By 30 April, employers with a headcount of more than 50 employees are required to submit a biennial report on the situation of employees within the company.
The report on male and female employees “has longstanding origins” and, already in its first edition in 1991 – which does not differ significantly from its current fprmat – was structured so as to provide a statistical overview capable of offering a realistic representation of gender employment conditions against key labour-related parameters.
A first immediate consideration concerns which employers are, in practice, required to submit the report.
It is important to note that the report may also be submitted on a voluntary basis, even in the absence of the aforementioned numerical threshold, as this requirement may provide advantages, for example in the context of participation in public tenders financed, even partially, through the National Recovery and Resilience Plan or the National Complementary Plan (art. 47, para. 3 of Decree-Law no. 77/2021), or in procurement or concession procedures (art. 61, paras. 1 and 2 and annex II.3 of Legislative Decree no. 36/2023).
Further details on submission procedures, the content of the report, as well as other recent obligations and updates, are included in our newsletter.
Buona lettura,
Marcella de Trizio
Hiring of young workers, women and in southern (ZES) regions – Incentives extended
On 28 February 2026, Law no. 26/2026 converting Decree-Law no. 200/2025, containing “Urgent provisions on statutory deadlines”, entered into force.
Among the measures whose validity has been extended is the postponement of the deadline for the application of incentives already provided for the recruitment of:
- young workers under the age of 35,
- ‘disadvantaged’ female workers,
- workers assigned to production units located in the Special Economic Zone (ZES) for Southern Italy (arts. 22, 23 and 24 of Decree-Law no. 60/2024, converted, with amendments, by Law no. 95/2024).
Notably, the deadline for carrying out subsidised hirings has been extended to:
- 30 April 2026 in the case of recruitment of i) workers under 35 years of age and ii) workers assigned to production units in southern Italy (ZES area),
- 31 December 2026 in the case of recruitment of ‘disadvantaged’ female workers of any age, i.e. those without regularly paid employment
Nova 21/2026
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Annual SME Law – Employment-related measures
Law no. 34/2026, in force as from 7 April 2026, introduces provisions aimed at promoting the development of small and medium-sized enterprises (SMEs) from both an organisational and financial perspective.
Without prejudice to the measures concerning access to bank credit, the fight against fake reviews in the tourism sector, the regulation of innovative start-ups and support measures — including financial ones — for specific sectors such as fashion, craftsmanship and the ‘Hotel, Restaurant, Café/Catering’ (HORECA) sector, this contribution focuses solely on the provisions relating to the organisation and management of employment relationships, in particular with regard to:
- health and safety at work,
- the aggregation of micro-enterprises and SMEs and their functioning,
- retirement transition and generational turnover,
- tax incentives for business networks.
Among the various measures introduced, particular relevance is attached to art. 11 of the law, which amends art. 3 of Legislative Decree no. 81/2008 by providing that, with reference to work performed under smart working arrangements, compliance with health and safety obligations is ensured by the employer through the delivery to the employee – and to the workers’ safety representative – of a written notice identifying both general risks and specific risks connected with this particular mode of performance of the employment relationship.
Such notice must be provided to the employee at least on an annual basis. Failure to comply with this obligation is punishable by arrest from two to four months or by a fine ranging from EUR 1,708.61 to EUR 7,403.96.
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ISI 2025 Public Notice – Deadlines for the submission of applications for incentives
With the ISI 2025 public notice, INAIL has set out the procedures and timelines for submitting applications for access to incentives funded by INAIL, aimed at companies implementing projects to improve employees’ health and safety conditions.
Employers wishing to benefit from the incentive for projects carried out during 2025 must submit their application exclusively in electronic form, from 13 April 2026 until 28 May 2026.
Substitute tax on pay increases and shift allowances – Tax codes
With Resolutions no. 2 and no. 3 of 2026, Agenzia delle Entrate established the tax codes for the payment of:
- the substitute tax on i) bonuses and allowances for night work and for work performed on public holidays, as well as on ii) shift allowances paid to employees,
- the substitute tax on salary increases granted to employees in 2026 pursuant to collective agreement renewals signed between 1 January 2024 and 31 December 2026.
Concerning the aforementioned increases, it should be noted that the tax authorities have not provided any further interpretative guidance concerning the application of the substitute tax regime.
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Bonuses and allowances for night work, public holiday work and shift work – Substitute tax regime
With circular message no. 2/2026, Agenzia delle Entrate set out its interpretative position regarding the application of the substitute tax in lieu of IRPEF and the related regional and municipal surcharges, pursuant to art. 1(10-12) of Law no. 199/2025, to bonuses and allowances granted to employees under the provisions of the applicable NCBA for night work, as well as for work performed on public holidays and weekly rest days, and to shift allowances and any emoluments connected with shift work provided for by the applicable NCBA.
