The employer community is at the starting line for the implementation of Legislative Decree no. 96/2026 on pay equity, published in Gazzetta Ufficiale on 1 June. The new provisions will come into force on 7 June 2026 and will immediately affect all employers with regard to recruitment procedures and information obligations towards employees during the employment relationship.
More burdensome requirements, to be implemented progressively from next year onwards, will apply to employers with a headcount of at least 100 employees.
In order to promote pay equity, the legislation relies on pay transparency, a tool already familiar within the Italian legal framework.
One may legitimately ask whether such a tool will be adequate – and sufficient – to reduce the gender pay gap. In the author’s view, the measure may certainly contribute towards achieving this objective, although it should also be recognised that – in many cases – the pay gap is linked to factors other than gender discrimination and instead reflects a social and economic context in which roles traditionally performed by women are classified within the lower grades of collective bargaining classifications.
Given that the decree refers to collective bargaining agreements for the determination of fair remuneration, les jeux sont faits: little, if anything, is likely to change with regard to wage differentials between men and women.
It is therefore evident that, whilst the new provisions will undoubtedly contribute to reducing pay gaps resulting from discriminatory treatment, a genuine reduction of gender pay disparities as such will, in the author’s opinion, require a cultural shift. Such a shift should move away from the assumption that certain roles ought to be performed exclusively by women or – even worse – that certain roles should, as a matter of principle, be remunerated less than others.
Buona lettura,
Marcella De Trizio
Health and safety at work: training obligations for managers, supervisors and employees
Among the obligations that employers are required to fulfil in organising the company’s Prevention and Protection Service (Servizio di Prevenzione e Protezione – SPP), particular importance is attached to the duty to ensure that every employee receives sufficient and adequate training in occupational health and safety, including with regard to linguistic understanding, with specific reference to:
- the concepts of risk, damage, prevention, protection, organisation of workplace prevention measures, the rights and duties of the various workplace actors, and supervisory, inspection and assistance bodies,
- the risks associated with job duties, the possible resulting harm, and the corresponding prevention and protection measures and procedures specific to the sector or industry in which the employer operates (art. 37, para. 1 of Legislative Decree no. 81/2008).
The duration, minimum content and methods for delivering health and safety training are governed by a specific Agreement reached on 17 April 2025 within the Permanent Conference for Relations between the State, the Regions and the Autonomous Provinces of Trento and Bolzano.
Notably that Agreement – which became effective on 24 May 2025 – introduced significant changes regarding the identification of the duration and minimum content of occupational health and safety training programmes compared with the previous agreements. Specifically, with regard to training obligations concerning employees, managers and supervisors, it provides that the new provisions shall apply to training programmes commenced on or after 24 May 2026.
In light of this implementation date, the organisation of the employer’s Prevention and Protection Service (SPP) will necessarily need to be adapted to the new requirements.
This article examines:
i) the structure,
ii) the content; and
iii) the assessment procedures,
relating to training and periodic refresher courses in occupational health and safety for managers, supervisors and employees, also in light of the responses to specific questions provided by the Ministry of Labour and Social Policies and published on the Ministry’s institutional website on 27 March 2026.
The provisions governing training and periodic refresher obligations applicable to employers remain unaffected, including where the employer personally performs:
iv) the duties of the Head of the Prevention and Protection Service (Responsabile del Servizio di Prevenzione e Protezione – RSPP); or
v) work performed in confined spaces or environments suspected of contamination.
“Decreto Lavoro” Decree 1/3 – “Fair wages”, collective bargaining and remuneration monitoring
On 1 May 2026, Decree-Law no. 62/2026 containing “Urgent provisions concerning fair wages, employment incentives and the fight against digital labour exploitation” entered into force.
Given the broad scope of the matters governed by the decree under examination, the provisions contained therein have been analysed by grouping the legislative framework into homogeneous topics and subject areas.
This article, which constitutes the first of a three-part series, focuses on the new provisions contained in Chapter II of the above-mentioned decree concerning “fair wages”.
Unless otherwise specified, any reference shall be deemed to refer to the above-mentioned Decree-Law no. 62/2026.
