Hoteliers Up in Arms Over the Digital Work Card

Hoteliers point out that the digital work card does not take into account the specific operational needs of the hospitality sector. They have already addressed a formal letter to the Ministry of Labour regarding the issue.

Through their representative body, the Hellenic Federation of Hoteliers (POX), hotel owners are voicing their objections, citing issues arising from both the implementation circular recently made public and legal provisions that the digital work card appears to contradict. “It is evident that the particular needs and operational realities of hotel businesses have not been taken into account,” states the letter addressed to Minister of Labor and Social Security, Niki Kerameos, with copies sent to Minister of State Akis Skertsos and President of the Greek Tourism Confederation, Giannis Paraschis.

After all, the tourism sector consists of multiple interconnected industries, and some, like hospitality, involve a wide range of specialties, services, and unique working conditions—operating 24/7, either in seasonal peak intensity or year-round. The industry argues that the Ministry of Labor is pushing ahead with the implementation of a significant measure without considering crucial factors highlighted by both employers and employees.

The Issues

A prime example of the problems stemming from the Ministry’s circular is the designated clock-in and clock-out buffer time, which is set at 10 minutes (compared to 30 minutes for the industrial sector). According to hotel owners, this rule completely disregards the additional time required for employees to prepare for their shifts (such as changing uniforms) and the considerable distances between locker rooms and work areas, especially in large hotel complexes.

It is worth noting that as of March 1, 2025, the tourism and food service sectors will be fully integrated into the Digital Work Card system. The measure was initially introduced as a pilot in September 2024—a time when, for many parts of Greece, the summer tourism season was winding down, particularly for seasonal hotels. “How are hotels and their employees expected to adapt to these new requirements? Who will be held accountable for the operational issues these decisions will cause during the peak summer season? Have we truly considered the consequences for service quality?” asks the POX letter.

The food service sector echoes similar concerns, particularly regarding the rigid 10-minute rule. The General Confederation of Professionals, Craftsmen, and Merchants of Greece (GSEVEE) also addressed the Minister of Labor, arguing that “the preparation time should be increased from 10 to 30 minutes, not only for practical reasons but also for the sake of fairness.”

Another issue arises where the implementation of the digital work card clashes with existing labor laws, such as the prohibition of split shifts for kitchen staff (Ministerial Decision 20714/1023 – Government Gazette B 683, 1976). This regulation no longer reflects modern reality, as hotel food services now operate under half-board, full-board, or all-inclusive models, requiring morning and evening (or even midday) shifts. The maximum permitted gap between split shifts is currently set at five hours, but industry representatives are requesting it be extended to eight hours.

Regarding mandatory rest periods between shifts, current legislation sets this at 11 hours. Industry representatives propose that, under specific conditions and with employee consent, this period be reduced from 11 to 8 hours. They reference Article 17 of EU Directive 2003/88/EC, which allows exceptions to the 11-hour rest period, provided that workers receive compensatory rest or, in exceptional cases, alternative protective measures.

Hotel businesses argue that their shift-based operations, frequent schedule adjustments, and the nature of food service departments (breakfast-dinner shifts) make it extremely difficult to adhere to the 11-hour rest rule, particularly during peak months. A typical example is reception staff who sometimes work an evening shift (ending at 11:00 PM) and then opt for a morning shift (starting at 7:00 AM). This issue has become more pronounced in recent years due to staffing shortages.

Another major concern relates to working hour adjustments. According to the National Sectoral Collective Labor Agreement (EKSEE) for hotel employees:
“Businesses covered by this agreement may employ salaried staff beyond the maximum daily and weekly working hours for up to one extra hour per day without being required to pay additional compensation, provided that the average weekly working hours over an eight-week period do not exceed 40 hours.”

The circular, however, does not clarify whether businesses must officially report their use of this work-hour adjustment system or if simply logging work hours via the digital work card is sufficient.