On June 26, 2025, Ministerial Decision 16973/2025 (the "Decision") came into effect, significantly expanding the scope of the Digital Employment Card (the "Digital Card") measure. This extension now includes additional sectors of the Greek economy, including wholesale trade, energy, financial services, and the administrative and support services of the tourism sector.
The Decision mandates that businesses operating under the following main Activity Codes (Κωδικός Αριθμός Δραστηριότητας – ΚΑΔ) are now required to implement the Digital Employment Card system:
Wholesale and Retail Trade, Repair of Motor Vehicles and Motorcycles («ΚΑΔ» 45–46):
- Sale of motor vehicles («ΚΑΔ» 45.1);
- Maintenance and repair of motor vehicles («ΚΑΔ» 45.2);
- Wholesale trade («ΚΑΔ» 46).
Electricity, Gas, Steam, and Air Conditioning Supply («ΚΑΔ» 35):
- Electricity generation, transmission, and distribution («ΚΑΔ» 35.1);
- Gas production, distribution of gaseous fuels through pipelines («ΚΑΔ» 35.2);
- Steam and air conditioning supply («ΚΑΔ» 35.3).
Financial and Insurance Activities («ΚΑΔ» 64–66):
- Monetary intermediation («ΚΑΔ» 64.1);
- Financial leasing («ΚΑΔ» 64.91);
- Other financial services («ΚΑΔ» 64.99);
- Insurance and pension funding («ΚΑΔ» 65);
- Activities auxiliary to financial services («ΚΑΔ» 66).
Administrative and Support Service Activities («ΚΑΔ» 77–79):
- Rental and leasing of motor vehicles and light motor vehicles («ΚΑΔ» 77.11);
- Travel agency, tour operator, and other reservation services («ΚΑΔ» 79).
Employers in mandated sectors must ensure that all employees with employment contracts or dependent employment relationships, who physically work at the employer's premises, are registered in the Digital Employment Card system — including those hired via secondment agreements.
Furthermore, as stipulated by the existing legislation, certain employees are exempt from the Digital Employment Card requirement:
- Managerial Employees: Individuals with supervisory or decision-making authority who meet the criteria set out in the relevant legislative framework (as established by Ministerial Decision 90972/2021, and as amended and currently in force by Ministerial Decisions 113169/2023 and 24595/2024) are not required to clock in or out, even if they are registered in the system.
- Employees Without a Fixed Workplace: Employees whose job sites change frequently during the day—such as medical visitors, sales inspectors, traveling salespeople, technicians, drivers, employees who visit their employer's clients, advertisers, traveling sales reps, service technicians, delivery drivers, field staff—are exempt from clocking when working outside a fixed work location. They must carry documentation of their employment contract to justify not clocking in, but their lack of doing so is considered justified.
- Field staff, including agricultural workers, fishery workers, and those employed in construction and technical projects.
It is important to note that administrative sanctions for non-compliance will be imposed starting on November 5, 2025. Employers are advised to ensure full compliance with the Digital Card system to avoid potential penalties.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
