PUBLIC-HEALTH UPDATE | Decree-Law no. 105/2021
Decree-Law no. 105 of 23 July 2021 extended the Covid-19 state of emergency and expanded the use of the Green Pass for access to specified activities and venues.
The decree does not impose a general private-workplace obligation, but it changes the operating environment for hospitality, events, training and business travel. Employers need to understand whether they acte as venue operator, event organiser or employer in each situation.
A global company could easily over-apply the rules by requiring certificates for every office interaction, or under-apply them when hosting regulated events. Privacy risk could arise if staff copies or stores certificates rather than using the authorised verification method.
Employers should classify each activity, follow the rule applicable to the venue and limit verification records. Employment consequences should not be inferred from customer-access rules without a separate legal basis.