Among developments introduced in September, particular attention should be paid to two aspects of employment management: the management of absences and employees’ choice regarding the allocation of their severance pay (TFR).
Notably, in light of the recent clarifications issued by INPS, the use of leave entitlements to care for persons with disabilities pursuant to Law No. 104/1992 requires employers to distinguish carefully between the lawful exercise of such entitlements by employees and breaches of the limits laid down by the applicable legislation.
As regards the choice concerning the allocation of TFR, the introduction of the ministerial TFR3 form makes it possible to verify – subject to certain exceptions – the completeness of the information that employers are required to provide to and receive from employees in order to properly comply with the information obligations laid down by the legislation governing supplementary pension schemes in respect of employees newly hired from 1 July 2026 onwards.
These requirements call for significant administrative oversight by employers, aimed at ensuring full compliance with the applicable legislation, both in terms of the content of the relevant communications and the applicable deadlines, while safeguarding the individual rights granted to employees.
Buona lettura,
Marcella De Trizio
Temporary agency work – recent developments on the maximum duration of assignments
Following recent legislative changes, the rules governing temporary agency work have undergone significant amendments with regard to the maximum duration of fixed-term assignments where the temporary work agency enters into both an open-ended temporary agency work agreement (staff leasing) and a fixed-term temporary agency work agreement with the user undertaking.
This article provides an overview of the current regulatory framework.
Occupational accidents and diseases – revaluation of compensation for biological damage
With circular message No. 37/2026, INAIL announced that, with effect from 1 July 2026, the economic benefits paid by INAIL as compensation for biological damage resulting from occupational accidents or diseases will be increased by 1.4%.
Libro Unico payslips for riders – clarifications from the Ministry
In its reply to query no. 1/2026, the Ministry of Labour and Social Policies provided clarification on the processing of the Libro Unico (LUL) payslips for riders engaged under occasional self-employment contracts or operating under a VAT position.
Notably, the Ministry clarified that employers are required to prepare and provide workers with the LUL, including a record of the number of deliveries made by each worker during the July 2026 pay period, within 90 days of that pay period.
Employee sickness – commencement of sick leave
With circular message No. 92/2026, INPS addressed the economic treatment applicable in the event of sickness, providing new guidance on the date from which employees are entitled to the daily sickness benefit.
Specifically referring to the current organisational framework of the National Health Service, under which general practitioners may frequently be unable, for organisational and healthcare-related reasons, either to visit an employee at home or to see the employee at their surgery by the day following the first day of sickness, INPS clarified that, with effect from 4 September 2026, entitlement to sickness benefit is recognised from the day immediately preceding the date on which the medical certificate is issued, both where the doctor ascertains the employee’s illness during a home visit and where the examination is performed at the doctor’s surgery.
Sick leave – effective date of the social security benefit
By circular message No. 92/2026, INPS intervenes on the economic treatment granted to workers in the event of sickness, providing new guidance concerning the start date of the prognosis period to be specified in the medical certificate – certifying temporary inability to work – for the purpose of recognising the relevant daily allowance. Notably, INPS […]RegToDate 21/2026
Supplementary pension funds – TFR3 form published
By Interministerial Decree of 4 September 2026, the Ministry of Labour and Social Policies announced the adoption of the new ‘TFR3’ form, which represents the ministerial, non-exclusive version of the forms that private-sector employers are required to provide, at the time of recruitment, to workers recruited after 30 June 2026 and through which such workers […]RegToDate 22/2026
Contribution debts – New interest rate from 16 September 2026
By monetary policy decision of 11 September 2026, the European Central Bank (ECB) increased, with effect from 16 September 2026, the interest rate on the Eurosystem’s main refinancing operations (MRO) – formerly the Official Reference Rate – from 2.40 to 2.65 percentage points. Following the increase in the MRO, INPS clarified, by circular message No. […]RegToDate 23/2026
ISTAT – Consumer Price Index for August 2026
With press release of 16 September 2026, ISTAT announced that the Consumer Price Index for August 2026 stood at 103.7 points. This index is used to determine the revaluation coefficients applicable to the severance indemnity (TFR) and employment-related claims.
