With the return to ordinary business following the summer holidays, the 2027 Budget is beginning to take centre stage in the political debate.
According to press reports, a number of measures have already secured funding for 2027, while resources have yet to be identified for others.
Measures already funded include the bonus for employed and self-employed mothers with at least two children and the reduced 1% tax rate on productivity bonuses, applicable in 2026 and 2027. The enhanced tax relief for incentives linked to increases in productivity, profitability and efficiency is also expected to be confirmed, together with the tax-exempt threshold for fringe benefits.
Resources still need to be identified, however, to maintain the reduced 5% tax rate applicable to pay increases arising from collective bargaining renewals, as well as the 15% substitute tax applicable to “strenuous work”, namely premium rates paid to employees with income of up to EUR 40,000 for night work and work on public holidays, and shift allowances.
A possible tax relief measure for thirteenth-month salary payments is also under consideration.
There is also discussion of a further reduction in IRPEF, with the tax rate applicable to the income bracket between EUR 28,000 and EUR 50,000 being reduced from 35% to 33%.
Buona lettura,
Marcella De Trizio
Regional IRPEF Surcharge – Income Exemption Threshold
Legislative Decree No. 147/2026, containing provisions on regional and local taxation and regional fiscal federalism and in force from 12 August 2026, also introduced changes concerning regional IRPEF surcharges (Art. 23).
Notably, Regions are permitted to establish an exemption threshold based on the fulfilment of specific income requirements. This threshold is defined as an income limit below which the regional IRPEF surcharge is not payable and above which the surcharge applies to the taxpayer’s total income.
Company car fringe benefits – New criteria for determining value
By Legislative Decree No. 148/2026, the legislator intervenes once again in relation to the criteria for determining the value of the fringe benefit represented by a car granted for mixed business and private use: – by increasing the value of the benefit according to the age of the vehicle assigned to the worker, irrespective of […]2026 Permanent Employment Incentive – Submission of Applications
With message no. 2518/2026, INPS supplements the guidance previously provided in circular message No. 72/2026 adding: (i) instructions on the procedures for submitting applications for the contribution exemption; and (ii) administrative clarifications concerning access to the measure.
With regard to the conversion of fixed-term employment relationships into permanent employment relationships with effect from 1 August 2026, applications for the incentive may be submitted electronically from 29 July 2026.
Instalment payment of social contribution debts – INPS regulation
By circular message no. 60/2026, INPS sets out the rules governing the payment by instalments of outstanding social security contribution and related ancillary charges, in light of Article 23 of Law No. 203/2024 and the INPS regulation of 24 October 2025.
Specifically, payment by instalments may be granted in the following circumstances:
- where a temporary and objectively demonstrated financial difficulty is declared, for debts of up to EUR 500,000.00, repayment may be authorised over a maximum of 36 monthly instalments,
- where a temporary and objectively demonstrated financial difficulty is declared, for debts exceeding EUR 500,000.00, repayment may be authorised over a maximum of 60 monthly instalments.
In order to obtain an instalment arrangement, the taxpayer must declare that the objectively demonstrated financial difficulty is temporary in nature. This requirement enables INPS to consider that there is a realistic prospect of financial recovery and of overcoming the state of financial distress, consistently with the purpose of the instalment payment scheme.
INAIL benefits – insurable earnings limits for executives
With circular message no. 35/2026, INAIL established the insurable earnings limits for the calculation of insurance premiums for 2026 in respect of certain categories of workers.
With specific reference to executives, from 1 July 2026 the conventional earnings are determined as follows:
Daily conventional earnings: EUR 128.22
Monthly conventional earnings: EUR 3,205.48
Hourly conventional earnings*: EUR 16.03
*applicable only to executives employed under part-time contracts
Stock option plans for executives in the finance sector – exemption from the additional IRPEF surtax
By measure No. 223895/2026, the Italian Revenue Agency (Agenzia delle Entrate) established the procedures and deadlines for payment of the amount due to Third Sector entities, in consideration of which an employer or principal that is a financial intermediary or financial holding company may disapply the 10% IRPEF surcharge applicable to: (i) stock options and other incentive schemes implemented through shares; and (ii) variable remuneration or emoluments exceeding three times the fixed component of remuneration, awarded to employees classified as “executives” and to individuals engaged under coordinated and continuous collaboration arrangements (Art. 33(2-ter) of Decree-Law No. 78/2010, converted into law, with amendments, by Law No. 122/2010).
Hiring of working mothers – INPS instructions on the social security contribution exemption
With Circular No. 82/2026, INPS provides instructions for the application of the full exemption from mandatory social security contributions introduced by art. 1, para. 210-213 of Law No. 199/2025, aimed at promoting the employment of working mothers, in favour of private-sector employers who, from 1 January 2026, hire women who have not held regularly paid […]
Victims of violence – access to NASpI unemployment benefit following resignation
With message no. 2540/2026, INPS clarified that resignations submitted by employees who are victims of stalking or gender-based violence may, subject to certain conditions, be treated as resignations for just cause, thereby enabling the employee concerned to access the monthly unemployment benefit (NASpI).
