Complying with the Italian transposition of the EUPTD

Italy’s formal transposition of the EU Pay Transparency Directive (EUPTD) was established via Legislative Decree No. 96/2026. This regulation introduces compliance obligations for employers operating in Italy regarding hiring transparency, employee information rights, and equal pay reporting.

Because the Decree became effective on June 7, 2026, organizations must ensure their compensation and recruitment practices strictly align with these legal frameworks.

This article details the objective compliance timelines, highlights where Italian law deviates from or aligns with the broader EU Directive, and explains how to utilize beqom’s PayAnalytics solution, including proactive data publishing strategies to minimize administrative burden.

Compliance timeline and effective dates

Under the new regulations, Italian employers must adopt immediate transparency measures, while the rollout of the pay reporting obligation is phased according to employee headcount.

Requirements effective June 7, 2026

The following core compliance protocols apply to all covered employers as of June 7, 2026:

• Pre-employment transparency: In notices and announcements advertising job opportunities, employers must provide information regarding the starting salary or the applicable salary range to be assigned to the position, based on objective and gender-neutral criteria. Postings must also explicitly reference the relevant provisions of the applicable National Collective Bargaining Agreement (NCBA / CCNL).

• Salary history ban: Employers are prohibited from inquiring about a candidate's current or historical compensation, whether directly or through third-party recruitment agencies.

• Accessibility of pay criteria: Organizations must make the objective, gender-neutral criteria used to determine pay levels easily accessible to all employees.

  • Employers that apply a collective bargaining agreement drafted by comparatively representative national trade unions may fulfill this obligation by referring to the criteria, classification levels, and remuneration set out in that agreement.

    

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    The obligation to disclose criteria for pay progression (for example, promotions and raises) is restricted to employers with 50 or more employees.

• Individual right to information (RTI): Employees hold the right to request and receive in writing information regarding their individual pay level, alongside the average pay levels of workers performing the same work or work of equal value, broken down by gender. Employers must fulfill these requests within two months.

  Employers may meet the obligation referred to in paragraph 1 by publishing, on their intranet or in the reserved area of the company website, information about the average salary levels by gender for categories of workers performing the same work or work of equal value.

Mandatory reporting deadlines

Formal gender pay gap reporting requirements follow a phased timeline based on organization size:

• Employers with 250+ employees: The initial annual report is due by June 7, 2027.

• Employers with 150–249 employees: The initial triennial report is due by June 7, 2027.

• Employers with 100–149 employees: The initial triennial report is due by June 7, 2031.

If a formal gender pay gap report reveals an unjustified gap of 5% or more in any worker category, employers have a six-month window from the reporting date to remedy the gap. Failure to resolve an unjustified gap triggers a mandatory Joint Pay Assessment conducted in cooperation with worker representatives.

Alignment and deviations from the EUPTD

While Legislative Decree No. 96/2026 closely tracks the foundational requirements of Directive (EU) 2023/970, the Italian framework adapts several mechanisms to integrate with its existing domestic labor laws.

Strategic alignments

• Headcount thresholds: Italy utilizes the same headcount groupings (100, 150, and 250 employees) and reporting frequencies as those outlined in the EU Directive.

• The 5% threshold: The mathematical trigger initiating a Joint Pay Assessment remains strictly aligned with the EU’s 5% variance cap.

• Candidate protections: The structural bans on salary history tracking and mandates for upfront pay ranges match the European standard.

Local deviations and specificities

• Centrality of NCBAs (CCNL): In Italy, National Collective Bargaining Agreements serve as the primary legal reference point for evaluating "work of equal value." Internal job evaluation architectures are permitted but must supplement and integrate with the statutory CCNL classifications rather than replace them.

• Coexistence with Law 162/2021: The legislative decree does not replace Italy’s existing obligation for companies with 50+ employees to submit a biennial gender equality report. Both reporting regimes run concurrently.

• Narrower scope of "pay level" for RTI: The Italian decree defines "pay level" as gross annual remuneration and the corresponding gross hourly rate consisting of continuous and fixed pay elements. Non-structural, highly individualized discretionary bonuses or temporary supplements that are not generalized within the same category of workers are excluded.

