NEW RULES ON CREDITING INSURANCE SERVICE DAYS AND ADMINISTRATIVE FINES
With SSI Circular No. 2026/22 issued by the Social Security Institution (SSI) on 19 October 2026, Circular No. 2015/25 was amended. The new rules clarify how insurance service days, employment entry and termination records, and administrative fines will be handled when actual employment is identified through information and documents obtained from public authorities, official reports and, in particular, traffic penalty notices served in person.
One Service Day Will Be Credited for Each Verified Record
Where information or documents obtained from public authorities, or reports prepared by public officials such as police officers, municipal police, doctors, veterinarians or engineers, establish that an individual actually worked, one insurance service day will be credited for each record as of the date of the relevant report or document. Traffic penalty notices served in person and other supporting records will be reviewed by the relevant SSI units, with appropriate cases referred to social security inspectors.
How Multiple Findings at the Same Workplace Will Be Treated
If more than one record showing actual work at the same workplace is submitted to the SSI, the earliest finding will be treated as the employment commencement date. One service day will be credited for each verified day in the same month and in subsequent months. The relationship will be treated as part-time employment, meaning that days for which no finding exists will not automatically be credited as service days.
Administrative Fine Will Be Based on the First Finding
For consecutive findings relating to the same employment relationship, the administrative fine for failure to submit the employment entry notification on time will be imposed only for the first finding, in an amount equal to two monthly minimum wages. Subsequent verified days within the same employment relationship will be credited without requiring a separate employment entry notification for each day.
A Month Without a Finding Will Trigger a New Employment Relationship
If a new finding is made after an entire month in which no finding exists, the new finding will be treated as a new employment commencement and the previous employment relationship will end as of the last day for which service was credited. If continuous employment between the first and last findings is claimed, the matter will be referred for inspection. A repeat finding in this context may result in an administrative fine equal to five monthly minimum wages.
Practical Points for Employers
As official records may constitute evidence of employment particularly for field employees, drivers and personnel frequently dealing with public authorities, employers should ensure that employment entry and termination notifications, withholding and premium service declarations, attendance records and assignment documents are consistent with each other. Traffic penalty notices and other official records received by employers should also be reviewed from an unregistered-employment risk perspective.
SSI Circular No. 2026/22 clarifies the crediting of service days on a day-by-day basis where actual employment is identified through public records and adopts a discontinuous-employment approach where there are gaps in the findings. Employers should therefore closely monitor whether there is a full month without any finding, distinguish between initial and repeat findings, and assess the related administrative fine exposure.
