[Italy] EU Pay Transparency Directive implemented

Italy has become one of the first EU member states to implement the EU Pay Transparency Directive after Legislative Decree 96/2026 came into force on June 7, in accordance with the EU’s timetable, Employment Law Worldview reports.

The Decree applies to public and private sector employers. Some of its obligations vary based on business size.

Italy has reportedly kept close to the wording of the Directive and has not sought to “gold plate” the provisions. 

Its existing national collective bargaining agreement framework will also be central to the new pay transparency landscape, with such agreements providing a foundation for assessing key concepts such as “same work” and “work of equal value”. 

With the Decree now in force, Squire Patton Boggs advises Italian employers to take the following steps:

• Review and update job advertisements/job vacancy announcements to ensure they include the relevant salary/salary band information.

• Train Talent Acquisition Teams and managers with involvement in recruitment on the new requirements.

• Audit recruitment processes to ensure compliance, including that candidates are not asked about their remuneration at their current or previous employers.

• Ensure processes are in place to comply with individual employee information requests

• Assess current headcount levels to determine which pay gap reporting obligations apply and the relevant deadlines.

It is reportedly too soon to fully assess the practical impact of the new legislation. The official text has only recently been published, and Italy awaits further interpretative guidance and commentary on a few key aspects. 

Among the open issues are questions about how the rules will apply to agency workers and the practical extension of certain obligations.

Source: Employment Law Worldview

Italy has become one of the first EU member states to implement the EU Pay Transparency Directive after Legislative Decree 96/2026 came into force on June 7, in accordance with the EU’s timetable, Employment Law Worldview reports.

The Decree applies to public and private sector employers. Some of its obligations vary based on business size.

Italy has reportedly kept close to the wording of the Directive and has not sought to “gold plate” the provisions. 

Its existing national collective bargaining agreement framework will also be central to the new pay transparency landscape, with such agreements providing a foundation for assessing key concepts such as “same work” and “work of equal value”. 

With the Decree now in force, Squire Patton Boggs advises Italian employers to take the following steps:

• Review and update job advertisements/job vacancy announcements to ensure they include the relevant salary/salary band information.

• Train Talent Acquisition Teams and managers with involvement in recruitment on the new requirements.

• Audit recruitment processes to ensure compliance, including that candidates are not asked about their remuneration at their current or previous employers.

• Ensure processes are in place to comply with individual employee information requests

• Assess current headcount levels to determine which pay gap reporting obligations apply and the relevant deadlines.

It is reportedly too soon to fully assess the practical impact of the new legislation. The official text has only recently been published, and Italy awaits further interpretative guidance and commentary on a few key aspects. 

Among the open issues are questions about how the rules will apply to agency workers and the practical extension of certain obligations.

Source: Employment Law Worldview