Employment and pensions
Italy | Gender Pay Transparency
Published on 3rd June 2026
In force from 7 June 2026, Legislative Decree no. 96/2026 applies to all employers, both public and private, with regard to employment relationships
Legislative Decree no. 96 of 7 May 2026, implementing Directive (EU) 2023/970, was published in Official Gazette no. 125 on 1 June 2026, and enters into force on 7 June 2026.
It applies to all employers, both public and private, with regard to employment relationships.
Immediately effective obligations (as of 7 June 2026)
- Pre-hiring transparency: all job postings must specify the starting salary or salary range and the applicable National Collective Bargaining Agreement. Asking candidates for information about their current or past salaries, even indirectly or through recruitment agencies, is prohibited.
- Transparency regarding salary criteria: the criteria for determining salary and salary progression must be made available to employees, generally by updating the information notice required under Legislative Decree 152/1997 or by referring to the applicable National Collective Bargaining Agreement. Employers with fewer than 50 employees are exempt (only) from the salary progression obligation.
- Employees’ right to information: employees may request, once a year, data on average pay levels broken down by gender within their category. The employer is required to respond to such request within two months. Contractual confidentiality clauses regarding pay are void.
- Information notice: employers must inform all employees annually of their right to receive such information and the procedures for exercising that right. It is advisable to act promptly.
Deferred obligations (reporting on the gender pay gap)
Applicable to employers with at least 100 employees, with deadlines staggered from 2027 to 2031 based on company size.
The technical details will be established by ministerial decrees.
In summary: what to do right away
- Update job postings (salary range + applicable National Collective Bargaining Agreement)
- Train the HR team and external recruiters on the prohibition against “pay history inquiries”
- Update the information notice required under Legislative Decree no. 152/1997
- Remove any salary confidentiality clauses from contracts
- Establish a channel and procedure to handle employee requests
- Inform employees of their right to receive the relevant information
