By virtue of article 74 of Law 4808/2021 (A' 101) and with the Ministerial Decree No. 49758/26-5-2022(B' 2668), as amended and in force, a legal framework for the digital organization of working time and the digital work card is established in Greek law. All companies-employers of Greece are obliged to have and operate an electronic system for measuring the working time of their employees, whether they are employed under contract or a dependent labor relationship, directly connected and interoperable, in real time, with an online governmental platform. The measurement of working time is carried out using a digital work card.

Furthermore, with par. 2 of Part A' of the above RA, as amended with the under no. 113169/27.12.2023 Ministerial Decree (B' 7421/28-12-2023) and No. 24595/28.03.2024 Ministerial Decree (B' 1966/29.03.2024), the scope of the digital work card system is determined, which in the current implementation phase, includes:

1. All banks, from 01.07.2022.

2. Supermarkets with more than 250 employees (with main VAT number 4711), from 01.07.2022.

3. Security companies (with main KAD 801* and 802*), from 16.02.2023

4. The private insurance companies (with main KAD 651*), from 16.02.2023.

5. OSE S.A., ERGOSE, Fixed Communications S.A., OSY, OASA, OSETH, OASTH, Attiko metro, Building Infrastructures S.A., Egnatia Odos S.A., EYDAP and ELTA, as well as Hellenic Train and the Hellenic Railway Equipment Maintenance Company, from 22.03.2023.

6. The companies belonging to the industry sector [with main KAD from 10 to 33, except the two-digit 19, the four-digit 3011 and 3012 and Hellenic Defense Systems A.V.E. (EVO - PYR- KAL) ], from 01.01.2024.

7. Businesses belonging to the retail trade sector (with main KAD 47) from 01.01.2024.

It is recalled that the companies-employers in question are obliged, based on the relevant ministerial decisions, from the above dates to have and activate, respectively, a digital work card system for all their employees with a contract or a dependent work relationship, who are employed on a physical basis presence at the place of employment of the company, including the employees who are employed in the above companies through lending.

From the moment a company - employer joins the Digital Labor Card mechanism, it is obliged, regardless of the number of employees, to have and activate a digital labor card system for all its employees with a contract or dependent labor relationship, who are employed by physical presence at the place of employment of the business (ie, in the current phase of implementation, in its building facilities), including those employed by it through lending, taking into account some exceptions, but not teleworkers.

Thessaloniki June 27, 2024

Apostolos O. Mountoulias

Managing Partner