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Salary range in Italian job ads: what D.Lgs. 96/2026 asks employers to disclose, and when

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By Bandplain · Last verified: 2026-10-04 · Rule pack 2026-10 · Information, not legal advice

In short. Italy's Legislative Decree 96 of 7 May 2026 (D.Lgs. 96/2026), in force since 7 June 2026, requires employers to give applicants the initial pay or its range, and the relevant collective-agreement (CCNL) pay provisions, in the job notice itself. It bans questions about an applicant's current or past pay. Employees can ask in writing for the average pay levels, by sex, of workers doing the same work or work of equal value, and must be answered within two months (Art. 7(1)). Their own pay is already stated in the hiring information under D.Lgs. 152/1997. Gender pay-gap reporting starts at 100 employees. The rules for employers under 50 differ in two places, described below. (Sources: Gazzetta Ufficiale, https://www.gazzettaufficiale.it/eli/id/2026/06/01/26G00112/sg, opened 2026-10-04.)

Who this applies to

Question Answer Source
Which employers? Public and private employers (for matters not already governed by national law, Art. 2(1)); no size floor for the job-ad and information duties Art. 2
Which contracts? Fixed-term, open-ended, part-time and managers. Domestic work and intermittent contracts are excluded. Applicants are covered for the job-ad duty Art. 2
In force 7 June 2026 (Art. 17) see Sources
Law behind it Implements Directive (EU) 2023/970 (https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023L0970, opened 2026-10-04) see Sources

What to disclose about pay, and when

Moment What the employer gives Where Source
Before hiring The initial pay or its range, based on objective, gender-neutral criteria, and the relevant provisions of the collective agreement (CCNL) applied by the employer to the position In the notices and calls that announce the job ("negli avvisi e nei bandi"). This is stricter than the directive, which leaves the timing to each country Art. 5(1); Art. 5(1)
In the ad text Gender-neutral wording and job titles The ad Art. 5(3)
What counts as "pay" The Italian definition of "livello retributivo" counts continuous and fixed pay only; individual, discretionary or temporary non-structural elements are left out Used when stating levels and averages Art. 3(1)(b)

Practical reading for a 10 to 250 employee company: state a realistic range for each role in every notice, built from the pay actually paid for that role, and name the applicable CCNL. Whether naming the CCNL is enough is not settled (see below).

Salary-history questions

Employers may not ask applicants about current or past pay, and may not obtain it indirectly, including through recruiters (Art. 5(2)). Source: listed at the end of this guide. If a recruitment agency writes your ads or screens candidates, give it the same instruction in writing.

Pay-information requests from employees

Item Rule Source
Form Written request; written answer Art. 7
Deadline Within two months Art. 7(1)
Frequency At most once a year per worker Art. 7(1)
Intranet The duty may be met by publication on an intranet Art. 7(2)
Annual notice All workers are informed of the right once a year Art. 7(4)
Clarifications Reasoned reply to a request for clarification Art. 7(5)
Pay-secrecy clauses Banned Art. 7(6)
Employers up to 49 employees May answer through the modalities set by a ministerial decree (Art. 7(8) with Art. 9(4)) see Sources

In Italy the law itself limits use: information about other people's pay may be used only to exercise the right to equal pay and must not reveal any individual's pay (Art. 7(7)).

Pay criteria and progression

Criteria for setting pay and for pay progression must be accessible to workers; a reference to the CCNL can satisfy this (Art. 6(2)). Employers with fewer than 50 employees are exempt from the progression criteria (Art. 6(3)). A CCNL signed by the most representative unions creates a presumption that pay classifications conform (Art. 4(1)). The hiring information under D.Lgs. 152/1997 is the ordinary way to meet the criteria duty (Art. 6(2)). Source: listed at the end of this guide.

Reporting thresholds and dates

Employees First data due Then Source
250 or more 7 June 2027 every year Art. 9(8)-(9)
150 to 249 7 June 2027 every 3 years see Sources
100 to 149 7 June 2031 every 3 years see Sources
Under 100 No reporting duty found in the decree Art. 9(8)

The decree says the data are "raccolti" (collected) by those dates and go to a monitoring body at the Labour Ministry (Arts. 9(5), 14). Employees may ask for clarifications of the data and must get a reasoned reply within 60 days (Art. 9(7)). A joint pay assessment is required when the report shows a gap of at least 5% in a category of workers that is not justified by objective, gender-neutral criteria and is not corrected within 6 months (Art. 10; Directive Art. 10(1)). Source: §1.

What is not yet settled (as of 2026-10-04)

  1. Reporting format. The ministerial decree that sets how data are collected (Art. 9(4)) was due around 5 September 2026. We have not confirmed whether it has been adopted. Labour Ministry guidance (Art. 4(6)) is possible by 31 December 2026. (open items)
  2. Sanction for a missing range. The decree applies the Equal Opportunities Code (D.Lgs. 198/2006, Art. 41) when a discrimination is established (Art. 13). It creates no specific fine for a missing range in an ad. Whether a missing range can be pursued under that route needs professional review. We therefore state no amount.
  3. Collective agreement. Art. 5(1) asks for "indicazioni" (indications) on the relevant provisions of the collective agreement the employer applies to the position; this points to a reference rather than a full quotation, and applies only where a collective agreement is applied. Whether naming the CCNL and level is enough needs professional review. (see Sources open items; product-constraints.md §5)
  4. Employers under 50. The use of the ministerial-decree modalities for answers (Art. 7(8)) depends on a decree we have not seen.

Checklist for the next job ad

  • The ad states the initial pay or a range for the role, based on pay actually paid.
  • The ad names the collective agreement (CCNL) the employer applies to the position, or says none applies, and the classification level (livello) for the role if a CCNL applies (our suggestion; see open item 3).
  • The wording and the job title are gender-neutral.
  • Nobody (including a recruiter) asks about current or past pay.
  • A named person and a calendar reminder exist for written pay requests: answer within two months, once a year per worker.
  • Contracts contain no pay-secrecy clause.
  • You know your headcount band (under 50, 50-99, 100-149, 150-249, 250 or more) and which dates apply.
  • A labour consultant has reviewed the template wording.

FAQ

Does the range have to be in the ad itself in Italy? Yes. The decree says the information is given in the notices and calls announcing the job, which is stricter than the directive (Art. 5(1)).

Does it apply to a company with 12 employees? The job-ad, salary-history and information duties have no size floor in the text we read. Employers under 50 are exempt from the progression criteria (Arts. 2, 5-7).

Can we ask candidates what they earn now? No. Questions about current or past pay, direct or indirect, are not allowed (Art. 5(2)).

How fast must we answer an employee? In writing, within two months, and at most once a year per worker (Art. 7(1)).

Do we have to file a pay-gap report? From 100 employees, with the dates in the table above (Art. 9).

Is there a fine? The decree applies the Equal Opportunities Code when a discrimination is established (Art. 13) but sets no specific fine for a missing range in an ad; whether a missing range can be pursued that way is not settled, and no amount is stated here .

Sources (all opened 2026-10-04)

Update log

  • 2026-10-04: first draft, rule pack 2026-10. Next scheduled review: 2 November 2026.