For 2026 only, the above-mentioned bonuses and allowances are subject to the favourable tax regime up to an overall annual limit of EUR 1,500.00, applying a tax rate of 15%. It is also provided that the substitute tax may be applied only where the employee has received employment income for 2025 not exceeding EUR 40,000 gross.
Synthetic indices of contributory reliability: ministerial decree and initial INPS guidance
Synthetic indices of contributory reliability (ISAC) have been introduced as part of a project aimed at fostering cooperation between INPS and other institutions, with the objective of identifying and preventing the underreporting of contribution bases. INPS sends the relevant employers a communication setting out any discrepancies from the standard values of the indicators used within the ISAC model. Employers falling within the normal range may avoid priority inspection assessments.
On an experimental basis, Ministerial Decree of 3 March 2026 identified ISAC indicators for two economic sectors considered to be at higher risk of contribution evasion and avoidance, namely wholesale food trade and hotel and non-hotel accommodation services, with the prospect of extending the system to additional sectors in the future.
Subsequently, with circular message no. 26/2026, INPS provided initial guidance on ISACs, specifying their scope of application – currently limited to the above-mentioned wholesale trade and accommodation sectors – the data sources used for their construction, the possible regularisation actions available to non-compliant employers, and the incentive mechanisms applicable to compliant employers.
Company directors: PEC certified email notification exempt from stamp duty
In its answer to query no. 16/2026, Agenzia delle Entrate clarified that the notification to the Companies Register of the digital domicile by company directors, as provided for by art. 1(860) of Law no. 207/2024, may benefit from exemption from stamp duty and secretarial fees (art. 16, para. 6 of Decree-Law no. 185/2008).
Indeed, excluding directors from such exemption would result in an unjustified disparity with respect to a formal requirement serving the same traceability purposes.
Prohibition on collecting information on employees’ health conditions and private life
With Decision no. 107 of 24 February 2026, the Data Protection Authority (Garante per la Privacy) ordered the definitive restriction of the processing of data – systematically collected and stored for the entire duration of the employment relationship and for up to 10 years after its termination. by the employer through a digital platform interconnected with the employee attendance recording system – relating to: i) specific health conditions, ii) participation in strikes and trade union activities, as well as iii) strictly personal, family and private information concerning employees; and of the processing carried out through video surveillance systems positioned near access points to areas reserved for employees.
As data controller, the employer is authorised to process employee data provided that such processing is necessary:
- for the performance of the employment contract or for pre-contractual measures taken at the request of the data subject (art. 6(1)(b) GDPR), or
- to comply with a legal obligation (art. 6(1)(c) GDPR).
With specific reference to the processing of special categories of personal data — such as political opinions, religious or philosophical beliefs, or trade union membership — by way of derogation from the general prohibition under art. 9(1) GDPR, such processing is permitted only where specific conditions are met, namely where the employer is required to “carry out obligations and exercise specific rights of the controller or of the data subject in the field of employment and social security and social protection law, insofar as it is authorised by Union or Member State law or by a collective agreement” (art. 9(2)(b) GDPR).
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Tax regime for ‘inpatriate’ workers – Reduction of the benefit in case of transfer to another region
With ruling no. 76/2026, Agenzia delle Entrate clarified, with regard to the application of the special tax regime for ‘inpatriate’ workers in force as at 31 December 2023, that workers who transfer their tax residence from a Southern Italy region to another region of the national territory lose the enhanced benefit consisting in the 90% exemption of employment income.
The application of the ordinary 70% relief provided for by art. 16 of Legislative Decree no. 147/2015 applies retroactively.
ISTAT – Consumer price index for February 2026
With its press release of 17 March 2026, ISTAT announced that the consumer price index for households of workers and employees (FOI) for February 2026 stands at 100.9 points.
This index is used to determine the revaluation coefficients applicable to TFR and employment-related receivables.
Special CIG subsidised furlough for companies in areas of complex industrial crisis – extension request
Following the entry into force of the provisions contained in the Decreto Milleproroghe (art. 14, para. 1-sexies of Decree-Law no. 200/2025), with note no. 5035 of 18 March 2026 the Ministry of Labour provided operational guidance regarding applications for the extension of wage supplementation measures in derogation for companies operating in areas recognised as zones of complex industrial crisis.
Tax regime for ‘inpatriates’ also applicable to employees working remotely from Italy
In its answer to query no. 82/2026, Agenzia delle Entrate, confirming its previous position, clarified that the special tax regime for inbound workers also applies to employees who transfer their tax residence to Italy and perform their work in the country under smart working arrangements for a foreign employer.
