In 2021, Spain was among the EU countries with the highest levels of labour market precariousness. Following the 2021 reform, the situation was completely reversed: it is sufficient to note that 40% of all new permanent contracts signed in the EU were signed in Spain.
This development was accompanied by a 61% increase in minimum wage between 2019 and 2024, which offset the severe wage devaluation brought about by previous policies.
These are the remarks of labour law scholar Antonio Baylos, Professor Emeritus at the University of Castilla-La Mancha, who also points out that increasing minimum wage did not harm the economic framework; on the contrary, it stimulated economic recovery and boosted wage bargaining in collective agreements. The EU Directive on adequate minimum wages has been welcomed as confirming this trend, which has also contributed to increasing collective bargaining coverage.
The reform focused on stabilising employment relationships by prioritising permanent contracts; strengthening labour and social rights; paying greater attention to the energy transition; and correcting, through fiscal measures, certain excessive imbalances caused by striking situations of profound social inequality, together with public policies aimed at stimulating and developing the productive economy.
Unfortunately, nothing comparable can be observed in Italy, where measures such as the EU Directive on minimum wages seem to have no impact on the labour market and where collective bargaining, upon renewal of collective agreements, manages to secure only minimal increases, with self-evident consequences for the Country’s economic growth.
Nor, from a regulatory standpoint, are there initiatives capable of unblocking the market: suffice it to note the lack of significant innovations in the budget law and, moreover, the uncertainty surrounding legislative interpretation on matters affecting the daily management of companies. To mention only the most recent examples, the interpretation of de facto resignations – which, within a matter of months, owing to both case law developments and ministerial interpretations, has cast doubt even on what should be a clear and straightforward statutory provision.
These topics will be explored in greater depth in our newsletter, with careful analysis of the related case law aspects, alongside the usual compliance calendar and regulatory updates of the month.
Buona lettura,
Marcella De Trizio
Obligation for company directors to communicate their certified email address (PEC) – Regulatory developments
By Decree-Law No. 159/2025, published in the Gazzetta Ufficiale issue no. 254 of 31 October 2025 and entering into force on the same date, the Government introduced a series of legislative amendments which, despite what might be suggested by the title of the measure (“Urgent provisions for the protection of health and safety in the workplace and in matters of civil protection”), affect the obligation for company directors to notify their certified email address (PEC), as provided for by art. 1(860) of Law No. 207/2024, thereby shedding light on certain contentious interpretative issues of this requirement.
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Protection of health and safety at work – New measures
By Decree-Law No. 159/2025, published in the Gazzetta Ufficiale of 31 October 2025, No. 254, provisions have been introduced aimed at strengthening the measures already laid down by Legislative Decree No. 81/2008 for the protection of workers’ health and safety.
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Instalment plan for the payment of social contribution debts: ministerial decree published in the Gazzetta Ufficiale
Ministerial Decree 24 October 2025, by which the Ministry of Labour implements the provision set by art. 23 of Law No. 203/2024 concerning the instalment plan for the payment of social contribution debts, has been published in the Gazzetta Ufficiale.
Specifically, the decree provides that, where the employer is in a declared temporary situation of objective difficulty in paying contributions, INPS and INAIL may allow the deferred payment of social security and welfare debts in up to 60 monthly instalments.
The requirements, criteria and procedures for accessing the instalment plan shall be defined by a specific measure to be adopted by the boards of directors of each Institute by 29 January 2026.
ATECO Classification: INPS publishes the Operating Manual
With message No. 3206/2025, INPS announced the publication of the new “ATECO 2025” Economic Activity Classification Manual.
Notably, INPS also reports the release of the ATECO–CSC–CA compatibility consultation tool, which enables users, on the basis of the social security contribution statistical codes (CSC) assigned in relation to the economic activity performed (ATECO code), to more easily identify the contribution details that may be associated with the specific ATECO–CSC pairing, as well as their periods of validity.
New “Mothers’ Bonus”: INPS instructions
With circular message no. 139/2025, INPS has provided operational guidance for accessing the income-supplement allowance of EUR 40 per month for each month (or fraction thereof) in which the employment relationship is in force during 2025. The measure, introduced for 2025 by art. 6(2) of Decree-Law No. 95/2025, is granted i) to working mothers with two children until the second child reaches the age of ten, or ii) to working mothers with three or more children until the youngest child reaches the age of eighteen, provided that they are not employed under a permanent employment contract.
