Greece’s Digital Work Card (ΕΡΓΑΝΗ): a guide for employers (2026)

02

Which businesses must use it

Sectors are brought in in phases, based on the business’s main activity code (ΚΑΔ) in TAXIS. Each phase has a start date and, separately, a date from which penalties apply:

• From 1.7.2022: supermarkets with more than 250 employees, and banks.
• From 16.2.2023: security services (ΚΑΔ 80.10 and 80.20) and private insurance.
• From 1.1.2024: manufacturing (ΚΑΔ 10–33, except 19) and retail (ΚΑΔ 47), with penalties from 1.7.2024.
• From 11.9.2024: tourist accommodation and food service, with penalties from 1.3.2025.
• From 26.6.2025: energy, wholesale and vehicle repair, financial and insurance activities, administrative and support activities (Decision 16973/2025), with penalties from 3.11.2025.
• From 2.6.2026: telecoms and IT, health and social care, other personal services and further sectors (Decision 15441/2026), with penalties from 12.10.2026.
• From 29.6.2026: water and waste, warehousing and transport support, consultancy, advertising, call centres and events, repairs and further sectors (Decision 18047/2026), with penalties from 16.11.2026.

03

Who is exempt

Under the decisions and circular 25291/2026, the following do not clock in — or are not brought in — among others:

• farm workers, fishery workers and workers on construction projects;
• the whole business, if its main ΚΑΔ is not one of those brought in, or if it has no revenue under that ΚΑΔ (based on its Ε3 tax form);
• managers, who are registered but do not clock in;
• employees on their teleworking days, and those who regularly move between work sites, for those days.

04

What is declared to ΕΡΓΑΝΗ ΙΙ, and when

Before the first employee clocks in, the employer registers two kinds of information:

• Employment details: contractual weekly hours, five- or six-day week, break (length and whether it is within working hours), flexible arrival.
• Working-time organisation: either a fixed weekly schedule or a schedule that varies by day. Each day is a continuous shift, a split shift (the second part starts at least 3 hours after the first ends), teleworking, a day off or a non-working day.

05

How clocking in works

• The employee clocks in personally. Circular 25291/2026 prohibits the employer from clocking in on the employee’s behalf.
• The start or end event must reach ΕΡΓΑΝΗ ΙΙ within at most 15 minutes (circular 25291/2026).
• A day has 0 clock events (teleworking or working off-site), 2 (continuous shift) or 4 (split shift). Up to 3 single clock events a month per employee are tolerated; more lead to a risk-analysis inspection (Labour Code, article 580).
• Preparation time before the start is capped at 10 minutes (30 minutes in manufacturing). Flexible arrival of up to 120 minutes is allowed only with a written agreement (Labour Code, article 580, as amended by Law 5239/2025).
• Means: an employer system that transmits to ΕΡΓΑΝΗ ΙΙ in real time, or a Ministry app such as “Ergani CardScanner”, which reads the employee’s QR card.

06

When a late declaration is allowed

Circular 25291/2026 is clear: a late clock-event declaration is allowed only for force majeure or objective impossibility, and only with one of three reasons:

• a problem with the employer’s systems;
• a problem with power or telecommunications;
• a problem connecting to ΕΡΓΑΝΗ ΙΙ.

07

Advance or retrospective system

For changes to the schedule, the organisation of working time and overtime, the employer chooses between two systems. Under the advance system (προαναγγελτικό) every change is declared beforehand. Under the retrospective system (απολογιστικό) changes are registered by the end of the following calendar month and cross-checked against the card’s clock events.

Deadlines, conditions and traps for each system are in our Greek guide to the advance and retrospective systems.

08

Overtime

Legal overtime is registered in ΕΡΓΑΝΗ ΙΙ with the digital working-time and overtime declaration before the overtime starts (Labour Code, article 581 §1) — or, under the retrospective system, by the end of the following month. The card only records the actual start and end, which are cross-checked against the declaration.

09

Fines

Amounts are per employee affected by the breach:

• €10,500 for not activating the card (Labour Code, article 580 §4). Three findings within 12 months lead to a 15-day suspension of operations.
• €10,500 when, under the retrospective system, the change does not match the card (Labour Code, article 581 §3).
• €3,000 when card data differ from the actual start or end, and €3,000 when they are not submitted (Decision 80016/2022, Annex VI).
• €2,000 for an employment change not declared before it took effect, and €2,000 (part-time) or €600 (full-time) for an undeclared change to working-time organisation (Decision 80016/2022, Annex VI).

10

Practical steps for employers

1. 1Check whether your main ΚΑΔ has been brought in, and from when penalties apply.
2. 2Register each employee’s employment details (hours, five- or six-day week, break).
3. 3Choose the advance or retrospective system and declare the choice before the month it applies to.
4. 4Declare the working-time organisation before work starts.
5. 5Make sure every employee clocks in personally and that each clock event reaches ΕΡΓΑΝΗ within 15 minutes.
6. 6Set a procedure for technical problems: notify the Labour Inspectorate the same day and file the late declaration with the right reason.