With the publication in the Official Gazette on June 1, 2026 of Legislative Decree No. 96 of 7 May 2026, Italy has become one of the first EU member states to formally implement the EU Pay Transparency Directive (2023/970/EU), meeting the June 7, 2026, transposition deadline. The decree enters into force on June 7, 2026.

Italy’s choice to anchor the reform to the national collective bargaining framework — a feature we highlighted when the draft was first published (see here) — is confirmed in the final text.

This article examines the key provisions and their practical implications for employers operating in Italy.

A Distinctly Italian Approach: The Central Role of the NCBA

The most distinctive feature of Italy’s implementation — confirmed in the final text — is the central role assigned to national collective bargaining agreements (NCBAs, or contratti collettivi nazionali di lavoro) as the primary framework for assessing “same work” and “work of equal value.”

Employers may supplement the NCBA framework with their own internal job classification and evaluation systems, provided these are objective and gender-neutral. However, internal systems may only integrate — and not replace — the NCBA framework.

Pre-Employment Transparency

All job postings must specify the initial pay or pay range for the position, determined on the basis of objective and gender-neutral criteria, as well as a reference to the relevant provisions of the applicable NCBA. Asking candidates for information...

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