The allowance is paid directly by INPS following submission of a specific application by the worker concerned. Therefore, the employer does not intervene in the disbursement of the benefit.
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“Inpatriate” workers regime – additional clarifications from the Italian Revenue Agency
Answering queries no. 263 and 264 of 13 October 2025, the Italian Revenue Agency (Agenzia delle Entrate) clarified on the applicability of the special tax regime for “inbound workers” (art. 5 of Legislative Decree No. 209/2023) in two distinct scenarios involving the transfer of tax residence to Italy (art. 2 of Presidential Decree No. 917/1986):
- where the worker transfers tax residence to Italy in order to perform an employed work activity for a company that is neither associated with nor owned by the company for which the worker has been employed abroad in the preceding three-year period, while maintaining a pre-existing collaboration with an Italian university,
- where the worker moves to Italy to perform an employed work activity while continuing, at the same time, to perform work for an international financial institution that does not belong to the institutions or bodies of the European Union and has its registered office in a non-EU country.
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Taxation of stock options received by a former “inpatriate” employee
In its answer to query no. 274/2025, the Italian Tax Authorities provided further clarification on the inbound workers regime, stating that income deriving from equity incentive plans which vest during the period in which the worker benefits from the regime in Italy, but which are received after the worker has moved back abroad, are taxable in Italy under ordinary rules, with no possibility of applying the special tax regime. This interpretation is based on the principle that the applicable tax treatment is determined at the time the income is actually received, regardless of when the rights matured.
Company cars used for both business and private purposes – benefit valuation after the latest rulings of the Italian Tax Authorities: transitional regime, treatment of optional equipment and electricity recharging
As of 1 January 2025, significant changes have been introduced to the criteria for determining the fringe benefit value of a company car granted to an employee for mixed business and private use. The taxable value is now graduated according to the vehicle’s type of power supply. These legislative amendments initially required an additional statutory intervention, which subsequently introduced a transitional regime.
In the months that followed, the Italian Revenue Agency issued several interpretative documents on the application of the new rules. While these clarifications have in part helped shed light on the correct valuation method, they have also raised several legal and administrative concerns.
This briefing provides an overview of the current legislation governing the valuation and taxation of company-car fringe benefits, highlighting the practical and operational issues stemming from the Tax Authorities’ interpretative stance, including the treatment of optional equipment, electric charging, and the implications of the transitional regime.
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Paternity leave for the intended parent – INPS clarifications
With message no. 3322/2025, INPS clarified on the use of mandatory paternity leave by a female worker who is the intended parent in a same-sex couple composed of two women who are both recorded as parents in the civil status registers. INPS states that any instances of mandatory paternity leave taken before 24 July 2025 – the date on which Corte Costituzional judgment no. 115/2025 (which recognised the right to such leave) was published in the Gazzetta Ufficiale -cannot be regarded as undue.
Validation of resignation and probationary period – ministerial clarifications
By means of note No. 14744/2025, the Ministry of Labour and Social Policies clarified that the requirement for the Territorial Labour Inspectorate (ITL) to validate the resignations submitted by a pregnant worker, or by working parents within the first three years of the child’s life (art. 55, para. 4 of Legislative Decree No. 151/2001), also applies where the termination of the employment relationship occurs during the probationary period.
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Exemption from social contribution duties for new companies established through aggregation processes – INPS guidelines
With message No. 3344/2025, INPS has provided operational instructions for the fruition of the incentive addressed to new companies established through aggregation processes deriving from one or more corporate transactions, namely mergers, transfers, contributions, acquisitions of undertakings or of their branches, bringing the employer to a headcount equal to or exceeding 1,000 employees. The incentive, granted in the form of an exemption from social security contribution duties, is subject to the condition that the company has entered into, at governmental level, an agreement with the trade unions concerning an industrial plan aimed at the requalification of the workers involved and at managing the processes of occupational transition. The exemption applies to each worker up to a maximum of 100 per cent of the social security and welfare contributions payable by the employer, excluding the premiums and contributions due to INAIL, for a maximum period of 24 months, within an annual limit of EUR 3,500 per worker.
