Pay transparency in Italy: data, reports and job ads

What the law asks

Legislative Decree 96/2026 transposes EU directive 2023/970 and has been in force in Italy since 7 June 2026. Some rules apply to every employer, others depend on headcount.

Before hiring (article 5), candidates must be told the starting pay or pay band, and the employer can't ask what they earn or used to earn, not even through an agency.

From 100 employees (article 9), the indicators have to be reported: the overall gap and the gap in variable pay, the medians, the share of women and men receiving variable pay, the share in each pay quartile and the gap by category of workers. You confirm the data yourselves, after consulting worker representatives. The decree leaves the way of collecting it to decrees from the Ministry of Labour, so the final format has to be checked there.

What changes on your website

This is the quick part, and it concerns small companies too:

• in the application form I remove any "current salary" or "last salary" field;
• on the careers page I add the pay or pay band to each ad, with the collective agreement;
• I check the wording of the ads, which must use gender-neutral criteria.

If ads live in business software or a portal, I add the field there, so nobody forgets it.

The report

Nearly all the work is in the data. Payroll sits in one program, bonuses in a spreadsheet, job grades in another, and "work of equal value" doesn't always match the contract level. I take the exports, merge them and calculate the article 9 indicators, with the same formulas every time.

If the calculation is rerun often it becomes a small business app or a dashboard with personal logins. If it's needed once every three years, a well-built spreadsheet will do, and I'll tell you so up front.

What I don't do

I don't run payroll, decide which jobs have equal value or negotiate with unions. That's for you, your payroll consultant and your lawyer. This page summarises the decree as read on 30 October 2026 and is not legal advice.

Switzerland has different rules: see the equal pay analysis with Logib.

Frequently asked questions

When do I have to report?

It depends on headcount. 250 or more: data collected by 7 June 2027, then every year. 150 to 249: by 7 June 2027, then every three years. 100 to 149: by 7 June 2031, then every three years. Below 100 the report isn't required, but the rules on job ads and hiring still apply.

Doesn't my payroll consultant already do this?

They may, so start there. Software helps when the data sits in three places (payroll, bonuses, job grades) or when the calculation has to be rerun often to see what a pay rise does. If your consultant already gives you the indicators, you don't need anything else from me.

Where does the salary data stay?

With you: the program runs on your server or your computer, with personal logins. Data like this doesn't go through outside AI services, and I test with made-up data.

What if the gap is above 5%?

A joint assessment with worker representatives is triggered if the average gap in a category is at least 5%, can't be justified by objective, gender-neutral criteria and isn't corrected within six months (article 10). That's a company decision: I can show you where the gap is, category by category.

Read more

• The service: Custom business web apps
• More pages like this: New rules to comply with