JUS – The Case Law Review Journal
In this March issue of JUS, the focus will be on:
i) employer liability for accidents occurring during secondment,
ii) the nullity of the dismissal of an employee with a disability who did not inform the employer of their condition,
iii) the lawfulness of a transfer due to emerging conflict between the contractor and the client,
iv) the extension of a supervisor’s liability to employees not directly under their authority.
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Duties of the supervisor where multiple companies operate on the same site
In workplace accident prevention, where multiple contractors are operating on the same site carrying out different works, the legislation set out in Legislative Decree no. 81/2008 is considered to establish “a position of guarantee covering the risks affecting all those who have work-related access to the site, regardless of the existence of a specific relationship between the injured party and the individual holder of that position”.
Accordingly, in such cases, the supervisor of one of the contractors is required to report any hazardous situation in order to protect not only their own employees but also all other individuals involved in or potentially affected by the activities carried out on the site as a whole (Corte di Cassazione, criminal section, 23 February 2026, no. 7096).
Ineffective transfer of business – Measure of damages
In the context of a transfer of business declared ineffective, the incentive paid to the employee to accept collective dismissal cannot be deducted from the compensation due to that employee (Corte di Cassazione, 2 March 2026, no. 4665).
This because the economic benefit represented by the incentive offered by the employer does not arise from the unlawful transfer of the business unit, but from the dismissal implemented by the transferee company within the framework of the collective procedure.
Health and safety at work: legal definition of employer
Regarding the legal definition of employer in relation to health and safety obligations, the criminal section of Corte di Cassazione reaffirmed that “for the purposes of prevention, the employer is the person who, by virtue of having decision-making and spending powers, is responsible for the organisation or the production unit”.
Accordingly, in the case of a company with three managing directors entrusted with different roles, but all vested with decision-making and spending powers, all three directors are deemed to hold a position of guarantee as employers for health and safety purposes, regardless of the fact that only one of them signed the risk assessment document (Corte di Cassazione, criminal section, 25 February 2026, no. 7563).
Disciplinary proceedings and the use of WhatsApp chat logs
Messages exchanged between colleagues within a WhatsApp group, even if offensive towards the employer, must be regarded as private correspondence, protected under art. 15 of the Italian Constitution concerning the freedom and confidentiality of communications.
Accordingly, disciplinary dismissal imposed on the basis of offensive voice messages shared within a WhatsApp group is unlawful (Court of Appeal of Ancona, 19 February 2026).
Riders: what the EU Directive provides
By Marcella de Trizio
AG has addressed the topic “Riders: what the EU Directive provides”, published on MementoPiù by Giuffrè Francis Lefebvre and authored by lawyer Marcella de Trizio.
Italy is required, by 2 December 2026, to transpose Directive (EU) 2024/2031 of 23 October 2024 on “improving working conditions in platform work”. The Directive is currently highly relevant and of topical interest in light of recent developments, including the imposition of judicial administration measures for alleged labour exploitation not only on Glovo but also on Deliveroo, as well as requests for documentation addressed to major companies such as McDonald’s, Burger King, Esselunga, Poke House, Crai, Carrefour and KFC.
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Equivalence of NCBAs: cannot be achieved through individual ‘superminimo’
By Marcella de Trizio
AG has addressed the topic “Equivalence of NCBAs: cannot be achieved through individual superminimo”, published on MementoPiù by Giuffrè Francis Lefebvre and authored by lawyer Marcella de Trizio.
With judgment no. 325 of 20 February 2026, the Regional Administrative Court of Emilia-Romagna (TAR Emilia-Romagna) held that the requirement of equivalence between the NCBA indicated by the contracting authority and that applied by the successful tenderer cannot be satisfied through the granting of individual personal salary (superminimo).
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Tax Control Framework (TCM) on an optional basis: organisational and contractual implications
By Daniela Ghislandi and Luca Barbieri
AG has addressed the topic “Tax Control Framework (TCM) on an optional basis: organisational and contractual implications”, published in Diritto & Pratica del Lavoro by Wolters Kluwer and authored by Daniela Ghislandi and Luca Barbieri.
With Measure no. 42022/2026, Agenzia delle Entrate issued “Provisions for the implementation of the optional regime for the adoption of a tax risk control system governed by art. 7-bis of Legislative Decree no. 128 of 5 August 2015”, approving the “Application form for the optional adoption of the tax risk control system”.
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Procurement contracts in the public sector: the principle of application of the NCBA and the assessment of equivalence
By Luca Barbieri and Luca Mariani
AG has addressed the topic “Procurement contracts in the public sector: the principle of application of the NCBA and the assessment of equivalence”, published in TEME and authored by Luca Barbieri and Luca Mariani.
Pending the issuance of the ministerial decree that will define the guidelines for certifying the equivalence of economic and regulatory protections – as well as for assessing any marginal deviations – in cases where a collective agreement different from that indicated by the contracting authority is applied, ANAC has approved “Standard Tender Document no. 1/2023”, as updated by Legislative Decree no. 209 of 31 December 2024.