Bilateral Solidarity Fund for the TLC Supply Chain – adjustment of the supplementary benefit
Through message no. 3409/2025, INPS has provided guidance regarding the payment, by way of adjustment, of the supplementary benefit related to extraordinary and ordinary subsidised furlough schemes (CIGS and CIGO), as well as of the wage supplementation allowance (AIS) paid by the Bilateral Solidarity Fund for the telecommunications supply chain. The Institute informs that the amount of the adjustable total is indicated in the Social Security File of the Contributor by following the path ‘Dati complementari/Cruscotto CIG e Fondi’. UniEmens data flows already transmitted by the employer for the payment of the main benefit paid by the aforementioned Fund are also used for calculating the supplementary benefit.
Exemption from social contribution duties for solidarity agreements – INPS instructions for the recovery of 2024 funds
With circular message no. 143/2025, INPS provided operational instructions concerning the procedures for recovering contribution reductions, drawing on the resources allocated for 2024, for undertakings that enter into or currently have in place defensive solidarity agreements accompanied by CIGS. This contribution reduction must be applied to the contributions paid for each employee affected by the reduction in working time, as established by the solidarity agreement itself. For each month, the employer is entitled to a 35 per cent reduction on the portion of contributions payable by them for each employee who, in that month, has a working time reduced by more than 2 per cent compared with the level established in the agreement.
ISTAT – Consumer price index for October 2025
In a press release dated 17 November 2025, ISTAT announced the consumer price index for blue- and white-collar worker households (FOI) for the month of October 2025, amounting to 121.4 points. Revaluation coefficients for TFR and employment-related credits are calculated based on this index.
Telecommunications supply chain solidarity fund – INPS instructions on the extraordinary allowance
With circular message No. 144/2025, INPS has provided instructions regarding access to the extraordinary allowance granted within the framework of worker exit processes through the Bilateral Solidarity Fund for the telecommunications supply chain. Access to extraordinary benefits is subject to the signing of a company- or group-level collective agreement entered into with company trade union representatives or with the unified trade union representation body expressing the trade unions that are comparatively most representative at national level.
Leave of absence for elective public offices and trade union positions – Clarifications on the recognition of figurative pension contribution
With message No. 3505/2025, INPS has provided clarification regarding the recognition of figurative contributions in favour of workers placed on leave of absence as a result of being called to hold elective public functions or trade union positions. The Institute specifies that, for the purposes of recognising such contributions, it is necessary that the elective or trade union position be conferred on the worker by means of a written act or formal appointment.
JUS – The Case Law Review Journal
In this November issue of JUS, we shall examine four first-instance and Supreme Court decisions that we have considered relevant for employers, particularly from a managerial and operational perspective.
- Replacement of striking workers: profiles of lawfulness
- Certification of the severity of the medical condition for the purposes of exceeding the protected period must be provided through appropriate means
- No entitlement to remote working where incompatible with business needs
- Change of NCBA through harmonisation agreed with trade unions and workers: inadmissibility
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Resignation through conclusive conduct – clarifications from case law
With regard to a case concerning the termination of an employment relationship, in judgment No. 4953 of 29 October 2025, the Court of Milan addressed the legal mechanism of resignation through conclusive conduct introduced by art. 19 of Law No. 203/2024, providing a judicial interpretation – preferable to that put forward by the Ministry of Labour – on the correct application of the institution..
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Pay equity and pay transparency: an overview of case law
by Marcella De Trizio
AG has addressed the topic ‘Pay equity and pay transparency: an overview of case law’, published in MementoPiù – Expert Solution Lavoro, issued by Giuffrè Francis Lefebvre and authored by lawyer Marcella de Trizio. The principle of pay equity between men and women has been provided for by a national and international body of legislation for several years now. On the basis of such legislation, significant case law has also developed, much of which has been incorporated into EU Directive 2023/970, to be transposed in Italy by 7 June 2026. In view of that date, it is useful to take stock of the judicial approaches, particularly with regard to the notions of remuneration and remuneration of equal value.
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Retaliation against whistleblowers: compensation for non-pecuniary damages awarded
by Marcella De Trizio
AG has addressed the topic ‘Retaliation against whistleblowers: compensation for non-pecuniary damages awarded’, published in QuotidianoPiù, issued by Giuffrè Francis Lefebvre and authored by lawyer Marcella de Trizio. The Bergamo Court, in judgment No. 4306 of 6 November 2025, in a case brought by a whistleblower, focused on the compensatory aspects arising from unlawful employer conduct amounting to demotion and impairment of the claimant’s moral integrity.
