EU Pay Transparency Directive Status Italy: In Force
Italy's transposition is complete and in force. The Council of Ministers approved the final legislative text in the spring of 2026, it was published as Legislative Decree No. 96/2026 in the Official Gazette on 1 June 2026, and it took legal effect on 7 June 2026, meeting the EU deadline exactly rather than missing it. The decree amends and builds on the existing Code of Equal Opportunities, layering in the Directive's pre-employment transparency duties, employee information rights, phased gender pay gap reporting, and joint pay assessment mechanism. Because Italy is already past the point of drafting and consultation, the obligations described here are current legal requirements for Italian employers today, not proposals; the main open question for employers is less whether the law applies and more the practical rollout of reporting portals and guidance as the first reporting deadlines approach in 2027.
What is Pay Transparency, and who does it apply to?
The EU Pay Transparency Directive (Directive (EU) 2023/970) is a binding EU law requiring pay equity for equal work between women and men. It introduces mandatory rules around salary disclosure, pay gap reporting, and worker rights.
Italy already had a foundational gender equality framework under the Code of Equal Opportunities between Men and Women (Legislative Decree 198/2006) and the constitutional equal pay guarantee in Article 37. Italy has now fully transposed the EU Pay Transparency Directive through Legislative Decree No. 96/2026, which was published in the Official Gazette on 1 June 2026 and entered into force on 7 June 2026, the EU-wide deadline itself. Italy is one of only four EU member states, alongside Slovakia, Lithuania, and Malta, to transpose the Directive on time, so unlike most of the rest of the EU, Italian employers are now operating under a finished, binding law rather than a draft.
In Italy, pre-employment transparency and employee pay information rights apply to all employers today, while gender pay gap reporting and joint pay assessment duties phase in starting at 100 employees and scale up in frequency for employers above 150 and 250 staff.
What employers must do in Italy
All employers
- Disclose starting salary or salary range, along with relevant collective bargaining agreement provisions, in job advertisements and postings
- Refrain from asking candidates about their salary history
- Use objective, gender-neutral criteria in job descriptions, pay setting, and pay determination
- Maintain accessible criteria for pay, pay levels, and pay progression, except that employers with fewer than 50 employees are exempt from the pay progression transparency requirement
All employers, employee information rights
- Respond within two months to employee requests for average pay levels, broken down by gender, for categories of workers performing the same or equivalent work
- Limit disruption by allowing employees one such information request per 12-month period
Employers with 100 to 149 employees
- Report gender pay gap data every 3 years, with the first report due 7 June 2031
Employers with 150 to 249 employees
- Report gender pay gap data every 3 years, with the first report due 7 June 2027
Employers with 250 or more employees
- Report gender pay gap data annually, with the first report due 7 June 2027
Employers with 100 or more employees
- Conduct a joint pay assessment with worker representatives, and formally confirm the accuracy of reported pay gap data following consultation, when an unjustified pay gap of 5% or more in any category persists 6 months after reporting
Key deadlines
Penalties for non-compliance in Italy
Non-compliance is sanctioned under the administrative fine regime of Article 41 of the Code of Equal Opportunities, generally cited in the range of a few thousand euros per violation, with serious or repeated breaches potentially triggering revocation of benefits and exclusion from public procurement and financial incentives for up to two years; exact fine amounts can vary by violation type, so employers should confirm current figures with Italian counsel.
Enforcement in Italy is shared by the Ministry of Labour and Social Policies, the National Labour Inspectorate, and the territorially competent equality counsellors (consiglieri di parita), with a dedicated procedure under Article 38 of the Code of Equal Opportunities for injunctions and damages claims.
How TalentUp can help you with Pay Transparency Compliance
Below you can see a preview of our platform, where we help you stay compliant with Pay Transparency by spotting pay inconsistencies and structural risks in your compensation strategy, analysing data from your company.
Book a demo| Name | Level | Location | Salary | Labels | Actions |
|---|---|---|---|---|---|
|
John Doe
Software Developer
|
Mid
|
Rome
Italy
|
32500 EUR
Above market
|
Unbalanced
|
|
|
Jane Smith
Project Manager
|
Senior
|
Rome
Italy
|
45000 EUR
Above market
|
In Market
|
|
|
Michael Brown
Data Analyst
|
Mid
|
Milan
Italy
|
39000 EUR
Above market
|
In Market
|
|
|
Emily Johnson
QA Engineer
|
Mid
|
Milan
Italy
|
36000 EUR
Above market
|
In Market
|
|
|
Robert Wilson
HR Manager
|
Senior
|
Naples
Italy
|
50000 EUR
Above market
|
Above Market
|
|
|
Sarah Davis
Marketing Specialist
|
Junior
|
Naples
Italy
|
34000 EUR
In market
|
In Market
|
MEAN PAY
39.4K EUR
MEDIAN PAY
37.5K EUR
MEAN FEMALE PAY
38.3K EUR
MEDIAN FEMALE PAY
36K EUR
MEAN MALE PAY
40.5K EUR
MEDIAN MALE PAY
39K EUR
Gender gap
Variable pay by gender
General gender pay gap
Pay gap insights
Add employee data to see pay gap insights
Tenure distribution
Pay gap per level (quartiles)
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Frequently asked questions about pay transparency in Italy
Yes. Italy's Legislative Decree No. 96/2026 entered into force on 7 June 2026, making Italy one of only four EU countries to transpose the Directive by the deadline rather than still working from a draft.