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FAQ (Translated Q&A Appendix)

Translated and lightly edited from the official manual's "Παράρτημα Χρήσιμες Ερωτήσεις – Απαντήσεις" appendix.

1. Am I subject to the new digital work-time procedures?​

Per the ministerial decision for Phase B – Sub-phase I, the Digital Work Time Organization registration ("απογραφική") procedure applies to all employers/businesses, of any economic activity and size, that employ staff under a dependent employment relationship. So: all employers with at least one dependent employee are in scope. Registration is done via the Employment Relationship Change declaration, followed by the relevant schedule declarations (Fixed Weekly, Variable/Modified Per-Day, Leaves).

Regarding the Work Card (Κάρτα Εργασίας): enrollment happens gradually, per sector and/or employee headcount. Relevant decisions and deadlines are announced separately.

2. How do I roll out Digital Work Time Organization for my whole workforce?​

To register, submit a new Employment Relationship Change Declaration choosing, for each employee:

  • Στοιχεία Απασχολούμενου: ΑΦΜ, Επώνυμο, Όνομα
  • Ημερομηνία Αναφοράς (Εφαρμογής) of the declaration — e.g. 16/11/2022
  • Ψηφιακή Οργάνωση Χρόνου Εργασίας: Ναι
  • Συμβατικές Εβδομαδιαίες Ώρες Πλήρους Απασχόλησης (e.g. 40 or 37)
  • Εβδομαδιαία Απασχόληση (5-ήμερη / 6-ήμερη)
  • Κάρτα Εργασίας: Όχι (unless your sector is already enrolled in the Work Card scheme)
  • Ευέλικτη Προσέλευση: 0 (only relevant if Work Card is active)
  • Διάλειμμα (Λεπτά), e.g. 15' or 30'
    • Εντός Ωραρίου: Ναι if the break is within working hours, Όχι if it extends the schedule

From the chosen effective date onward, E4 – Συμπληρωματικό Ωράριο is no longer available — you must use Fixed Weekly or Variable/Modified Per-Day instead.

Discontinued forms: After an employee is enrolled, E4 – Συμπληρωματικό Ωράριο is discontinued for them, and in E4 Τροποποιητικός Αποδοχών / E4 Ετήσιο, the fields ΩΡΕΣ ΕΝΑΡΞΗΣ & ΛΗΞΗΣ - ΗΜΕΡΕΣ ΕΡΓΑΣΙΑΣ and ΩΡΕΣ ΔΙΑΛΕΙΜΜΑΤΟΣ – ΔΙΑΚΟΠΗ must remain empty.

3. Do Διευθυντικά Στελέχη (managerial staff) need a declared schedule?​

Managerial staff are registered normally in Work Time Organization if they have a dependent employment relationship. However, for employees who meet the criteria to be classified as Διευθυντικά Στελέχη and are therefore exempt from working-time limits, the employer is not required to declare a work schedule for them.

In Phase B, in the Employment Relationship Change declaration: select Ψηφιακή Οργάνωση: Ναι and Κάρτα Εργασίας: Όχι, but no Digital Schedule submission is required for these staff.

The same applies to seconded staff (Δανειζόμενο Προσωπικό) under a temporary employment agency (ΕΠΑ) — the indirect employer (agency) is not required to submit the Digital Schedule; this would be the responsibility of the direct (host) employer if applicable.

4. How do I declare a rotational/part-time work schedule for non-working days?​

Declare the contractual full-time weekly hours (e.g. 40h, or less per a collective agreement, e.g. 37h for banks) and the company's weekly working day system (5-day or 6-day).

This makes visible, up to what limit, a part-time employee could potentially be asked to do additional work (i.e. up to completion of the full contractual weekly schedule).

Within the Digital Schedule, the organization of working time must always be submitted before the work begins (Fixed or Variable). [In Fixed, all 7 days must always be covered; in Variable, every date in the declared "Από… – Έως…" range must have an occupancy type.]

