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Hiring Workers Trained Abroad: Italy’s Quota-Exempt Procedure Under Article 23

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Summary

Employers can hire eligible non-EU workers who have completed approved training programmes abroad through Italy’s quota-exempt procedure under Article 23 of the Consolidated Immigration Act. This guide explains the requirements, the LFE work authorisation application, the main procedural steps and the deadlines to monitor.

Introduction

Employers can hire non-EU workers trained abroad through a special entry route under Article 23 of Italy’s Consolidated Immigration Act (TUI). This route operates outside the entry quotas set by the Decreto Flussi.

However, only workers who complete an approved vocational and civic-language training programme qualify. Attending a general course abroad does not provide access to this procedure.

This guide explains the main requirements, the LFE application form and the steps that employers and workers must follow.

Who qualifies as a worker trained abroad under Article 23?

This route covers non-EU nationals who live abroad and complete an approved training programme under Article 23.

The programme must meet the relevant ministerial guidelines and hold formal approval. Therefore, a university degree or a general vocational course abroad does not, on its own, qualify a worker for this route.

These programmes prepare workers for jobs in Italy. They combine practical job skills with civic and language training.

In particular, the training covers:

  • Italian language skills.
  • Civic education.
  • The Italian labour market.
  • Workers’ rights and duties.
  • Health and safety at work.

Before starting the hiring process, employers should check that the candidate has completed an approved programme. Only then can they apply for work authorisation.

What are the benefits of quota-exempt entry?

The main benefit is access to an entry route outside the Decreto Flussi quotas.

As a result, employers do not need to wait for a click day. Instead, they can apply throughout the year, provided they meet the legal requirements and deadlines.

However, quota-exempt entry does not remove the other hiring duties. Employers must still submit an application through the Ministry of the Interior’s online portal. They must also prove that they meet the requirements for hiring a foreign worker.

The relevant authorities then check the application before granting work authorisation.

Employers must also obtain an asseverazione where the law requires one. This document confirms compliance with the relevant hiring requirements.

In addition, this route removes the need for a preliminary check with the local Employment Centre (Centro per l’Impiego — CPI). Employers do not need to check whether suitable workers are already available in Italy.

Requirements for employers and workers

Before applying, both the employer and the worker should check that they meet all the relevant requirements.

Worker requirements

The worker must:

  • Be a non-EU national living abroad.
  • Have completed an approved vocational and civic-language training programme under Article 23 within the previous 12 months.
  • Have a job offer that matches the training completed.

Employer requirements

The employer must:

  • Meet the legal requirements for hiring foreign workers.
  • Ensure that the worker has access to suitable accommodation.
  • Obtain an asseverazione where the law requires one.
  • Commit to paying the worker under the relevant national collective bargaining agreement (CCNL) and job level.

The documents needed may vary depending on the case. Moreover, the authorities may update their forms and filing rules.

For this reason, employers should check the current requirements before submitting an application.

How to apply using the LFE form

The employer or an authorised representative must apply online through the Ministry of the Interior’s services portal.

First, they must log in using SPID or an electronic identity card (CIE).

Next, they must open the section for the Single Desk for Immigration (Sportello Unico per l’Immigrazione — SUI). From there, they must choose the quota-exempt route for workers trained abroad and complete the LFE form.

The application requires details about:

  • The employer.
  • The worker.
  • The job offer and employment terms.

After submission, the portal issues a receipt with a registration number.

The Single Desk for Immigration and the other relevant authorities then review the application. They check the legal requirements before granting work authorisation.

What happens after the application?

After the employer submits the LFE form, the process follows these main steps:

  1. Application review. The Single Desk for Immigration checks the application and the supporting documents.
  2. Work authorisation. If the application meets the requirements, the authorities issue the nulla osta within 30 days of submission.
  3. Visa application. The worker applies for an entry visa at the relevant Italian embassy or consulate.
  4. Entry into Italy. The worker enters Italy within the visa’s validity period.
  5. Residence contract. The employer and worker complete the residence contract procedure through the Single Desk for Immigration.
  6. Employment notification. The employer submits the mandatory UNILAV employment notification.
  7. Residence permit. The worker applies for a residence permit for employment.

This route does not require a preliminary labour availability check with the Employment Centre.

In addition, work authorisation allows the worker to start work while awaiting signature of the residence contract. However, the employer must still meet the UNILAV notification requirements.

Timelines and deadlines to monitor

Employers and workers should track the deadlines from the date the training programme ends.

Work authorisation application

Employers can apply at any time of year because this route operates outside the annual quotas.

However, they must submit the application within 12 months of the worker completing the course.

Issue of work authorisation

The stated timeframe for issuing work authorisation is 30 days from submission.

However, requests for further documents may affect the processing time. Therefore, employers should monitor messages from the authorities and respond promptly.

Visa application

The worker must apply for a visa within 12 months of completing the training programme.

The extension from six to 12 months applies on a trial basis until 31 December 2027. After that date, employers and workers must check for any changes or extensions.

Entry into Italy

The worker must enter Italy before the visa expires.

Steps after entry

After entry, the employer and worker must complete the residence contract procedure.

The employer must also submit the UNILAV employment notification. The worker must apply for a residence permit for employment.

Common mistakes employers should avoid

Careful checks before submission can help prevent delays and reduce the risk of refusal.

In particular, employers should avoid these common mistakes:

  • Choosing an ineligible course. A general course abroad does not replace an approved Article 23 training programme.
  • Failing to check completion. Employers should confirm that the worker completed the programme and qualifies for this entry route.
  • Sending incomplete documents. Missing evidence about training, the job offer, accommodation or the asseverazione may delay the process.
  • Providing inconsistent details. The LFE form, job offer and supporting documents should contain matching information.
  • Missing requests from the authorities. Employers should check messages from the Single Desk for Immigration and reply promptly.
  • Using outdated guidance. Forms, filing rules and deadlines may change.

Before filing, check the worker’s personal details, duties, workplace and employment terms across all documents.

Also, keep copies of the application and supporting records so that you can respond quickly to any questions.

Need help hiring workers trained abroad?

Studio A&P can help your company assess eligibility and plan the next steps under Article 23.

Request a case assessment using our dedicated form, or book a consultation to discuss your case with an expert

Consultation on Hiring Workers Trained Abroad in Italy

Regulatory Framework

Authority Source Number Article Type Date Link
Italian Government Legislative Decree No. 286/1998 286 / Law 25/07/1998 Read more
Guidelines on Training Programmes Abroad under Article 23 – Directorate Decree No. 27 of 7 July 2023 27/2023 - Law 07/07/2023 Read more
Joint Circular No. 4518 of 10 August 2023 – Work Authorisation Applications by Temporary Employment Agencies 4518 - Practice 10/08/2023 Read more

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