• Σχόλιο του χρήστη 'Remote Greece S.M.P.C.' | 17 Ιουνίου 2026, 20:02

    Remote is a global HR platform operating in 180+ countries, offering Employer of Record, Global Payroll and Contract Management solutions through a single, compliant platform. Remote participates in this consultation as an Employer of Record (EOR) provider operating in Greece through its local entity, Remote Greece S.M.P.C., which directly employs individuals in Greece to deliver employment-related services to its clients (ΓΕΜΗ no. 159109403000; ΑΦΜ 801558204 / VAT EL801558204), with its registered seat at Alexandras Avenue 116A, 4th Floor, 11471 Athens. Remote fully supports the objectives of Directive (EU) 2023/970 and of the draft, and the purpose of this submission is to ensure that the new obligations apply to the EOR model in a way that produces accurate and meaningful data, thus supporting the monitoring objectives of the competent authorities as well as employers and workers. **Article 4 - Definitions: "pay" and "category of workers"** **The provision:** Pay is defined as the consideration received from the employer, and categories of workers are created by the employer or derive from an applicable collective agreement. - Remote recommends that the Ministry clarify that, where pay elements and role scope are referable to a specific client engagement rather than to a pay policy operated by the employing entity, the relevant pay criteria and worker categories are those applicable to that engagement, because in the EOR model pay and role scope originate from each client's distinct service requirements, and grouping employees engaged on unrelated client engagements into a single category produces categories that correspond to no common pay policy. - The Regulatory Impact Analysis supports this approach in its emphasis on proportionality and the avoidance of disproportionate administrative burden.