Skip to content As of 7 June 2026, Legislative Decree No. 96 of 7 May 2026 is in force. The decree transposes EU Directive 2023/970 on pay transparency into Italian Law.
The decree introduces new obligations for employers and new rights for workers and candidates, with the aim of strenghtening the principle of equal pay for women and men for the same work or work of equal value.
Why it matters
The legislation aims to make the criteria used to determine pay and salary progression more transparent.
For companies, HR teams and managers, this means paying greater attention to the recruitment phase, the communication of pay-related information and the internal management of salary policies.
Main changes
1. Pay information at the recruitment stage
Employers must indicate in job advertisements and selection notices the initial pay or the relevant pay range for the position.
This information must be based on objective and gender-neutral criteria. The relevant provisions of the applicable collective bargaining agreement must also be indicated.
2. Ban on asking about previous pay
During the selection process, the employer or the person managing the recruitment process may not ask candidates for information on the pay received in current or previous employment relationships.
The aim is to prevent previous pay gaps from affecting the new salary offer.
3. More accessible pay criteria
During the employment relationship, employers with 50 or more employees must make available to workers the criteria used to determine pay, pay levels and salary progression.
These criteria must also be objective and gender-neutral.
4. Workers’ right to receive information
Workers may request, in writing, information on average pay levels, broken down by sex, for categories of workers performing the same work or work of equal value.
The employer must provide a response within two months of the request.
The request may also be submitted through workers’ representatives or equality bodies, subject to a specific authorisation. This right may be exercised once a year.
5. Reporting obligations for larger companies
Employers with at least 100 employees are subject to specific obligations to collect and periodically report data on the gender pay gap.
Deadlines and reporting frequency vary depending on company size.
Scope of application
The decree applies to employers in both the public and private sectors.
It concerns subordinate employment relationships, whether fixed-term or open-ended, including part-time employment and executive positions.
Domestic work and intermittent work are excluded.
What companies should do
Companies should check that job advertisements, recruitment procedures, pay criteria and salary progression systems are consistent with the new obligations.
For HR teams and managers, it is therefore important to adopt clear, documented and non-discriminatory criteria, so that they can transparently explain how pay is determined.
Also in global mobility processes, companies will need to pay attention to the consistency and transparency of remuneration packages, allowances and benefits.
How we can help
Arletti Partners supports companies in managing the HR, immigration, tax and labour aspects related to international assignments.
Discover our support service for foreign companies intending to hire staff in Italy and stay up to date on the latest Global Mobility developments on our website.