“Decreto Lavoro” Decree 2/3 – New information obligations
Art. 11 of Decree-Law no. 62/2026, in force since 1 May 2026, introduces new information obligations, providing that:
a) among the information which, pursuant to art. 1, para. 1 of Legislative Decree no. 152/1997, the employer is required to communicate to the employee upon commencement of the employment relationship and, in any event, before the beginning of the working activity, by delivering either the individual employment agreement or, alternatively, a copy of the mandatory communication regarding the establishment of the employment relationship, there shall also be included the unique alphanumeric code assigned by the National Council for Economics and Labour (CNEL) to the applicable national collective bargaining agreement (NCBA) (art. 1, para. 1(q-bis) of Legislative Decree no. 152/1997),
b) the aforementioned alphanumeric code assigned by CNEL to the applicable NCBA shall also be expressly indicated by the employer in the payslip delivered upon payment of remuneration pursuant to art. 1(1) of Law no. 4/1953, which must state:
- the employee’s name, surname and professional qualification,
- the period to which the remuneration refers,
family allowances and all other elements forming part of remuneration, together with the individual deductions, separately shown;
c) the Ministry of Labour and Social Policies (MLPS), the National Labour Inspectorate (INL), INPS, CNEL and other competent bodies shall, within the scope of their respective powers, take into account the unique alphanumeric code assigned by CNEL to the applicable NCBA (and indicated by the employer in mandatory communications and social security reporting flows) in order to:
- monitor the actual application of national collective bargaining agreements; and
- carry out analyses concerning remuneration data, identifying any discrepancies in the economic and regulatory treatment applied across the various economic sectors.
The findings resulting from the monitoring activities are required to be used when planning inspection activities, analysing phenomena of contractual and remuneration dumping, as well as verifying the actual existence of the conditions and requirements for access to regulatory, contribution-related or economic benefits.
Art. 7(6) of the decree further provides that the identification code of the applicable NCBA must be expressly indicated among the data and information relating to the job position published by the employer within the Information System for Social and Employment Inclusion (SIISL), together with the remuneration connected to the qualification and contractual level corresponding to the duties assigned to the employee.
This obligation shall apply from the entry into force of the law converting the decree under examination, expected by 30 June 2026.
“Decreto Lavoro” Decree 3/3 – Incentives for the hiring of women, young people and workers in the ZES area
Chapter I of Decree-Law no. 62/2026, in force since 1 May 2026, introduces a series of measures aimed at promoting employment and fostering equal opportunities as well as work-life balance.
Following the introduction of these measures, art. 5 of the decree under examination repeals art. 14(1-bis) of Decree-Law no. 200/2025, converted into law, as amended, by Law no. 26/2026, pursuant to which the application period of the incentives already provided for the hiring of:
- young workers under 35 years of age,
- workers assigned to production units located within the Special Economic Zone (ZES) for Southern Italy,
had been extended from 31 December 2025 to 30 April 2026.
The above-mentioned provision also repeals the legislation in force until 30 April 2026 aimed at encouraging the recruitment, under open-ended employment contracts, of disadvantaged women workers.
As previously noted, this article, which constitutes the third and final part of the analysis of Decree-Law no. 62/2026, examines the employment incentive measures introduced by the decree, as well as the social security contribution relief available to employers that have obtained certification of a system designed to support parenthood and the reconciliation of work, personal and caring responsibilities.
Treasury Fund – New and extended deadline for the payment of TFR contribution
Art. 16 of Decree-Law no. 62/2026, in force since 1 May 2026, provides that employers falling within the scope of the obligation, as from 1 January 2026, to pay a monthly contribution to the Treasury Fund (Fondo di Tesoreria) equal to the amount of severance pay (TFR) not allocated by the employee to a supplementary pension fund (art. 1, para. 203 of Law no. 199/2025), may elect to make, by 16 July 2026, the payment to the Fund of the contributions due in respect of the period from January to June 2026.
In this regard, it should be noted that the obligation to pay the aforementioned TFR contribution applies to employers who, in 2025, employed on average at least 60 employees.
As clarified by INPS in circular message no. 12/2026, employers who, as at 31 December 2025, were not subject to the obligation to pay the contributions in question are required to apply for authorisation code “1R”, which identifies an “Employer employing workers in respect of whom contribution payments financing the Treasury Fund are due.”
