The note refers to Article 37(4) of Legislative Decree No. 81/2008. This provision requires employers to provide training when the employment relationship begins. For temporary agency workers, this requirement applies when they start their assignment with the user undertaking.
Removal of the 60-day reference
The INL recalls that the State–Regions Agreement of 17 April 2025 removed the previous provision on training deadlines. That provision allowed workers to complete training within 60 days of recruitment. Some employers had incorrectly interpreted it as permission to delay the start of training.
The clarification highlights the importance of planning. Employers should treat training as part of preparing workers for their duties. They should not wait until work has begun to organise it.
Remedying breaches and lifting the suspension
The note also updates INL Circular No. 3/2021. To have a suspension for undeclared work lifted, employers can meet the training-related requirement by scheduling courses for completion as soon as possible.
The compliance notice (verbale di prescrizione) must set a deadline based on the time technically necessary to attend the courses. Inspectors must no longer apply the previous 60-day period automatically.
Employers must therefore distinguish between two steps. Scheduling training can satisfy the training-related condition for lifting the suspension. To comply with the notice, however, workers must actually complete the training.
Practical implications for businesses
From an organisational perspective, checks on training should be included in the preparations for every work assignment. Before work begins, businesses should review the available documentation, identify any training needs and plan the necessary compliance measures in good time.
This approach is also useful when managing international projects and work at clients’ premises in Italy: a training certificate should be assessed against the duties and risks associated with the planned activities, without assuming that documents relating to other contexts are automatically sufficient.
For businesses involved in international mobility, the note serves as a reminder to incorporate checks on health and safety compliance into project planning.