Digital Work Card – Extension to New Sectors

The Ministry of Labour and Social Insurance has issued an Interpretive Circular 25291/23-09-2026 providing guidance on the application of the Digital Work Card system to new sectors of the economy. The extension follows Ministerial Decisions 15441/28-05-20261 and 18047/24-06-20262, which list the sectors to which the use of the digital work card is extended. 

The Digital Work Card obligation has been extended in two phases to cover 11 additional sectors of the economy enrolled on two separate dates and each governed by a Ministerial Decision.

1. From 2 June 2026³ the Digital Work Card obligation applies to the following sectors:

   a. telecommunications, computer programming, consultancy, IT infrastructure;

   b. administrative and support services (employment, cleaning and landscape services);

   c. human health and social work services; and

   d. other services (hairdressers, beauty centres and funeral services).

2. From 29 June 2026 the Digital Work Card obligation applies to the following sectors:⁴

   a. water collection/treatment, sewage treatment, waste management;

   b. warehousing and support activities for transportation;

   c. head offices, management consultancy activities;

   d. advertising, market research, public relations;

   e. office administrative activities, call centres, conference/exhibition organization; 

   f. gambling and betting activities; and

   g. repair and maintenance of computers, communication equipment and vehicles.

The Circular reiterates the fundamental rules governing the operation of the Digital Work Card system, placing particular emphasis on employer responsibility and the permissible tolerances for scanning irregularities. These are:

1. Scanning records the first entry into and last exit from the employer’s premises.
2. Employers bear the responsibility for the correct application of the system and scanning by employers on behalf of employees is prohibited.
3. The maximum permitted delay for submission of scans is 15 minutes.
4. An even number of scans per day is required: 0 for remote work, 2 for continuous schedule, 4 for split shift.
5. Up to 3 single (odd) scans per month per employee are accepted (due to inadvertence).

Certain categories of employers, employees and work arrangements fall outside the scope of the Digital Work Card system, either by virtue of a horizontal sectoral exemption or due to the nature of the employment relationship. These are: 

1. Horizontal exemptions: the petroleum, mining, shipyard, agricultural, fishery and construction industries and lawyers on fixed retainer.
2. The employers’ principal Business Activity Code (KAD) registered with TAXIS determines inclusion in the system.
3. Senior management is exempt from scanning but registration in ERGANI II is required.
4. Workers are not required to scan on the days they are working remotely.
5. Special security rules apply to defense industry installations (NATO/National Industrial Security Regulation).

The Circular provides detailed guidance on a number of practical scenarios that frequently arise in the workplace, including work at third-party premises, inter-branch movement, employee lending and flexible working arrangements. These are:

1. Employees at third-party premises must scan at their regular place of work.
2. Where employees move between branches during a workday, they must scan entry at the first branch and exit at the last.
3. In cases of secondments, the third-party (indirect) employer bears responsibility for compliance.
4. Agreements can be reached for flexibility for up to 120 minutes daily.
5. Preparation time is in general 10 minutes and 30 minutes for industry and energy sites and operating theatres.
6. In cases of hybrid models (physical presence and remote work), scanning is only required when an employee is physically present.

Employers should note that a grace period applies following enrollment in the system. Once this period expires, the full range of administrative sanctions⁵ becomes enforceable. These are:

1. Sectors enrolled on 2/6/2026: sanctions apply from 12 October 2026.
2. Sectors enrolled on 29/6/2026: sanctions apply from 16 November 2026.
3. Employers may not unilaterally charge leave days or offset remuneration due to improper card use.
4. The Labour Inspectorate conducts risk analysis in cases of recurring omissions.