As further confirmed by INPS in message no. 1511/2026, the payment of such contributions must be made using causation code “CF05” within the UniEmens reporting flow, corresponding to “Payment of arrears relating to TFR quotas pursuant to Law no. 199 of 30 December 2025.”
Furthermore, with regard to contribution periods commencing from July 2026, employers shall pay TFR contribution due on a monthly basis no later than the 16th day of the month following the payroll period to which the employee’s accrued TFR quota relates.
Equal pay and gender equality – Transparency principles
As from 7 June 2026, Legislative Decree no. 96/2026 entered into force. In order to strengthen the application of the principle of equal pay for men and women performing the same work or work of equal value, the decree implements the provisions of Directive (EU) 2023/970 and forms part of the broader anti-discrimination framework already in force within the legal system, consisting of:
- the principle of equal pay for male and female workers for the same work or work of equal value (art. 157 of the Treaty on the Functioning of the European Union (TFEU)),
- the prohibition of both direct and indirect discrimination based on sex concerning any aspect or condition of remuneration in relation to the same work or work to which equal value is attributed (art. 4, para. 1 of Directive 2006/54/EC, subsequently implemented into the Italian legal system by Legislative Decree no. 5/2010),
- the prohibition of pay discrimination introduced by art. 28 of Legislative Decree no. 198/2006 (Codice delle pari opportunità).
In compliance with the provisions of the above-mentioned Directive (EU) 2023/970, the new implementing decree introduces specific rights to information concerning pay transparency in favour of:
i) private-sector employees, including managerial employees, whilst excluding domestic workers and workers employed under on-call contracts; and
ii) job applicants.
The decree also establishes new disclosure obligations for employers, while explicitly referring to the provisions contained in Book III, Title I, Chapter III of Legislative Decree no. 198/2006 concerning:
i) judicial remedies; and
ii) the sanctions regime applicable where discrimination is found to have occurred in breach of the above-mentioned requirements.
The proper implementation of transparency obligations contained in the decree requires employers to undertake an analysis of the remuneration practices adopted within the undertaking, with a view to implementing pay structures based on the principle of equal pay for men and women performing the same work or work of equal value.
Supplementary pension schemes – Portability of the individual position from 31 October 2026
Following the conversion into law of Decree-Law no. 19/2026 by art. 1 of Law no. 50/2026, in force since 21 April 2026, the effective application of the most recent provisions concerning the portability of the individual position accrued by employees within a supplementary pension fund, introduced by art. 1, para. 201(c) of Law no. 199/2025, has been postponed from 1 July 2026 to 31 October 2026 (art. 29, para. 11-bis).
Accordingly, until 30 October 2026, art. 14, para. 6 of Legislative Decree no. 252/2005, currently in force, will continue to apply. This provision grants employees who have been members of a supplementary pension fund for at least two years the right to transfer their entire individual pension position to another pension fund. Such position is funded through:
- accrued TFR contributions,
- contribution paid by the employee and
- any contribution payable by the employer.
Until 30 October 2026, the exercise of this right to portability will remain subject to the limits and procedures established by the applicable collective bargaining agreement (NCBA, territorial collective agreement or company-level collective agreement) applied by the employer.
Work-related injuries and occupational diseases – Guidance on the management of medical certification
In light of the new procedures for the electronic transmission of medical certificates and the applicability of digital systems to medico-legal assessments, INAIL, through circular message no. 17/2026, has provided guidance concerning the management of medical certification relating to occupational accidents and occupational diseases.
Instalment payment of insurance premium liabilities – INAIL instructions
With circular message no. 19/2026, INAIL has shared initial instructions on the rules governing the instalment payment of liabilities relating to insurance premiums and ancillary charges not yet enrolled for enforced collection, as introduced by art. 2, para. 11-bis of Law no. 203/2024 (Collegato Lavoro).
Notably, the Institute specifies:
- the types of liabilities eligible for instalment payment,
- the procedures for submitting the relevant application, and
- the conditions that must be satisfied for the granting of an instalment arrangement.
