Italy's Council of Ministers has approved transposition of the EU Pay Transparency Directive (2023/970) into local law. Following publication in the Official Gazette on June 1, 2026, the legislation took effect on June 7, 2026. It applies to all employers in the public and private sectors, with certain reporting requirements for companies with 100 or more employees. Although the legislation closely follows the directive's provisions, it also introduces some deviations from and additions to the directive.
Italy's Pay Transparency Directive legislation: Governance framework
| Provision and timing | Italy | Alignment with the directive |
|---|---|---|
| Category of worker | The primary reference is to the classification of jobs set out in the national Collective Bargaining Agreement (CBA) applicable to the employer. The directive's concept of "same work or work of equal value" can be interpreted as follows:
|
Aligned with the directive, except for cases where the employer adopts internal classification systems, in which case negotiation with employee representatives is not required |
| Transparency prior to employment Compliance from: June 7, 2026 |
Employers need to provide information on the starting salary or the relevant pay grade for the position in the notices and job postings announcing employment opportunities. Employers are prohibited from asking about an applicant's current salary or salary history, or obtaining such information by other means, indirectly or otherwise (e.g., third parties). |
National provision exceeding the directive |
| Transparency on pay criteria Compliance from: June 7, 2026 |
Employers are required to make information available to workers on criteria used to determine pay and benefit levels and pay progression (which must be objective and gender-neutral). Employers that apply a CBA and company agreements may refer to those agreements and should make them available. The information provided at the beginning of the employment relationship is considered to have met disclosure obligations (pay grade, starting salary, applicable CBA and relevant criteria for determining pay). The requirement on pay progression does not apply to organizations with fewer than 50 employees. |
Aligned with the directive |
| Employee right to information Compliance from: June 7, 2026 |
Employees are entitled to information on the average pay levels for workers performing the same work or work of equal value, broken down by gender, which must be provided within two months. Employers may fulfill this obligation by proactively publishing the information on their intranet or restricted areas of the corporate website. Pay levels are defined as continuous and fixed components (excluding individual, discretionary and ad hoc pay elements) that are objective and gender neutral. Employers must annually inform all workers of their right to receive information and procedures for exercising this right. Employees can exercise their right to information once a year. |
Not aligned with the directive on several items:
|
| Gender pay gap reporting First compliance by: June 7, 2027 |
Organizations with 100 or more employees are required to report periodically on gender pay gaps by entity and by category of worker. Entities with 100 to 249 employees report every three years; those with 250 or more employees report annually. Reporting commences on June 7, 2027, for entities with 150 or more employees and on June 7, 2031, for those with 100 to 149 employees. Entity‑level gaps must be reported to the monitoring body; they can also be made publicly available by the employer. Category‑level gaps must be made available to workers and their representatives and must be transmitted, on request, to the Labor Inspectorate and relevant regional equality bodies. |
Aligned with the directive |
| Pay gap assessments | Where gender pay gaps of 5% or more are identified at the category of worker level and cannot be justified on objective, gender‑neutral grounds or corrected within six months, employers must conduct joint pay assessments in cooperation with employee representatives and develop an action plan to address the gaps. | Aligned with the directive |
| Pay structures Compliance from: June 7, 2026 |
Employers must have formal pay structures based on gender‑neutral criteria, including responsibility, skills, effort and working conditions. The application of a CBA, including its systems of professional classification, grading and economic treatment, is considered a presumption of compliance with the principles of equal pay and transparency set out in the decree. |
Aligned with the directive |
| Other matters (including penalties) | Sanctions apply in line with enforcement mechanism established within Decree n.198/2006 (Equal Opportunities Code) for violations of the decree and proven discrimination. | Not aligned with the directive on the burden of proof |
Employers should prepare to implement the pay transparency legislation, including developing any databases and reporting systems to support compliance. The Ministry of Labor will publish additional decrees within 90 days of publication of the approved legislation, to provide details on information and communications concerning the gender pay gap reporting obligations. Italy had an unadjusted gender pay gap of 17.4% in the private sector as of 2024 (Eurostat data).
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