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Classification and incentives for ‘project-based’ managers: the Bill under review
by Marcella de Trizio
AG has addressed the topic ‘Framing and incentives for “project-based” managers: the Bill under review’, published in QuotidianoPiù, issued by Lefebvre Giuffrè and authored by lawyer Marcella de Trizio. For SMEs, the management of critical phases, transformation processes or dedicated development projects is rarely entrusted to external managers. A Bill currently under discussion aims to encourage this approach by introducing tax incentives for the engagement of so-called ‘temporary managers’.
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Human oversight of a high-risk AI system: organisational aspects and regulatory framework
by Luca Barbieri
AG has addressed the topic ‘Human oversight of a high-risk AI system: organisational aspects and regulatory framework’, published in Diritto & Pratica del Lavoro, issued by Wolters Kluwer and authored by Luca Barbieri. According to the principles formulated by the independent expert group on artificial intelligence, established by the European Commission in June 2018, reliability constitutes an essential requirement for any artificial intelligence system. Such reliability is based on four key principles: respect for human autonomy, the prevention of harm, fairness, and the system’s ability to be explained and understood.
Diritto & Pratica del Lavoro, issued by Wolters KluwerREAD
Faculty to redeem periods not covered by compulsory pension contribution through employer financing
In this article, we shall examine the elements that legitimise the methods and time limits for exercising the faculty to redeem periods not covered by compulsory social security pension contribution in cases where the employer pays the related cost, using the amount that would otherwise have been paid to the worker as a ‘production bonus’, as well as the features and distinctive elements compared with the faculty to redeem periods corresponding to the duration of university studies for pension contribution purposes.
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Contractual Deadlines
| 1 |
| CHEMICAL INDUSTRY
Minimum salary and IPO salary item |
| SOCIAL COOPERATIVES |
| Expiration of NCBA
The NCBA of 26 January 2024 for employees of cooperatives in the social – healthcare – care – educational sectors expires on 31 December 2025. |
| HOTEL EXECUTIVES |
| Expiration of NCBA
The NCBA of 28 November 2023 for executives of hotel companies expires on 31 December 2025. |
| ROAD HAULAGE – EXECUTIVES |
| The NCBA of 18 May 2023 for executives of hotel companies expires on 31 December 2025. |
| HOTEL CHAINS – EXECUTIVES |
| Expiration of NCBA
The NCBA of 12 September 2023 for executives of hotel chains expires on 31 December 2025. |
| BUILDING SECTOR – INDUSTRIAL AND COOPERATIVE COMPANIES |
| Health surveillance
The agreement of 21 February 2025 launches an annual pilot project on health surveillance, running from 1 January 2025 to 31 December 2025, with the aim of strengthening the system for preventing occupational diseases and accidents for manual workers, as well as relaunching the performance of health surveillance in construction sites. |
| ELECTRICITY |
| Pension fund
The NCBA of 11 February 2025 for workers employed in the electricity sector has provided, for specific categories of uncovered workers, the payment directly to the Pension Funds operating in the sector, with effect from the completion of the first year of service and for each year of seniority, of an amount by way of a periodic measure supporting the supplementary pension system. |
| ENERGY AND PETROL |
| Minimum salaries
With reference to the NCBA of 16 April 2025 for employees in the research, extraction, refining, cogeneration, processing or distribution of petroleum products (excluding the research, extraction, etc. of asphalt and bituminous rocks) and for employees in the ENI energy sector, on 10 July 2025 CONFINDUSTRIA ENERGIA and FILCTEM–CGIL, FEMCA–CISL, UILTEC–UIL signed the Memorandum of Agreement setting out new amounts, adjusted in line with the inflation differentials for the 2022–2024 three-year period. |
| RUBBER AND PLASTICS – INDUSTRY |
| Expiration of NCBA
The NCBA of 26 January 2023 for employees of the rubber and plastics sector expires on 31 December 2025. |
| METALWORKERS – INDUSTRIAL COMPANIES |
| Monthly salary element
The NCBA of 5 February 2021 for employees of private metalworking industries and plant installation companies provided, for those employed as at 31 December 2008 and with the remuneration for the month of December, for the granting of an annual payment corresponding to 11 hours and 10 minutes by way of a non-absorbable individual annual element of monthly remuneration. |
| PENS AND BRUSHES – INDUSTRIAL COMPANIES |
| Salary equalisation element
The NCBA of 3 May 2023 for employees of companies manufacturing pens, pencils, pencil and pen parts and related articles, as well as for employees of companies producing brushes, paintbrushes, brooms and processors of the relevant raw materials, provided that, in the absence of company-level collective bargaining, the equalisation element shall be granted.
