Italy
Entry and employment of foreign workers
Impact date: 3 October 2025 Decree-Law No. 146/2025 updates the rules on the regular entry and employment of foreign workers. Main changes include:
- Permanent adoption of pre-filled work-permit applications and a limit of three applications per private employer
- Faster procedures, with deadlines starting when the application is allocated to the immigration quota (rather than from the date of submission)
- The right to work while waiting for the conversion of a residence permit
- Longer (12-month) residence permits for victims of trafficking, domestic violence or labor exploitation, who also gain access to the inclusion allowance
- Three-year planning of volunteer-program quotas (rather than annual)
Employer implications/action needed Employers should use the new pre-filled application system, monitor the three-application limit, ensure accurate declarations. Companies should also be aware that foreign workers may start working while waiting for permit conversions.
Employer risk Failure to comply with the required application forms and statutory limits may result in the rejection of work-permit applications.
Resignations during probationary period – Ministry of Labor clarification
Impact date: 13 October 2025 The Ministry of Labor, with the communication No. 14744/2025, has clarified that resignations submitted by pregnant employees or parents of children up to three years old must be formally validated by the Labor Inspectorate, even during the probationary period.
Employer implications/action needed Employers must ensure that resignations from protected parents - even during probation - are sent to the territorial Labor Inspectorate (ITL) for formal validation.
Employer risk Failure to validate the resignation may expose the employer to claims for back pay or unlawful dismissal, as well as actions by social-security and insurance authorities, whose contribution assessments rely on the existence of a valid employment relationship.
Trade union representation (case law)
Impact date: 30 October 2025 The Italian Constitutional Court, with judgment No. 156/2025, declared that the most representative national trade unions must be entitled to appoint company-level trade union representatives (the so-called “RSA”), even if they did not participate in negotiating or signing the collective agreement applied in the company. The previous rule limiting this right has been declared unconstitutional.
Employer implications/action needed Employers should recognize the RSAs established by representative national trade unions, and should update their internal union relations procedures accordingly.
Employer risk Failure to recognize such RSAs may result in claims of anti-union conduct.
Decree-Law No. 159/2025 - Workplace health and safety
Impact date: 31 October 2025. Please note that certain provisions will come into force from 1 January 2026 and 1 April 2026. Decree-Law No. 159/2025 introduces new health and safety provisions to strengthen working conditions. Below is a summary of the key updates introduced:
- Mandatory electronic ID cards for employees performing work under contracts or subcontracting on building sites or in other high-risk sectors, as detailed in a specific Ministerial Decree are to be issued by the end of the year. These cards must have a dedicated anti-counterfeiting code and be connected to the relevant national platform (the so-called “Sistema Informativo per l’Inclusione Sociale e Lavorativa” / “SIISL”)
- Recording of all safety training in the employee’s electronic employment file
- Based on risk assessment, work clothes that are classified as personal protective equipment (the so-called “Dispositivi di protezione individuale” / “DPI”) must be provided by the employer
- Medical check-ups that are required by current legislation or ordered by the competent doctor must be carried out during normal working time. The only exception concerns the pre-employment medical check-up (the so-called “visita medica preassuntiva”)
- A new type of medical check-up has been introduced for employees performing high-risk activities, to be carried out before or during their shift if there is reasonable reason to suspect they are under the influence of drugs or alcohol
- As of 1 January 2026, higher fines for construction companies without the required safety credit license (the so-called “patente a crediti”)
- As of 1 April 2026, mandatory publication of job vacancies on the SIISL platform for companies seeking hiring incentives
Employer implications/action needed Employers should ensure that:
- Mandatory electronic ID cards are issued
- Employee’s safety training is recorded
- DPI is properly maintained
- Medical-surveillance procedures are updated and
- Job vacancies are published on the SIISL platform
Employer risk Failure to comply to health and safety obligations may result in fines and severe sanctions, in some cases also in criminal charges for the employer.
Metalworking Industry NCBA – Renewal Agreement
Impact date: 22 November 2025, with specific measures entering into force between 2025 and 2028 On 22 November 2025, the NCBA for the Metalworking Industry was renewed. The new agreement will be valid from 22 November 2025 to 30 June 2028. The most significant provisions include:
- A gradual increase in the minimum monthly base salaries, totaling €205,32 over the next three years (i.e. 2026, 2027 and 2028)
- An increase of annual tax-free welfare benefits from €200 to €250
- New reasons for the use, extension and renewal of fixed-term contracts exceeding 12 months. However, from January 2027, these reasons are allowed only if the company has converted at least 20% of the fixed-term contracts that expired in the previous year to permanent contracts. Terminations during probationary periods, for just cause and resignation are excluded from the calculation
- From January 2026, agency employees assigned to the same user company for more than 48 months acquire the right to be hired on an open-ended basis by it
- Longer periods of higher-duty work required to obtain a promotion
- Extension of protected sick leave for employees with disabilities
- New paid leave for parents, unpaid leave for migrant workers, and additional paid leave hours for employees working in heavy shift-rotation systems (18+ weekly rotating shifts)
- For companies with more than 400 employees there is a new obligation to provide the Unitary Workplace Union Representative Body (“RSU”) with a semi-annual report on all direct service contracts performed within the production site
- Additional eight hours of training for the Workers’ Safety Representative (the so-called “RLS”) and greater involvement in accident analysis
- New annual company contribution of €1.50 for each employee to the “MetApprendo” association, to support the delivery of services relating to training planning and access to training rights
Employer implications/action needed Employers should be compliant to the new provisions.
Employer risk Failure to comply with the new NCBA may result in claims for damages brought by employees, as well as union actions for anti-union behavior.
Executives of the trade sector - Renewal of the “Dirigenti Commercio” NCBA
Impact date: 1 January 2026 On 5 November 2025, the National Collective Bargaining Agreement (“NCBA”) for executives of the Trade Sector was renewed. The new agreement will be valid from 1 January 2026 to 31 December 2028. The most significant provisions include:
- A gradual increase in the minimum monthly base salaries, totaling €800 over the next three years (i.e. 2026, 2027 and 2028)
- An annual corporate welfare benefits equal to €1,500 during the three-year period 2026–2028
- The contribution to the complementary pension Fund (the so-called “Fondo Mario Negri”) has been increased for both employers and employees
- The insurance coverage to the fund with insurance and welfare nature (the so-called “Associazione Antonio Pastore”), has been increased to €560 gross
- Measures to support active ageing, such as mentoring roles for executives close to retirement
- A contribution of €2,000 to the CFMT platform (the so-called “Piattaforma Welfare CFMT”) for each executive dismissed
Employer implications/action needed Employers must comply with the new provisions of the collective agreement concerning the terms and conditions for executives of the trade sector.
Employer risk Failure to comply with the new NCBA may result in claims for damages brought by executives, as well as union actions for anti-union behavior.
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