For the Day Occupancy Analysis, both Fixed and Variable support: Εργασία (ώρα από/έως), Τηλεργασία (ώρα από/έως), Ανάπαυση/Ρεπό, and Μη Εργασία (used for part-time/rotational employment).

In theory: a full-time employee with stable days, e.g. working Tue–Fri 09:00–17:00, would have Sat/Sun as Ανάπαυση. In a rotational scheme, e.g. only Mon & Tue worked 09:00–17:00, the remaining weekdays in the weekly system are technically ΜΗ ΕΡΓΑΣΙΑ even though that's functionally similar to rest.

In Variable, you may declare only Mon & Tue, but if a change occurs (e.g. Monday is not worked, replaced by another day), it must be declared before the payroll period begins, and must not overlap an already declared start time for Monday in the original Digital Schedule declaration.

5. Can the system pre-fill Telework on non-fixed days?​

Telework can be declared even if it is not a stable weekly declaration, using the "Από – Έως" pre-fill for the week, in either the Fixed or Variable schedule forms.

6. What does "Ευέλικτη Προσέλευση" (Flexible Arrival) mean?​

a) It applies to all employees enrolled in Digital Work Time Organization, provided the Work Card has been activated and both employer and employee have agreed to use it as described above. Flexible Arrival is only allowed once the Work Card has been activated.

b) When "Flexible Arrival" applies, arrival is possible within X minutes (up to a maximum of 120') from the declared start time of the most recently declared Work Time Organization for that day.

7. How do I handle pre-existing leave (long sick leave, military service, parental leave, etc.) when submitting the schedule?​

In the Work Time Organization declaration, declare the work schedule initially as ΕΡΓΑΣΙΑ (work), and then declare all leaves using the appropriate code from the Leave Type Codes table, per the relevant submission.

8. How are seconded employees (δανειζόμενο προσωπικό) registered?​

As with the rest of the workforce, the employer must complete the registration procedure for any seconded employees they employ during the secondment. The digital Work Time Organization declaration is submitted, in each case, before the employee begins the assignment — by the "immediate" (host) employer, and where applicable also by the "indirect" employer (agency). See also Q4.

9. What if I need to make a late ("εκπρόθεσμη") correction to a schedule?​

There is no provision for late (εκπρόθεσμη) submission of schedule modifications.

10. Can the Employment Relationship Change declaration be re-submitted?​

Yes.

11. Can flexible arrival be changed after the initial declaration?​

Yes, using the same Employment Relationship Change form, on a different date.

12. For mothers with reduced hours, do I declare actual or contractual hours?​

The "Συμβατικές Ώρες" field has nothing to do with reduced schedules. It is unambiguous and refers to the Contractual Full-Time Weekly Hours (the weekly full-time hours per Collective Agreement / Arbitration Decision, e.g. 40).

13. Which form is used if an employee transfers to a different branch/site?​

A new Employment Relationship Change declaration for the new branch, plus a new schedule declaration for the new branch.

14. What should I keep in mind for schedule changes involving past dates?​

a. In the Digital Schedule, submission of the work-time organization must always occur before the start of the declared work (Fixed or Variable). [In Fixed, always 7 days; in Variable, every date in "Από… – Έως…" must have an occupancy type.]

b. In the Digital Schedule, any change/modification must always occur before the start of the latest declaration's effective period.

If an employee already has a declared schedule of 10:00–14:00 and is then told they must additionally work until 18:00 at 13:00 on the day, you could submit either:

  • a new Variable declaration for 13:00–18:00, or
  • a new declaration only for 14:01–18:00 (so it doesn't overlap the original 10:00–14:00 declaration).

For the same day, if the original schedule was 09:00–14:00 and it is now 10:45, you could submit either ΕΡΓ 09:00–18:00 or ΕΡΓ 09:00–14:00

  • ΕΡΓ 14:01–18:00 — but always before the next event starts.

Late (εκπρόθεσμη) submission of a schedule modification is not possible.