Where an employer pays an advance on the employee’s TFR before termination of the employment relationship, the revaluation rate applies to the entire amount accrued up to the payroll period in which the advance is paid. For the remaining payroll periods of the relevant year, the same revaluation rate applies only to the portion of the TFR remainingwith the employer, net of the amount paid in advance.
Lastly, it should be noted that the portion of the TFR paid by employees into supplementary pension schemes is not subject to revaluation.
OT23 form – recognition of the reduction in the average INAIL premium rate for injury prevention measures
Through its Operational Instruction of 18 September 2026, INAIL clarified that, for the purposes of obtaining a reduction in the average prevention premium rate, employers must demonstrate that they have remedied any breaches relating to the protection of working conditions and occupational health and safety within the deadlines set by the supervisory authorities.
Employers may apply for the reduction in the average prevention premium rate by submitting the relevant OT23 form and providing evidence that they have made investments and implemented measures within the company to protect workers’ health and safety.
TFR3 form – UniEmens procedures updated
Through message No. 3021/2026, INPS announced that the procedures for acquiring and validating, within the UniEmens reporting flow, information concerning the choice regarding the allocation of TFR made by employees hired from 30 June 2026 onwards have been updated following the publication of the TFR3 form.
Notably, from the July 2026 reporting period onwards, the new value “T3” may be entered in the <TipoScelta> element under <GestioneTfr>; <DestinazioneTFR>, meaning: “Choice explicitly made using Form TFR3 – newly hired employees whose employment commenced after 30 June 2026”.
Foreign workers – instructions and new entry quotas for 2027
With joint circular message No. 7185/2026, the Ministry of the Interior, in conjunction with the Ministry of Labour, the Ministry of Agriculture and the Ministry of Tourism, provided operational guidance on the entry quotas for foreign workers for 2027.
Most notably, the entry of 76,200 foreign nationals for non-seasonal employment is permitted for 2027. The pre-filling phase for work authorisation applications will be open from 23 October 2026 to 7 December 2026, while the click day for submitting applications for the entry of foreign nationals for non-seasonal employment will be 16 February 2027.
Worker caregiver – Clarifications on the use of Law 104 leave
By circular message No. 100/2026, INPS clarifies on the use of the three days of paid monthly leave granted to employees for the purpose of assisting family members with disabilities, specifying the rules applicable where the limits on use set by art. 33, para. 3, of Law No. 104/1992 are breached as a result of […]RegToDate 24/2026
JUS – the case-law review journal
In the September issue of JUS, we will address a topic that has been widely debated in case law concerning the maximum duration of fixed-term employment.
This issue has been prepared by examining three aspects that give rise to significant management challenges for employers. We will focus on:
- the criteria for calculating the 24-month period,
- the definition of the same level and statutory employment category,
- the conversion of a fixed-term contract into a permanent employment relationship.
The lower courts have examined these three statutory limits in detail, adopting a rather strict approach aimed at ensuring greater protection in the management of fixed-term contracts and preventing their improper use as a means of increasing precarious employment.
Jus 08/2026
Reimbursement for use of an employee’s private car – tacit authorisation is sufficient
Where an employee uses their private car to perform their work duties, the costs associated with the use of the vehicle may be reimbursed even in the absence of express authorisation from the employer, provided that such authorisation can be inferred from the employer’s conduct (Corte di Cassazione, Judgment No. 24114 of 27 July 2026).
Employee riders: how to comply with the employer’s health and safety obligations
By Marcella de Trizio
AG addressed the topic “Employee riders: how to comply with the employer’s health and safety obligations” in an article published by Lefebvre Giuffrè in QuotidianoPiù on 18 September 2026, authored by Marcella de Trizio.
The prevention obligations incumbent on employers cannot be entirely transferred to workers through self-assessment, nor can they entail financial costs being borne by workers, even in a working environment characterised by a high degree of autonomy, such as that of riders. This principle was established by the Tribunale di Torino in Judgment No. 5811 of 4 August 2026.
Overtime and compensatory rest: limits on employers’ discretion
This article examines a practical case submitted to us in order to assess the limits within which an employer may legitimately grant compensatory rest in lieu of overtime pay.
This labour case study is the first contribution to our analysis of one of the most critical aspects of working time management, a topic that will be revisited in the next October issue, with a focus on working time flexibility.