Indeed, INPS, in accordance with the opinion of the Ministry of Labour, considers that acts of stalking or gender-based violence against an employee, even where committed by persons outside the workplace, may, in principle, give rise to a situation of “objective impossibility of continuing the employment relationship”, entitling the employee to access NASpI pursuant to Art. 2119 of the Codice Civile.
Disability – online service for submitting the “Life Project” application
With message No. 2550/2026, INPS announced that the “SISDA” online service is now available on its website, enabling individuals whose disability status has been certified to submit an application for the individual “life project” regulated by Art. 15 of Legislative Decree No. 62/2024.
By submitting the application, the person with a disability requests and authorises INPS to transmit the following documentation to the Social Territorial Area (ATS) responsible for the municipality of residence, or to another body designated under regional legislation:
- the final certificate confirming disability status and any subsequent amendments,
- the “WHODAS” questionnaire,
- the personal contact details provided.
Meal vouchers not provided – fiscal treatment of compensation for damages
With Ruling no. 156/2026, the Italian Revenue Agency clarified that amounts paid to an employee by way of compensation for damages arising from: (i) the inability to take a lunch break during on-call shifts; or (ii) the employer’s failure to provide meal vouchers or an alternative canteen service, do not form part of the employee’s taxable income and are therefore exempt from taxation.
Indeed, such amounts constitute compensation for actual financial loss, as they are intended to compensate the employee for the loss resulting from the failure to recognise his or her entitlement to a lunch break, with the amount of compensation determined by the court on the basis of the equivalent value of the meal vouchers not received.
ISTAT – Consumer Price Index for July 2026
With press release of 12 August 2026, ISTAT announced that the Consumer Price Index for July 2026 stood at 103.1 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 remaining with 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.
Company Welfare – tax treatment of reimbursement of nursing home expenses for a family member
With reply no. 163/2026, the Italian Revenue Agency clarified that, under a company welfare plan, the reimbursement of expenses incurred by an employee for the admission of a family member to a residential nursing home (RSA), even where the family member does not live with the employee, does not form part of the employee’s taxable employment income.
Indeed, pursuant to Art. 1 of Legislative Decree No. 148/2026, eligibility for the relevant tax benefits is recognised in respect of the employee’s family members referred to in Art. 12 of the TUIR without any additional conditions and therefore also where such family members do not live with the employee.
Health and Safety in Contracting – Labour Inspectorate May Require a Company-Level Agreement to Protect Workers
In the context of an inspection carried out by the Territorial Labour Inspectorate (ITL), where a risk to workers’ health and safety is identified in the Interference Risk Assessment Document (DUVRI) prepared by the company in connection with a contract, the Inspectorate’s power to issue mandatory orders may extend to requiring the employer to enter into a company-level agreement providing for a hardship allowance where no specific allowance for such working conditions is provided for under the applicable NCBA (Consiglio di Stato, Judgment No. 4969 of 22 June 2026).
Worker Representatives – lawful to elect only employees with stable employment to the Board of Directors
A procedure for the election of worker representatives to the Board of Directors (BoD), laid down in the company’s articles of association pursuant to Law No. 76/2025, is not discriminatory where it excludes from eligibility for election employees who are: (i) newly hired; (ii) employed under fixed-term contracts; (iii) approaching retirement; or (iv) on leave of absence (Tribunale di Roma, Judgment No. 8209 of 14 July 2026).
According to the Court, restrictions on eligibility for election as a worker representative to the company’s Board of Directors must be aimed at ensuring the operational continuity of the management body.
Company crisis does not justify withdrawal from NCBA
An employer may not unilaterally withdraw from the applicable NCBA before its agreed expiry date, even where the collective agreement has become excessively burdensome as a result of the company’s economic crisis (Corte di Cassazione, Judgment No. 20601 of 18 June 2026).
Such withdrawal is, however, permitted in the case of company-level collective agreements entered into by an individual employer with local workers’ trade unions.
Employer’s remuneration obligations – consequences of failure to receive CIGS furlough
The rejection of an employer’s application for CIGS does not affect the employer’s remuneration obligations, and the employer therefore remains required to pay employees their remuneration (Corte di Cassazione, Judgment No. 24341 of 31 July 2026).
The employer may, however, be relieved of the obligation to make such payments where it proves that a supervening impossibility prevents it from accepting the employees’ work performance.
High-risk AI, worker protection and new liabilities
By Massimiliano Arlati and Luca Barbieri
AG addressed the topic “High-Risk AI, Worker Protection and New Liabilities” in an article published by Il Sole 24 Ore, Norme & Tributi Plus, authored by Massimiliano Arlati and Luca Barbieri.
Pursuant to Art. 24(1) of Law No. 132/2025, on 10 June the Council of Ministers approved, at preliminary examination, a draft legislative decree aimed at aligning national legislation with the provisions of Regulation (EU) 2024/1689 concerning: the use of artificial intelligence (AI) systems for law enforcement purposes and civil and criminal liability.