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CONTRACTUAL DEADLINES
| 1 |
| PAPER – INDUSTRIAL COMPANIES
Salary guarantee element The agreement of 10 February 2026 for employees of the paper and cardboard industry has determined the payment of a salary guarantee element.
Additional payment for turn-based workers
The agreement of 10 February 2026 for employees of the paper and cardboard industry has confirmed the payment of an additional allowance for workers on turn-based shifts.
Additional payment for turn-based workers
The agreement of 10 February 2026 for employees of the paper and cardboard industry has determined for salary increases. |
| ELECTRICAL SECTOR |
| Minimum salaries
The NCBA of 11 February 2025 for employees of the electrical sector has determined for salary increases. |
| GRAPHICS AND PUBLISHING – INDUSTRY |
| Salary guarantee element
The NCBA of 19 December 2023 for employees of the graphics and publishing sector has determined the payment of a salary guarantee element. |
| METALWORKING INDUSTRY |
| Continuous training
The NCBA of 22 November 2025 for employees in the private metalworking industry provides for the payment of a contribution to the MetApprendo training fund.
Additional training following absences
The NCBA now provides that employees returning from a continuous period of absence following maternity, paternity or parental leave of at least 5 months, or at least 6 months in cases of illness, accident, extraordinary leave pursuant to Law no. 104/1992, extraordinary wage supplementation or transfer, are entitled to an additional 4 hours of training (in addition to the 24 hours already provided).
One-off contribution
The NCBA of 22 November 2025 for employees in the private metalworking industry also provides for the obligation to inform non-unionised employees of the payment of an associative contribution. |
| AUDIO-VIDEO PRODUCTION |
| Salary guarantee element
The NCBA of 14 April 2025 for employees of the audio-video production sector has determined the payment of a salary guarantee element. |
ADMINISTRATIVE DEADLINES
| 16 | 20 | 31 |
| 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, submit the 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 submitted electronically 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.
|
PREVINDAI fund
Employers of the industrial sector must pay contribution for executives enrolled under the Previndai fund |
Individual UNIEMENS data flow
Employers already required to submit the 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.
|
FASI fund contribution
Industrial companies employing executives must pay FASI fund contribution related to the first quarter of 2026. |
|
| 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 allocated to 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 | 31 |
| Procurement contracts
Contractors and subcontractors involved in contracts exceeding EUR 200,000 must submit the receipts of the withholding tax payments made on behalf of their employees for the previous month or, if exempted, a copy of the tax compliance certificate.
|
Subsidised furlough
Employers must submit data required for the payment or settlement of subsidised furlough in case of direct payment by INPS, for periods starting in the previous month. |
| CIGO subsidised furlough request for unavoidable events
Employers must submit CIGO furlough requests for objectively unavoidable events that happened in the previous month. |
|
| INAIL premium
Employers must submit an application, in 2027, for the application of the bonus scheme for the 2026 adjustment, provided that they are compliant with health and safety rules and with the payment of contributions and premiums. |
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| Commission
Principals who have engaged agents and representatives must send them the statement of commissions and the settlement relating to the commissions accrued in the previous quarter. |
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| Biennial report on workforce composition
Employers concerned must prepare and submit the biennial report on the situation of male and female employees using the dedicated online application made available by the Ministry by 30 April 2026. |
AGPill – Subcontracting agreement as an alternative to outsourcing
By Marcella de Trizio
In this episode of AGPill – “Subcontracting agreement as an alternative to outsourcing” – Marcella de Trizio, lawyer at ArlatiGhislandi, explores the topic.
Outsourcing represents an extremely efficient, attractive and secure solution for companies seeking to externalise services such as cleaning or IT services. However, it tends to be viewed with greater caution in the case of in-house outsourcing arrangements. In such cases, it may be appropriate to consider alternative contractual models, including subcontracting agreements.
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AGPill – Confirmatory referendum of 22-23 March: rules on electoral leave granted to employees
By Amedeo Mastromarino Horn
On 22 and 23 March 2026, Italian citizens were called to vote in a confirmatory referendum concerning the constitutional reform of the Italian judiciary system.
In light of the institutional relevance of the consultation – which concerns key aspects of the judicial system and the administration of justice – Amedeo Mastromarino Horn, Labour Consultant at ArlatiGhislandi, examines the protections afforded to employees who are required to perform duties at polling stations during voting and counting operations.
WATCH THE VIDEO
Nova of the Month – Review on labour law and human resources management
Thursday, 30 April 2026, from 14:30 to 15:00
Lorenzo Dani and Giorgio Ottaviano will present the main developments and topics relating to labour law and corporate organisation in light of legislative measures and practice guidelines concerning the management of human resources within companies.