ISTAT – Consumer Price Index for April 2026
Through its Press Release of 15 May 2026, ISTAT published the Consumer Price Index for blue- and white-collar households (FOI), excluding tobacco products, for the month of April 2026, which stands at 102.5 points.
This index is used to determine the revaluation coefficients applicable to severance pay (TFR) and employment-related claims.
JUS – The Case Law Review Journal
In this May issue of JUS, we have chosen to examine a series of administrative law judgments concerning the proper application of the principle of ‘pay equivalence’ under the current legislation governing public procurement contracts.
Our analysis begins with a significant judgment of Corte di Cassazione, which, however, is entirely consistent with the approach adopted by the administrative courts in recent years.
Pay equivalence also requires compliance with the contractual obligations imposed by the procurement contract, particularly with regard to the applicable NCBA.
The regulatory framework and the approach of the administrative courts.
Social contribution – late payment and reduction of penalties
The reduction of penalties due in respect of late payment of social security contributions does not apply automatically. Rather, it is conditional upon payment of the outstanding contributions within the deadline set by INPS, including in circumstances where there is uncertainty as to whether the contribution is actually due (Corte di Cassazione, 30 April 2026, no. 12155).
Multi-site employers – Limits on dismissals following the closure of a business unit
Where the disposal of a business unit of a multi-site employer is carried out, the employer may proceed with the dismissal of only those employees assigned to the discontinued business unit, provided that it can demonstrate the reasons why those employees could not be transferred to other nearby locations (Corte di Cassazione. 27 April 2026, no. 11380).
Communication of dismissal via ordinary email deemed lawful
An employer may validly communicate a dismissal to an employee by ordinary email. For the purposes of the validity of the dismissal, which constitutes a receptitious act, the essential requirement is compliance with the written form, whereas the means used to communicate the dismissal does not affect the validity of the act itself (Corte di Cassazione, 11 May 2026, no. 13731).
Health and safety training obligations: legal and organisational elements
By Luca Barbieri and Matteo Raglio
AG has addressed the topic “Health and safety training obligations: legal and organisational aspects” in a special supplement, authored by Luca Barbieri and Matteo Raglio and published in Diritto & Pratica del Lavoro by Wolters Kluwer, devoted to occupational health and safety training, which constitutes an essential organisational safeguard within the corporate prevention and protection system.
The article reviews employers’ training obligations in light of the State–Regions Agreement of 17 April 2025 which, with regard to the organisation of training for employees, managers and supervisors, will become fully applicable from 24 May 2026. The contribution highlights:
- the duration and content of the individual training and refresher programmes,
- the methods for assessing learning outcomes; and
- the related sanctions regime.
READ ARTICLE
Pay transparency: how recruitment practices are changing
By Marcella De Trizio
AG has addressed the topic “Pay transparency: how recruitment practices are changing” in an article authored by Marcella de Trizio and published in QuotidianoPiù by Giuffrè Francis Lefebvre.
With regard to pay transparency, the Legislative Decree implementing Directive (EU) 2023/970 requires employers to indicate either the starting salary or the relevant salary range in job advertisements, based on objective and gender-neutral criteria.
The decree also prohibits employers from requesting information concerning candidates’ salary history, thereby promoting gender equality and ensuring that remuneration negotiations are conducted on an informed basis from the pre-employment stage onwards, with the aim of helping to reduce the gender pay gap.
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‘Decreto Lavoro’ decree: the new regulatory framework for work performed through digital platforms
By Luca Barbieri
ArlatiGhislandi, through Luca Barbieri, contributed to an article in Corriere della Sera commenting on the Labour Decree and the new regulatory framework governing work performed through digital platforms.
Decree-Law no. 62/2026 organises and regulates employment relationships carried out through digital platforms and establishes communication and information obligations aimed at ensuring greater transparency and comprehensibility of the functioning of automated and algorithmic systems.
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AI and the UNI standard for unregulated professional activities
By Luca Barbieri and Andrea Rossetti
AG addressed the topic “Artificial Intelligence and the UNI standard on unregulated professional activities” in an article published by Il Sole 24 Ore, NT+, authored by Luca Barbieri and Andrea Rossetti.
