Italy approves final text of legislation to implement the Gender Pay Transparency Directive (update)

At a glance

• On 30 April 2026, the Council of Minsters adopted its domestic legislation to implement the Gender Pay Transparency Directive (Directive).
• Although the legislation has not been officially published yet, most of the key obligations are now expected to take effect on 7 June 2026, in line with the Directive deadline. Other obligations will come into force at a later stage.
• The final text includes some changes from the original draft, which employers should take note of.

Update: 3 June 2026

Italy's new decree, Legislative Decree No. 96/2026, implementing the Directive has now been published in the Official Gazette.

19 May 2026

In an update to our earlier article, Italy has now confirmed its final text for the local legislation which will bring into force its gender pay transparency obligations under the Directive.

The final text was approved on 30 April 2026 and is now waiting official publication.

The new legislation does include some changes from the original draft. Notably:

• Apprenticeship contracts are now included in the scope (previously excluded).
• The definition of 'pay levels' has been refined: Only fixed and continuous pay elements are subject to comparison (eg base salary, seniority increments, fixed allowances). Variable or discretionary components such as bonuses, MBO / LTI incentives, overtime and individual top-ups are excluded.
• The definition of 'same work' has been clarified: Work is comparable only if it falls under the same job classification and category under the applicable national collective agreement.
• Employees may request pay information only once per year. The employer's response deadline is now expressly set at two months (previously 'within a reasonable time').
• If the 5% pay gap threshold is exceeded and no union agreement is reached, the Labour Inspectorate may now be invited to participate in the remediation process.

Notwithstanding these changes, it now appears that the following obligations will come into force on 7 June 2026:

• Disclosing the entry salary or salary band in job advertisements.
• Making pay determination criteria and pay levels accessible to employees.
• Providing a written response within two months to any employee's request for information on average pay levels disaggregated by sex.
• Informing all employees annually of their right to request this pay information.
• Reporting gender pay gap data, with first reports due for larger employers in June 2027.