Greece's digital work card: what it means for employers of third country workers

The digital work card records in real time when each worker's shift begins and ends, through the ERGANI II information system. It was established by Law 4808/2021. For an employer with staff from third countries the duty is identical to any other worker, but the preparation is longer, because a social security number, a tax number and registration come first.

What the law actually requires

The Ministry of Labour and Social Security describes the card as a mechanism for measuring actual working time. The worker registers a start on arrival and an end on departure, and ERGANI II receives the event with a maximum transmission delay of 15 minutes, per the Labour Inspectorate's guidance. That delay is a technical window for the data, not a grace period for arriving late.

Application began on 1 July 2022 in banks and in supermarket chains above 250 employees, and was extended sector by sector, as ypergasias.gov.gr records. An employer in manufacturing, hotels or construction who assumed the obligation only touched large chains is inside the scope today.

Two points matter in daily record keeping. First, working time measurement data is retained for at least 10 years and the worker has access to it, according to the Ministry of Labour. Second, additional hours and overtime are declared in ERGANI before they are worked, not afterwards, as the Labour Inspectorate states. Reconciling a shift after the fact is a breach, even when the worker is paid correctly for it.

What has to exist before a third country worker clocks in

The card cannot be activated in a vacuum. The worker has to exist in the registers first. That means an AMKA social security number from a citizen service centre or an AMKA desk, a tax number from the Independent Authority for Public Revenue, and registration in the insured persons register of e-EFKA. Without those, the employer cannot file valid contribution returns and cannot activate a digital work card in ERGANI II.

In practice the gap shows up in the first week. The worker has arrived, the residence file is still moving, the crew is waiting, and the registry number has not been issued. The shift is worked and never recorded. That single shift is exactly the finding an inspection picks up. The safe order is registers first, start date second.

What a breach costs

The Ministry of Labour, on the basis of Law 5053/2023, provides for fines of 2,000 to 3,000 euro per worker for individual breaches of the digital work card provisions, and up to 10,500 euro per worker where the card has not been activated at all. The decisive detail is that the amount is calculated per worker. A crew of twelve without activated cards does not produce one fine, it produces twelve.

A Labour Inspectorate check compares three things: who is physically on site, who shows as active in ERGANI II at that moment, and what the declared schedule says. For third country nationals the residence title is checked as well. The consequences of undeclared work are set out in the guide to labour inspections and fines, and the approval step that comes earlier in the chain in the guide to the metaklisi E.4 procedure.

Two practical measures reduce the exposure. The first is instruction in the worker's own language, so that clocking in does not depend on Greek he does not speak yet. The second is a named supervisor per shift who checks at the end of the day which records are missing, rather than leaving the accountant to discover it at month end. The full weight of this administration shows up in the cost of hiring a third country worker.

The digital work card does not create new law on working hours. It makes the hours that already applied visible. For companies employing staff from third countries that means the registers and the shift administration have to be ready before the first worker arrives. More on employing workers in Greece is on the page for employers.