On 30 April 2026, UNI Standard 11621-8, entitled Unregulated professional activities – ICT professional role profiles – Part 8: Professional role profiles relating to Artificial Intelligence (AI), was ratified by the President of the Italian Standardisation Body (Ente Italiano di Normazione).
The standard identifies twelve ICT (Information and Communications Technology) professional roles operating in the field of artificial intelligence and, for each of them, defines the scope of the professional activity. Consistently with the European Qualifications Framework (EQF) and the National Qualifications Framework (QNQ), it also sets out the essential requirements relating to:
i) competencies,
ii)skills and knowledge,
iii) autonomy, and
iv) responsability
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Corporate Welfare – The “mess” surrounding family members eligible for welfare benefits
In this article, through the analysis of a specific case study, we will examine a number of anomalies (and errors) identified in the provision of corporate welfare services through web-based platforms operated by third-party providers, with particular regard to the identification of the categories of beneficiaries entitled to access corporate welfare benefits pursuant to art. 51 of TUIR.
Contractual Deadlines
| 1 |
| INSURANCE – AGENCIES UNDER INDEPENDENT MANAGEMENT (ANAPA-UNAPASS)
Company productivity bonus Individual productivity bonus Expiry of the NCBA |
| METALWORKING INDUSTRY |
| Equalisation allowance The NCBA of 22 November 2025 for employees of the private metalworking industry and plant installation sector provides for the payment of an equalisation allowance where no second-level collective bargaining agreement concerning performance-related bonuses is in place, for employees whose remuneration consists exclusively of pay elements established by the NCBA.New minimum pay rates The NCBA of 22 November 2025 for employees of the private metalworking industry and plant installation sector provides for salary increases. One-off union contribution This contribution is to be deducted from the remuneration relating to the month of June of each of the above-mentioned years. Together with the April 2026 payslip, employers will distribute the relevant form enabling employees to accept or reject the trade union’s request, which must be returned to the employer by 15 May 2026. Collective welfare |
| METALWORKING – SMI (CONFAPI) |
| Equalisation allowance The NCBA of 24 July 2025 for employees of small and medium-sized metalworking and plant installation undertakings provides for the payment of an equalisation allowance to employees working in companies where no second-level collective bargaining agreement containing economic provisions is in place and who, during the previous year, received remuneration consisting exclusively of pay elements established by the NCBA.New minimum pay rates The NCBA of 24 July 2025 for employees in the small and medium-sized metalworking, jewellery and plant installation industries of Unionmeccanica-Confapi provides for salary increases. |
| ELECTRICITY |
| Equalisation allowance The NCBA of 11 February 2025 for employees of the electricity sector provides that employers not covered by a second-level collective bargaining agreement governing performance-related bonuses must pay an equalisation allowance to employees who do not receive other collective economic benefits comparable to such an arrangement. |
Administrative Deadlines
| 16 | 20 | 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, 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. |
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. |
||
| 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. |
||
| 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
| 23 | 29 | 30 |
| Service contracts Contractors and subcontractors involved in contracts exceeding EUR 200,000 must provide either:
|
Fiscal assistance Tax withholding agents must provide employees with a copy of the processed 2026 Form 730 tax return and the corresponding tax calculation statement in respect of returns submitted between 1 June and 20 June 2026. |
CIGO-CIG subsidised furlough Employers concerned must submit applications for Ordinary Wage Guarantee Fund (CIGO) benefits in respect of objectively unavoidable events occurring during the previous month.Employers must submit the data required for the payment or settlement of wage supplementation benefits where payment is made directly by INPS, in relation to the wage supplementation periods previously authorised. Annual leave |
Intelligent and predictive HR management
Thursday, 16 June 2026, from 17:00 to 18:30
ArlatiGhislandi is organising an event at Palazzo Chiesa dedicated to the application of artificial intelligence in the HR function, an area that remains largely unexplored from the perspective of predictive analytics and data modelling.
The event aims to demonstrate how predictive capabilities can support HR managers in their decision-making processes: from workforce cost management to the early identification of instability indicators, from workforce planning to strategic human resources decisions, through agentic systems capable of integrating heterogeneous data sources and generating advanced insights.
The event will be moderated by Alessia Cruciani, journalist at Corriere della Sera.