be compared with the applicable tables and amendments, particularly after the transition to KAD 2025. This article does not treat every technology company as automatically covered.

Doctors and dentists: a specific exemption

Doctors and dentists themselves are excluded from the card obligation in the covered health businesses. This does not automatically exempt the entire workforce of a medical practice, dental practice or treatment centre. Receptionists, administrative employees and other staff must be considered by reference to their employment relationship, their employer’s coverage and any genuinely applicable exception.

Circular 25291 of 23 September 2026 also explains justified non-use, including declared teleworking days and certain duties performed outside the premises. Such situations do not remove obligations concerning schedules, declarations and pay. When the same employee works on the business premises, the duty to record card events must be considered again.

Physical attendance is not always total working time

At this stage, the card records physical attendance on the employer’s premises or at a location provided for its exclusive use. Where someone begins or finishes work elsewhere, the first entry and last exit do not necessarily reveal the whole working day. The digital organisation of working time, the planned schedule and card events must be considered together with the actual nature of the duties.

There is no reliable universal rule that the card always overrides other evidence or that only the declared schedule counts. A discrepancy may involve real overtime, a lawful schedule adjustment, justified work elsewhere or an error requiring investigation. Recording helps scrutiny: it neither turns every minute on the premises into overtime nor erases work that was actually performed.

The employee records events; the employer runs the system

The employee must record their own card events. The circular does not allow the employer to unilaterally enter the beginning or end of daily attendance. The business nevertheless remains responsible for operating the system, activating cards, making declarations and transmitting accurate records. A general instruction that “staff are responsible for everything” does not satisfy those duties.

The Labour Inspectorate requires immediate transmission to ERGANI, with a maximum delay of fifteen minutes. That is a transmission limit, not a period of unpaid work or permission to alter the real event time. Technical faults and objective inability are subject to a specific notification and documentation procedure. They do not justify inventing events retrospectively to make the records fit a preferred schedule.

A 17:00 card exit followed by work until 19:30

Consider an employee scheduled from 09:00 to 17:00 who records departure at 17:00 but continues carrying out duties until 19:30 on the employer’s instructions. The recorded exit does not legitimise concealing that additional work. The assessment needs to establish the duties performed, who requested them, the applicable declaration system and the payment due under the relevant employment rules.

Useful material may include available card records, schedules, payslips, lawfully obtained work correspondence and a contemporaneous account of events. Collection must respect personal data, medical confidentiality and third-party systems. Covert recording or extracting confidential company files is not recommended. Equally, remaining on the premises for personal reasons until 19:30 does not by itself establish that the entire interval was work.

Practical steps before a dispute develops

An employee can consult their own information through myErgani and ask for a specific explanation of a discrepancy. The request is clearer when it identifies the date, declared schedule, duties actually performed and payment, rather than relying on a general complaint. Businesses should give clear instructions, appoint someone to manage faults and regularly reconcile records with payroll.

If the issue remains unresolved, the Labour Inspectorate’s employment-dispute procedure and individual legal assessment offer an organised route for examining it. The card improves transparency when it operates alongside accurate organisation and proper pay. Before choosing a remedy, preserve the relevant documents and check any time limits that apply to the particular claim.

Official sources and information date

This analysis draws on Decision 15441/2026, Circular 25291/2026, the Ministry’s two-phase announcement and the linked Labour Inspectorate and gov.gr services. Dates and references were checked on 10 October 2026. Coverage and exemptions for a particular business require examination of its actual circumstances and the amendments in force.

This article was prepared with artificial-intelligence assistance and reference to the cited official sources. It provides general legal information and is not individual legal advice for a particular case.