Labour Case Study 06/2026
CONTRACTUAL DEADLINES
| 1 |
| CLEANING SERVICES – INDUSTRIAL COMPANIES
New minimum pay rates
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| TOURISM – CONFESERCENTI |
| New minimum pay rates
The NCBA of 13 June 2025 for employees of companies providing cleaning and integrated/multiservice services provides for pay increases.
Seniority increases The NCBA of 13 June 2025 for employees of companies providing cleaning and integrated/multiservice services sets out the amounts of the biennial seniority increments for white-collar employees.
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ADMINISTRATIVE DEADLINES
| 12 | 16 | 21 | 30 |
| Mario Negri, FASDAC, PREVIR funds
Employers in the commerce and transport sectors that employ executives are required to pay contributions to the supplementary pension and welfare funds for executives in respect of the previous quarter.
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Declaration and payment of CASAGIT contribution
Employers of journalists and trainee journalists with a subordinate employment relationship are required to pay the contributions due for the previous month and, at the same time, submitthe relevant documentation relating to the monthly declaration of employee salaries, prepared in electronic format. |
Mandatory communication on the usage of temporary workers
Employment agencies performing staff leasing activities are required to report the hiring, extension, transformation, and termination of workers employed during the previous month. The communication must be submittedelectronically to the Employment Centre. |
LUL payslips
Art. 39, L. 133/2008 Employers must complete the Unified Employment Register (LUL) with data related to their employees for each reference month by the end of the following month.
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| Monthly tax withholdings
Employers, acting as tax substitutes, are required to pay the IRPF (income tax) withholdings on employment income and equivalent earnings.
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PREVINDAI fund contribution
Employers in the industrial sector are required to pay contributions on the remunerationpaid during the previous quarter to executives enrolled in Previndai.
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Individual UNIEMENS data flow
Employers already required to submitthe contribution report using the DM10 form and/or the EMENS monthly payroll report must communicate payroll and contribution data, along with the necessary information for the implementation of individual insurance positions and the provision of benefits.
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| INPGI separate management
Contracting entities that engage professional journalists, publicists, and trainee journalists registered in the relevant professional lists or registers, who work under a coordinated and continuous collaboration arrangement, must report and pay the compensation provided to collaborators and contribute to insurance payments, including the portion payable by the journalist.
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| INPS Treasury Fund
Ministerial Decree 30 January 2007
Employers with a headcount of at least 50 employees must pay contribution to the INPS Treasury Fund corresponding to the monthly portion of the severance pay (TFR) accrued in the previous month and not allocatedto supplementary pension schemes.
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| Payment of contribution to INPS separate management scheme
Art. 2(18), Law 8 August 1995, no. 335 Contracting entities employing door-to-door salespersons and those engaged in “Co.Co.Co.” collaboration arrangements must pay social security contribution to the INPS Separate Management scheme.
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| INPS contribution for employees
Employers must pay INPS contribution related to employees’ wages paid in the previous month. |
NORMATIVE DEADLINES
| 23 | 26 | 30 |
| Service contracts
Contractors and subcontractors performing contracts with a value exceeding EUR 200,000 are requiredto submit evidence of payment of the withholding taxes deducted from their employees’ remuneration during the preceding month or, where exempt from this obligation, a copy of their Tax Compliance Certificate. |
Tax assistance
Employers must provide the supplementary return where errors have been identified in Form 730/2026.
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CIGO subsidised furlough
Employers must submit CIGO furlough applications for unavoidable events that took place in the previous month. |
Webinar series: “WhatsApp, the great unknown”
Save the date – webinar series “WhatsApp, the great unknown – opportunities, limitations and critical issues of a business communication tool”
From 15 October to 12 November 2026, every Thursday at 2.30 p.m., AG will host a series of five 30-minute webinars dedicated to WhatsApp and smart apps, which have now become everyday working tools but are still lacking clear rules.
Their use in professional and business relationships raises legal and procedural issues that remain largely unexplored.
Nova of the month – review of labour law and HR management
Tuesday, 27 October 2026, 14:30 – 15:00
Lorenzo Dani and Giorgio Ottaviano will discuss the main news and topics concerning labour law and HR management, in light of recent legislative measures and administrative guidance concerning human resources management within companies.