Preventive measures when using a high-risk AI system
By Luca Barbieri
AG addressed the topic “Preventive Measures When Using a High-Risk AI System” in a supplement published in Diritto & Pratica del Lavoro by Wolters Kluwer, authored by Luca Barbieri.
The article highlights that, in order to protect workers’ health and safety where a high-risk artificial intelligence system is adopted, employers are already required to take into account the provisions of Regulation (EU) 2024/1689 (AI Act) when updating the Risk Assessment Document (DVR).
Notably, the adoption of a high-risk AI system entails the following obligations for the employer:
- to inform and consult workers’ representatives and the workers concerned,
- to entrust the human oversight of the AI system to persons who possess the necessary competence and training to perform such activities.
Right to disconnect: present and future
By Marcella de Trizio
AG addressed the topic “Right to Disconnect: Present and Future” in an article published by Lefebvre Giuffrè in MementoPiù, authored by Marcella de Trizio.
The right to disconnect must be guaranteed and effectively implemented whenever technology is used. Under the Italian legal system, however, this right is expressly regulated by law only in relation to smart working, with NCBAs having played a key role in filling this regulatory gap. Looking ahead, a bill is currently under consideration which aims to establish a specific legislative framework governing the right to disconnect.
Foreign companies, compliant employment contracts
By Massimiliano Arlati and Giorgio Ottaviano
AG addressed the topic “Foreign Companies, Compliant Employment Contracts” in an article published by ItaliaOggi, Norme & Tributi Plus, penned by Massimiliano Arlati and Giorgio Ottaviano.
A foreign company that does not apply an NCBA but instead adopts its own remuneration system which does not ensure payment of at least the annual minimum remuneration established by the most representative applicable NCBA and the one “closest” to the company’s business activity may be ordered by a court to pay the difference between the remuneration actually paid and the applicable sectoral minimum rates. Such an order may have retroactive effect covering the entire duration of the employment relationship, together with the application of the related statutory ancillary amounts.
Gender pay equity: the right to information and privacy
By Luca Barbieri and Matteo Raglio
AG addressed the topic “Gender Pay Equity: The Right to Information and Privacy” in an article published in NT Plus Lavoro by Il Sole 24 Ore, authored by Luca Barbieri and Matteo Raglio.
The exercise of the right to information is subject to limitations where it is necessary to strike a balance with the rules governing the processing of personal data.
CONTRACTUAL DEADLINES
| 1 |
|
MOTORWAYS AND TUNNELS – CONCESSIONARIES
Sunday allowance and use of transport An allowance is also provided for employees who use their own means of transport for work-related purposes.
|
| TOURISM – CONFESERCENTI |
|
New minimum pay rates
The NCBA of 22 July 2024 for employees of companies operating in the tourism sector, including hotels, campsites and travel agencies, as well as public establishments, collective and commercial catering, bathing establishments, day hotels and tourism businesses, provides for pay increases for companies operating in the collective catering sector and for travel agencies.
|
| TOURISM – CONFINDUSTRIA |
|
New minimum pay rates
The NCBA of 21 December 2024 for employees of companies operating in the tourism industry provides, with effect from 1 September 2026, for pay increases for companies operating in the travel, tourism and conference sectors.
|
ADMINISTRATIVE DEADLINES
| 16 | 21 | 30 |
|
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.
|
|
Monthly tax withholdings
Employers, acting as tax substitutes, are required to pay the IRPF (income tax) withholdings on employment income and equivalent earnings.
|
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.
|
|
|
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.
|
||
|
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.
|
||
|
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.
|
||
|
INPS contribution for employees
Employers must pay INPS contribution related to employees’ wages paid in the previous month. |
NORMATIVE DEADLINES
| 1 | 15 | 23 | 30 |
|
‘730’ form: reimbursements and withholdings
Tax withholding agents must withhold further tax due to be paid by employees (3rd instalment) or pay reimbursements.
|
INAIL: centralisation
Employers must apply to centralise their insurance position at a single office for 2027. |
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. |
CIGO subsidised furlough
Employers must submit CIGO furlough applications for unavoidable events that took place in the previous month. |
Nova of the month – review of labour law and HR management
Tuesday, 22 September 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.
DISCOVER MORE
Pay Transparency on C-Level
Tuesday, September 29, 2026 – 3:00 PM to 6:00 PM
ArlatiGhislandi is hosting the workshop “Pay Transparency on C-Level” at Palazzo Chiesa, an event dedicated to companies that need to align compensation policies for executives and senior figures — including middle management — with the transparency and gender pay equity requirements set out in Legislative Decree No. 96/2026, in force since June 7, 2026.
Pay transparency is not just a formal compliance exercise. Without objective, documentable criteria supporting executive compensation policies, companies face a concrete risk of legal challenges. The workshop covers the practical aspects of the topic: from criteria suitable for justifying pay gaps among executives, to reviewing agreements and contractual tools in light of the new transparency requirements, to methods for preventing disputes related to top management compensation.