Pay transparency
Pay transparency in Italy
Whether the Directive has been transposed here, under which act, and what it asks of an employer. The duty is the national law's, never the Directive's own date.
- Who it applies to
- Employers, through their own state's law, once it is in force.
- The dates
- The states had until 7 June 2026 to transpose it.
- The one thing to do
- Read the act below: it is Italy's law that binds you, not the Directive.
Where the state stands
Italy has communicated DECRETO LEGISLATIVO 7 maggio 2026, n. 96. to the Commission as transposing the Directive.
Dated 4 June 2026.
The register of communicated measures was read on 23 October 2026.
What the national act asks
Decreto legislativo 7 maggio 2026, n. 96 sets the first report per headcount band, and how often it comes back.
| Workers | First report | Then |
|---|---|---|
| 250 and above | 7 June 2027 | every year |
| 150 to 249 | 7 June 2027 | every three years |
| 100 to 149 | 7 June 2031 | every three years |
What it adds to the Directive
- The reporting article applies only to employers with at least 100 employees (Article 9(8)), so below that there is no Italian reporting duty at all rather than a voluntary one.
- An employer with a single group pay policy may report aggregated at national level where that represents the data more reliably (Article 9(3)).
- The Ministry of Labour collects the data; the employer does not publish it. Article 9(4) leaves the mechanism to ministerial decrees, due within ninety days of 7 June 2026. They may take the data from INPS, INAIL and the labour inspectorate, so what an employer sends is set by them.
Read from Normattiva, the Italian state's consolidated law portal on 18 October 2026. The source
What the Directive sets, whatever the state has done
Employers with 250 workers or more report from 7 June 2027, and every year after. Those with 150 to 249 workers report every three years from the same day. Those with 100 to 149 workers report from 7 June 2031.
Those days are the latest a national law may set. A directive binds the state, and the employer owes what its own state enacted.
The duties as a catalogue, read against this state
Every duty of the Directive, with the evidence each one asks for and Italy's own dates where the act is read.
Related:The pay transparency guideEvery register for ItalyThe duties, article by article