Law No. 112 of 25 June 2026, published in the Official Gazette No. 147 of 27 June 2026, converted into law, with amendments, Decree-Law No. 62 of 30 April 2026, containing urgent provisions on fair pay, employment incentives and the prevention of digital exploitation of labour.
The main changes introduced with respect to the original text of the Decree are set out below.
As regards fair pay, new paragraph 4-bis has been inserted into Article 7, defining the overall remuneration relevant for the purposes of fair pay. It consists of all fixed and recurring pay components, whether direct, indirect or deferred, established by national collective labour agreements, including additional monthly instalments and fixed and recurring allowances, as well as contractual welfare benefits granted to all employees and any other items or allowances having economic value established by the same collective agreements. Discretionary and variable pay components attributed to individual workers are in any case excluded, so that individual, non-structural above-minimum pay (superminimi) remains outside the calculation.
As regards the renewal of national collective labour agreements, the first three paragraphs of Article 10 have been rewritten. Where a collective agreement is not renewed within the first nine months following its natural expiry (rather than twelve months, as originally provided), in the absence of different contractual arrangements, pay is adjusted, as a lump-sum advance, in line with the variation of the consumer price index net of imported energy products (IPCA-NEI), to the extent of 50 per cent of that variation (in place of the 30 per cent of the IPCA previously provided for). For sectors characterised by high seasonality and revenue variability, identified pursuant to Presidential Decree No. 1525 of 7 October 1963, as well as for providers of healthcare and social-healthcare services on behalf of and at the expense of the National Health Service, the extent of the adjustment is determined by collective bargaining on the basis of sector-specific economic indicators, and may not in any case exceed 50 per cent.
The conversion law introduced new Article 7-bis, which amends Article 8 of Decree-Law No. 138 of 13 August 2011, concerning proximity collective bargaining. Collective agreements and specific company-level or territorial agreements must be filed with the General Directorate for Labour Relations and Industrial Relations of the Ministry of Labour and with the national archive of collective labour agreements held by the CNEL. For employers with up to fifteen employees, specific company-level agreements that derogate from statutory provisions or from national collective agreements, where they provide for less favourable treatment, must be signed at the territorially competent Labour Inspectorate office, with the employer being required to inform the workers concerned, in writing, within three days of signature.
New Article 4-bis introduces a duration limit for extracurricular internships: the maximum overall duration may not exceed twelve months per group of companies, without prejudice to any further limits provided for under current legislation.
With regard to work through digital platforms, paragraphs 2 and 3 of Article 12 have been amended, confirming that the classification of the employment relationship takes into account all relevant elements for determining its actual nature, including those that can be inferred from the use of automated monitoring or decision-making systems, and that the relationship is presumed to be one of employment where facts emerge indicating the existence of powers of direction and control, including through such systems, unless proven otherwise. New Article 11-bis has also been introduced, clarifying that the provisions of Chapter III apply to workers performing activity through digital platforms under Articles 47-bis et seq. of Legislative Decree No. 81 of 15 June 2015 . As regards protections for riders, the authentication system for accessing the platform has been clarified by reference to SPID, CIE or CNS, and it has been established that the deadline for entries in the single labour book relating to the period already in progress on the date of entry into force of the conversion law is extended by ninety days.
As regards secondment, new Article 16-quater introduces, on an experimental basis and in derogation from the ordinary secondment rules (which require a genuine interest of the seconding employer and limit secondment to companies within the same corporate group or the same sector), the possibility, from the date of entry into force of the conversion law until 31 December 2029, of seconding one or more workers, subject to a trade union agreement, even in the absence of a genuine interest on the part of the seconding employer and even between companies that do not belong to the same sector or do not apply the same collective agreement, where secondment is aimed at safeguarding employment levels or business continuity, preserving professional skills, or avoiding or limiting suspensions of activity, reductions in working hours, recourse to social safety nets or staff redundancies.
As regards staff leasing (agency work), new Article 16-quinquies amends Article 19 of Legislative Decree No. 81/2015, which governs the quantitative and duration limits applicable to staff leasing. For workers hired by the staffing agency under an open-ended contract, an overall limit of thirty-six months, even if not continuous, is introduced for fixed-term assignments performed with the same user company in duties of equivalent level and legal category, unless the collective agreement applied by the user company provides for a different time limit. Any clause restricting, even indirectly, the user company’s right to hire the worker during or at the end of the assignment period is declared void.
Among the further changes, new Article 6-ter amends Article 8 of Law No. 68/1999, providing that workers with disabilities retain their position on the waiting list for mandatory placement even when hired under an apprenticeship contract or a fixed-term contract, until the relationship is converted or an open-ended contract is concluded.
The employment incentives under Articles 1 to 4 (Bonus donne 2026, Bonus giovani 2026, Bonus ZES 2026 and the stabilisation incentive), already described in the previous Newsletter, remain confirmed, subject only to changes of a purely formal nature, as do the provisions on payments into the Treasury Fund for the year 2026 under Article 16.
The opinions and information contained in this Newsletter are for general informational purposes only and cannot be considered sufficient to adopt operational decisions or to undertake commitments of any kind, nor do they constitute the expression of professional legal advice. This Newsletter is the property of Studio Legale Carlo Pisani e Associati.
For further information on the topics covered, please contact:
Prof. Avv. Carlo Pisani
Avv. Federico Pisani