New clarifications on the insurance of lawyers remunerated by way of a Service Provision Invoice (DPI), the well-known “block receipt”, are provided by e-EFKA Circular 19/2026.
The circular concerns the way in which the insurance contributions of these professionals are reflected in the Analytical Periodic Declaration (APD) and is of particular importance both for lawyers and for the businesses that collaborate with them.
What do the instructions provide, whom do they concern and what do businesses need to pay attention to?
Whom does e-EFKA Circular 19/2026 concern?
The circular concerns lawyers who are remunerated by DPI and fall under the provisions of paragraph 9 of article 39 of Law 4387/2016.
This specific insurance regime applies, under the prescribed conditions, to professionals whose income from the provision of services comes from one or two contracting parties.
For example, a lawyer who works steadily with one business, issuing DPI for their services, may fall under the specific regime, provided that they meet the legal conditions.
Inclusion is not automatic for every lawyer who issues invoices. The actual form of the collaboration and the applicable insurance framework must be assessed.
What changes in the APD of lawyers with a block receipt?
Circular 19/2026 specifies the way in which the insurance of these lawyers is declared in the Analytical Periodic Declaration.
The aim is the proper recording of insurance data, based on the insurance branches to which each professional is subject.
In particular, separate insurance recording is предусмотрed for:
Main pension and healthcare, in accordance with the applicable contribution regime.
Supplementary insurance, where a relevant obligation exists.
Welfare branch (lump sum), in accordance with the more specific insurance provisions.
Depending on the case, the insurance recording may require more than one entry in the APD, using the appropriate codes.
The circular does not establish the insurance regime of lawyers with DPI from scratch, but provides more specific instructions for its correct application and recording.
How are insurance contributions calculated?
For lawyers subject to paragraph 9 of article 39, a specific insurance contribution framework applies.
Contributions for main insurance and healthcare are apportioned between the insured person and the counterparty, in accordance with the applicable provisions.
For supplementary insurance and the welfare branch, more specific rules apply, which are linked to the insurance category and the period to which the declaration relates.
The circular provides the necessary instructions for the correct depiction of these contributions in the APD.
Particular attention is also required in cases where pre-collection receipts for lawyers’ fees have been issued, as special treatment is предусмотрed for the related social security contributions.
What should businesses working with lawyers pay attention to?
For businesses working with lawyers through DPT, proper insurance management is important in order to avoid errors in declarations and contributions.
The main points that require attention are:
1. Check of insurance status
The business must know whether the collaborating lawyer falls under the provisions of paragraph 9 of article 39.
2. Correct entry in the APD
Social security contributions must be declared with the appropriate codes and in accordance with the instructions of e-EFKA.
3. Correct calculation of contributions
A check is required of the allocation of contributions and the special rules applied by insurance branch.
4. Check of previous insurance periods
As the circular includes instructions concerning earlier periods too, it is important to examine whether corrections are required, in accordance with the procedures laid down by e-EFKA.
Why is the correct submission of the APD important?
The Analytical Periodic Declaration is a key tool for recording insurance data and contributions.
Any errors in the insurance presentation may create discrepancies in contributions, a need for corrective declarations, or problems in the professional’s insurance record.
For this reason, the correct application of e-EFKA’s instructions is important both for lawyers and for the businesses they work with.
Regular monitoring of insurance obligations and coordination with the competent payroll department help to address possible errors in good time.
How can AFS support you?
The proper management of social security contributions and the submission of the APD require specialised knowledge, consistency and monitoring of legislative developments.
AFS – Athens Financial Services, through its Payroll & HR services, supports businesses and professionals in managing their social security and employment obligations.
Whether it concerns checking the insurance status of a collaborator or the correct submission of the APD, our team provides guidance based on the applicable provisions.
Do you work with lawyers who are paid on a freelance invoice basis, or do you need support with payroll and your business’s social security obligations?
Contact AFS so that we can review your business’s needs.
Tel.: 210 8317702 | www.afs.gr
