Italy completed transposition of Directive (EU) 2023/970 through Legislative Decree No. 96 of 7 May 2026. The decree was published in the Italian Official Gazette on 1 June 2026 and entered into force on 7 June 2026, the EU transposition deadline. The measure is therefore the primary national legal text for Italian implementation. Employers operating in Italy should now base compliance work on the enacted decree, including its national treatment of recruitment transparency, pay structures, worker information rights, reporting, remedies, enforcement and monitoring, rather than relying only on the wording of the Directive.
Jurisdiction: Italy
Italy Completed Transposition on Time
Italy adopted Legislative Decree No. 96 of 7 May 2026 to implement Directive (EU) 2023/970. The decree was published in the Gazzetta Ufficiale on 1 June 2026 and entered into force on 7 June 2026. This means Italy reached the Directive's transposition deadline with a national measure already in force. For compliance purposes, the Italian decree is now the central source to consult because it translates the EU framework into the national legal system and determines how the Directive operates alongside existing Italian employment and equality law.
The Decree Covers Pay Transparency as a National Legal Framework
The decree implements the Directive's core architecture around equal pay for the same work or work of equal value, recruitment transparency, access to pay information, reporting and enforcement. Employers should therefore update processes across HR, compensation, payroll, recruitment and legal functions rather than treating implementation as a single annual reporting exercise. The national text should be used to identify which obligations apply immediately, which reporting duties follow the Directive's timetable and what procedural rules govern worker requests, consultation, remedies and sanctions in Italy.
Recruitment Processes Need to Follow the Italian Decree
The Directive's pre-employment rules require pay transparency before hiring and prohibit reliance on applicants' pay history. Italy's implementing decree gives those principles national legal effect. Employers should review vacancy templates, recruiter scripts, offer processes and manager training so that salary-range information is provided in the required manner and salary-history questions are removed from formal and informal recruitment practices. Multinational employers should not assume that a group-wide recruitment policy automatically satisfies the Italian decree without checking the national wording and any subsequent official guidance.
Pay Structures and Worker Information Rights Need Operational Controls
The Italian framework now requires employers to support equal-pay comparisons through transparent pay structures and to respond to worker information rights created by the Directive. That makes job architecture, pay-setting criteria, job evaluation and data access central compliance issues. Employers should identify which teams hold the data required for individual and category-level information requests, how average pay levels will be calculated and how responses will be documented. A policy on paper is not enough if HR and payroll systems cannot reproduce the requested information accurately and within the required timeframe.
Reporting Obligations Should Be Planned Against the Enacted Text
Article 9 of the Directive sets the EU reporting timetable by employer size, but Italian employers should now verify the national decree and any subsequent technical instructions for the exact filing process, methodology and competent authorities. Employers with at least 150 workers face the first EU-level reporting date in 2027, while employers with 100 to 149 workers follow in 2031 unless national law imposes broader obligations. Data architecture should therefore be prepared in advance, including basic pay, complementary or variable components, worker categories, sex-disaggregated metrics and audit trails for the calculations used.
National Guidance and Enforcement Practice Are the Next Update Layer
Enactment is not the end of implementation. Employers should monitor guidance from the Ministry of Labour, labour inspectorate practice, equality-body materials, any implementing regulations and early case law. Those sources may clarify calculation methodology, documentation standards, enforcement priorities and procedural details that are not obvious from the statutory text alone. Compliance teams should therefore treat the decree as the legal baseline and maintain a review process for subsequent national guidance rather than freezing policies at the date of enactment.
Frequently Asked Questions
Has Italy transposed the EU Pay Transparency Directive?
Yes. Italy transposed Directive (EU) 2023/970 through Legislative Decree No. 96 of 7 May 2026, which entered into force on 7 June 2026.
What is the main Italian implementing law?
The key national measure is Decreto Legislativo 7 maggio 2026, n. 96, published in the Gazzetta Ufficiale on 1 June 2026.
Should Italian employers rely on the Directive or the national decree?
The Directive remains the EU framework, but employers should implement obligations using the enacted Italian decree and later national guidance because those sources govern how the rules operate in Italy.
Related Guides
Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.