• Small business progression exemption: Italy leveraged an available EU exemption to completely excuse companies with fewer than 50 employees from the obligation to document and share pay progression criteria.

• Capped requests for information: Employees may not exercise their right to request information more than once a year.

Minimizing administrative work: the proactive fulfillment option

Fulfilling individual, ad-hoc right to information requests within the statutory two-month window can create significant administrative friction for HR operations. Legislative Decree No. 96/2026 includes an operational provision to mitigate this.

Employers can legally fulfill their ongoing right to information obligations by proactively publishing the information on average wage levels, broken down by gender, for categories of workers performing the same work or work of equal value, on their own intranet or in the reserved area of their company website.

In this way, organizations can effectively avoid processing ad-hoc manual data requests. However, employers leveraging this strategy must still remind workers annually of their rights and outline the exact procedures for accessing this centralized portal.

Execution with PayAnalytics

The PayAnalytics solution by beqom is designed to automate both the immediate local requirements and the long-term reporting deadlines established under the Italian Decree. The EUPTD general guidelines and approach form the foundation that can be fine-tuned to meet the specific requirements and deviations for Italy. We recommend starting with Getting ready for the EUPTD with PayAnalytics in the Help Center.

1. Data preparation and configuration: Your employee dataset must contain the required fields (columns) to comply with the Italian Decree. The PayAnalytics platform flexibly supports the configuration and mapping of your Category of Worker group – whether using your internal grading system or the Italian CCNL classifications – and relevant Compensation elements.

   For data requirements and field mapping, see Preparing your data for the EUPTD.

2. Employee pay transparency reports: The built-in employee pay transparency report helps HR teams meet the EU Pay Transparency Directive Article 7 requirement to communicate to each employee how their pay compares to similar employees (their "category of worker") upon exercising their right to request pay information. After configuring the relevant Compensation element and Category of Worker group, this standard report supports compliance with the Italian employee right to information process.

   Step-by-step guidance is available in the Employee pay transparency report and Pay explainability report Help Center articles.

3. Proactive transparency reports: Rather than managing ad-hoc requests, you can use the Compensation by category table in the PayAnalyticsWorkforce Analytics report section to view aggregated, gender-disaggregated average compensation tables by role category. With the Category of Worker as role and the relevant Compensation element selected, the table provides the required data to upload to your employee intranet or HR portal.

   You can find more details in Workforce analytics.

   

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   It is not possible to bulk export the employee pay transparency reports (as mentioned in point 2) in PDF format.

4. Proactive 5% gap auditing: The analytics engine identifies any employee category approaching or exceeding the 5% adjusted gender pay gap limit well ahead of the 2027 and 2031 reporting deadlines, protecting you from unexpected Joint Pay Assessments.

   To learn how to act on these findings, refer to Measuring & closing pay gaps by group.

5. Targeted compensation remediation: If an unjustified gap is flagged, the platform calculates objective, cost-effective salary adjustments, helping HR teams make compensation decisions that close pay gaps within the statutory six-month remediation window.

   The Getting suggested remediation actions article describes this process in detail.

6. Pre-employment pay ranges: PayAnalyticsCompensation Assistant is designed to help your hiring teams and people managers make decisions that align with both the main compensation drivers in your organization, and the individual’s characteristics at the time of hiring, promotion, transfer, or reemployment. It is essential to ensure equitable compensation decisions as your workforce evolves. While not intended specifically for the EUPTD pre-employment pay ranges, the tool can help generate equitable, data-backed salary ranges based on objective criteria, for use in Italian job advertisements.

   For a full guide to this feature, visit Using the Compensation assistant in the Help Center.

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This article is for informational purposes only and does not constitute formal legal, financial, or compliance advice.

The transposition of the EU Pay Transparency Directive into Italian law is an evolving regulatory process. National legislation, administrative guidelines, and court interpretations may change frequently. While we strive to provide accurate, high-quality insights and intend to update this article periodically to reflect major changes, regulatory frameworks move fast, and we cannot guarantee that all information remains valid.

Our solution is designed to help organizations streamline and manage their compliance workflows based on current directive standards. However, because individual corporate structures and local enforcement nuances vary, we strongly recommend consulting with a qualified legal counsel or compliance specialist to ensure your specific implementation aligns fully with the latest Italian statutory requirements.