Expiration of NCBA
The NCBA of 3 May 2023 for employees of the pens and brushes industrial sector expires on 31 December 2025. |
| AGIDAE – CARE SERVICES |
| Expiration of NCBA
The NCBA of 12 March 2023 for employees of the care sector (AGIDAE) expires on 31 December 2025. |
| ANASTE-CONFSAL – CARE SERVICES |
| Expiration of NCBA
The NCBA of 23 July 2025 for employees of the care sector (ANASTE-CONFSAL) expires on 31 December 2025. |
| ANFFAS – CARE SERVICES |
| Expiration of NCBA
The NCBA of 20 May 2024 for employees of the care sector (ANFFAS) expires on 31 December 2025. |
| UNEBA – CARE SERVICES |
| Expiration of NCBA
The NCBA of 24 January 2025 for employees of the care sector (UNEBA) expires on 31 December 2025. |
| ANPIT – PROFESSIONAL FIRMS |
| Expiration of NCBA
The NCBA of 17 January 2023 for employees of professional firms (ANPIT) expires on 31 December 2025.
Collective welfare
The NCBA of 17 January 2023 for employees of professional firms and insurance agencies confirmed the payment to workers, by 31 December of each year, of contractual welfare benefits in the amounts indicated in the NCBA. |
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.
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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.
|
Year-end tax adjustment
By the end of the year, or upon termination of the employment relationship, or at the latest by 28 February 2026, the Employer (as withholding agent pursuant to art. 64, paragraph 1, of Presidential Decree No. 600/1973) must carry out the tax adjustment in accordance with the rules set out in paragraphs 3 and 4 of art. 23 of Presidential Decree No. 600/1973. Accordingly, for each worker, it will be necessary to perform the adjustment between the amount of withholdings applied to the sums and values paid for each pay period and the tax due on the total amount of sums and values paid during the year.
|
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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 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 Deadline
| 16 | 20 | 30 |
| TFR tax
Tax withholding agents must pay the advance (90%) on the 17% substitute tax on TFR revaluation for 2025.
|
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. |
AGPill – New protection for employees with oncological, disabling and chronic diseases
By Giovanna Caivano
The new pill of Labour Consultancy is dedicated to “New protection for employees with oncological, disabling and chronic diseases” by Giovanna Caivano – Team Manager for International Projects With Law no. 106/2025, the protection of workers affected by cancer is strengthened: up to 24 months of unpaid leave with job retention, and, starting January 1, 2026, 10 hours of paid leave per year for medical visits and treatments. A step forward in balancing health and work.
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AGPill – The path of TFR towards supplementary pension schemes – Rethinking and planning the future through financial planning
Edited by Gianluca Primavera and Luca Mariani
November was the month of financial education and, in this new episode of AGPill, ‘The path of TFR towards supplementary pension schemes – Rethinking and planning the future through financial planning’, Gianluca Primavera, ESG & Finance Partner at ArlatiGhislandi, and Luca Mariani, Labour Consultant at ArlatiGhislandi, examine the topic of TFR and supplementary pension schemes, illustrating the different ways of managing one’s TFR within pension funds and the related allocation opportunities.
WATCH VIDEO
Webinar – The Employer’s Christmas: taxation, welfare and payroll management
Thursday, 11 December 2025 – from 14:30 to 15:00
During the webinar, Giorgio Ottaviano and Amedeo Mastromarino Horn will examine the obligations incumbent on employers as the end of the year approaches, with particular focus on the methods for carrying out the year-end adjustment. They will also analyse the charges and obligations of employers concerning the proper management of employment-related institutions which, although producing effects throughout the entire tax period, require careful assessments when processing the final monthly remuneration of the year.
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Webinar – Nova of the Month – Review on labour law and human resources management
Thursday, 18 December 2025, 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.