A special regime will apply to the application of the digital work card for categories of workers in tourism who, by virtue of the nature of their work, are forced to travel regularly.
Specifically, as provided for in a new interpretative circular of the Ministry of Labor and Social Security for the application of the digital work card, categories of workers such as tour guides and tour leaders, workers in the car and light motor vehicle rental and leasing sector, etc., will not be required to display the digital card on days when they work outside the company’s fixed place of work and travel regularly and within the same day from one point to another or are abroad as part of their professional obligations.
This provision is based on the fact that work for employees with these specialties rarely begins or ends at the company’s headquarters and, therefore, there is an objective difficulty in marking the digital card at every point where they may be while performing their duties.
The circular also states that, in this case, in which the employees in question are not within the company’s premises and there is no card marking at the beginning and end of employment, the daily working hours declared in the ERGANI PS will be presumed as working hours for the specific day and the failure to mark their card on the specific days of employment within the week will be considered justified and will not result in sanctions.
It is noted, however, that the obligation to display the digital work card by the employees in question is maintained in full, when they work within the company’s premises.
It is recalled that from November 3, 2025, the sectors of wholesale trade, energy, financial companies as well as administrative and support activities in tourism will be included in the regime of full implementation of the Digital Work Card, while the measure has been put into pilot implementation since June 2025, providing businesses operating in the above sectors with a reasonable period of time to adapt to the new data.
In the approximately 4 months that have elapsed since the start of the pilot period, the Ministry of Labor and Social Security held an extensive dialogue with representatives of employees and employers of the above sectors on the implementation of the Digital Work Card.