15. Uploading a file (overwrite behavior)​

If you upload a Variable/Modified Per-Day Excel file for the next month, does it overwrite the existing one, or do you need to do it today?

Uploading a file deletes the existing entries for the scope of that specific declaration (i.e. only the contents of that particular declaration's date range are affected) — it is not additive. If you had already filled in something for a specific date in a declaration, uploading a new Excel for that declaration will delete it.

Reminder: schedule declarations are only effective within the Ημερομηνία Εφαρμογής Ωραρίου Από / Έως of that declaration. When multiple declarations overlap a date/period, the most recently submitted declaration applies.

16. Until when can the employer declare overtime?​

Lawful overtime must be recorded in ΠΣ ΕΡΓΑΝΗ via E8: Αναγγελία Νόμιμης Υπερωριακής Απασχόλησης, for each employee, before it is performed — i.e. before the end of the existing declared schedule for that day. The existing E8 process and procedures remain unchanged.

17. Is there a deadline for declaring leaves/absences after the fact?​

The obligation to declare any type of leave/absence within the first ten days of the following month adds significant administrative burden, which didn't exist before under the prior legal framework. There's currently no clarification on whether specific leave types are paid/unpaid, nor how to handle leave types not covered by the standard list (e.g. those granted via Επιχειρησιακή ΣΣΕ).

Answer: There is no distinction by paid/unpaid leave. The "ΑΛΛΗ ΑΔΕΙΑ" entry covers any type of lawful leave not in the standardized ΠΣ ΕΡΓΑΝΗ list.

Additionally, the obligation to submit declarations of leave already taken — which per Υ.Α. 49758/22 must be completed within the first ten days of the month following the month the leave was granted — does not remove the ability to declare them for an earlier period too. A forthcoming interpretive circular is expected to clarify open questions from the first implementation of the digital schedule and Work Card.

18. What submission channels exist for the new declarations?​

All of the following are supported for both the Employment Relationship Change declaration and the Digital Work Time Organization declarations:

  • Web form submission in ΠΣ ΕΡΓΑΝΗ
  • XML file upload to ΠΣ ΕΡΓΑΝΗ
  • Automated submission via the new Web API for employers

19. How do I validate the XML I produce?​

The validation process applies to all ΠΣ ΕΡΓΑΝΗ XML files. If your XML is invalid, validate it against the provided XSD. A free tool like Notepad++ with the XML Tools plugin can show you the validation errors.

20. Leave types not in the list​

If the leave types your company grants (via sectoral or company-level agreements) aren't in the provided list of values, choose:

  • Άλλη Άδεια (ΑΔΑΛ) for day-based leave, or
  • Άδεια Άλλη (ΩΡΕΣ) (ΩΑΑΛ) for hourly leave (Ωροάδεια).

21. Employee works Mon–Thu 8h and Fri 7.5h — how to fill in E3?​

For the E3 Unified Hiring Declaration, the mandatory fields for the first day of employment are the start and end time (no attached file required, and ΩΡΕΣ ΕΝΑΡΞΗΣ & ΛΗΞΗΣ - ΗΜΕΡΕΣ ΕΡΓΑΣΙΑΣ / ΩΡΕΣ ΔΙΑΛΕΙΜΜΑΤΟΣ – ΔΙΑΚΟΠΗ are not filled in).

For subsequent days, you must submit a Digital Work Time Organization schedule before those days begin — either Fixed Weekly (if hours/days are stable) or Variable/Modified Per-Day (if hours/days are not stable).

22. Is there a limit on the number of "Από–Έως" intervals per day in the Digital Schedule?​

E.g. for 10:00–12:00 / 14:00–18:00 / 20:00–22:00 / 23:00–23:45 — can all of these be declared?

There is currently no business-rule limit. Technically, if needed, the ability to add more intervals would be reviewed.

23. How are public holidays / strikes handled for closed businesses?​

There is currently no provision for declaring days where the business is closed due to a public holiday or industrial action (which may vary by region or sector).