Skip to content With note protocol No. 4634 of 24 June 2026, the National Labour Inspectorate (INL) provided initial operational guidance on the methods for recovering credits under the Points-Based Licence, as provided for by Article 7 of Ministerial Decree No. 132/2024.
The main guidance issued by the INL is summarised below.
Composition of the Commission responsible for the credit recovery application
Article 7 of Ministerial Decree No. 132/2024 assigns the assessment of applications for the recovery of Points-based Licence credits, in the cases referred to in Article 27, paragraph 10, of Legislative Decree No. 81 of 9 April 2008, to a territorial Commission composed of representatives of the INL and INAIL. It is also specified that representatives of the Local Health Authorities (ASL) and the Territorial Workers’ Safety Representative (RLST) are invited to attend the meetings of the Commission.
Note protocol No. 4634 clarifies that, for the purpose of identifying the ASL representative, the Director of the competent Interregional Labour Directorate will request the territorially competent ASL, identified on the basis of the company’s registered office, to provide the name of an expert in occupational health and safety.
With regard to identifying the RLST, pending the INAIL database provided for by Article 51, paragraph 8-bis, the Commission will identify the RLST by contacting the competent Joint Body, namely the body indicated by the company in the application form for the recovery of credits.
Methods for recovering Points-based Licence credits
Pursuant to Article 7, paragraph 1, of Ministerial Decree No. 132/2024, “the recovery of up to 15 credits is subject to the assessment of the territorial Commission, taking into account the fulfilment of the training obligation in relation to occupational health and safety courses, by the persons responsible for at least one of the violations referred to in Annex I-bis to Legislative Decree No. 81 of 9 April 2008, as well as by the workers employed at the construction site or sites where the violation occurred, and the possible implementation of one or more investments in occupational health and safety as indicated in Article 5, paragraph 4, letter a)”.
Training in occupational health and safety
With note protocol No. 4634, the INL clarifies that the training required for the recovery of credits must be additional to the training already provided for by Legislative Decree No. 81/2008 and cannot be considered valid for the purposes of ordinary refresher training. The courses must be delivered by training providers identified by the State-Regions Agreement of 17 April 2025, excluding the employer, and may be held in person or via synchronous videoconference, unless the Commission considers that such method is incompatible with the training objectives.
The training courses must also meet specific requirements: a maximum of 30 participants for courses held in person or via synchronous videoconference; content consistent with the violations that led to the credit deduction; teachers meeting the requirements set out in the Interministerial Decree of 6 March 2013; and the issuance of a certificate including, among other elements, the wording “valid for credit recovery purposes”.
For the purposes of awarding credits, the course must end with a learning test, passed with at least 70% correct answers, and the participant must have attended at least 90% of the scheduled hours. For each hour of training, 0.25 credits are awarded, rounded down to the nearest whole number (e.g. 7 hours = 1.75 credits, rounded down to 1 credit).
Investments in occupational health and safety
The note also focuses in particular on safety investments, which must be financially and organisationally sustainable and consistent with the company’s structure and size. The Commission is required to assess them in relation to the company’s economic resources, their ability to reduce occupational accidents and diseases, and the type of violations established.
Useful investments include, for example, environmental detection systems, personal protective equipment or smart workwear, occupational health surveillance technologies, robotics and automation systems, drones for high-risk activities, and teaching methods based on virtual, augmented or mixed reality. Investments made with public funding are also considered valid.
For the purposes of awarding credits, the note provides for a scale based on the amount of the investment: 1 credit for investments between EUR 5,000 and EUR 25,000; 3 credits for investments between EUR 25,000.01 and EUR 50,000; and 6 credits for investments exceeding EUR 50,000.
Finally, with regard to the credit recovery application, the INL clarifies that the company or self-employed worker concerned must submit the credit recovery request using the form attached to the note and setting out the proposal relating to the deducted credits, for example in terms of training, investments and timing.
The application must be submitted electronically to the certified email address (PEC) of the territorial office of the Labour Inspectorate where the Commission is based, including through the relevant representative association.