On the 3 April 2020, the Minister of Labour and Social Insurance (“MLSI”) announced important changes based on the guidelines and measures previously issued in relation to the Support Schemes for employees, businesses and employers.
1. Partial Suspension of Business and Self-employed persons:
In order for a company or self-employed person to calculate the reduction in turnover, any transactions that occurred prior to the 16 March 2020, will not be considered in the estimation of turnover (even if any invoice had been issued after the 16 March 2020 or if payment had been received after the 16 March 2020).
2. Groups of companies:
In relation to a group of companies, (i.e. relationship between mother company and a subsidiary or connected company via a common shareholder) that has a separate Employer’s Registration Number with the Social Insurance Numbers (Αριθμούς Μητρώου Εργοδότη, AME) all applications made with the Employer’s Registration Number for either the scheme introduced for full and or partial suspension of business activities, will be considered and treated as one application and the terms/conditions for participating in the scheme (s) will be applied as though the Employer Registration Number was a single one. However, in order for the above to apply, all companies forming part of the group must be engaged in the same activities (e.g. retail chain with many brands/companies, food chains with different brands, group of restaurants with each restaurant being a different company and so on).
3. Single entity companies: such companies that however, have more than one Employer’s Registration Number with the Department of Social Insurance, will be treated as though they have a single Employer’s Registration Number, regardless of whether their applications have been submitted per Employer Registration Number and treatment of such will be done as one employer (for both the full and partial suspension schemes, according to which scheme the employer opted to participate in).
4. Companies whose operations are connected to companies/ businesses that were mandatorily closed pursuant to the Decrees issued by the Minister of Health, will also be entitled to participate in the full work suspension scheme, if it has shown that they have suffered more than 80% reduction in turnover (as this is calculated based on the relevant guidelines).
5. Employees who did not have insurable units within 2018 and are therefore entitled to receive the special unemployment allowance based on their insurable income of January 2020 (or earlier in case this does not apply) will be entitled to 40% of their insurable income and not 60%.
6. All applications will be treated in as a first come – first served basis, provided that employees provide their banking data/IBAN in the electronic application system and the applications are property and accurately completed.
7. The above clarifications and changes apply retrospectively as from the 16 March 2020.