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ARTICLE · 30 SEPTEMBER 2026

Navigating Italy’s Pay Transparency Law: Takeaways From Decree 96/2026

GGI | Global Alliance
GGI | Global Alliance
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Italy's Legislative Decree No. 96/2026 implements the EU Pay Transparency Directive, introducing a comprehensive framework that shifts equal pay from an HR objective to a rigorous legal mandate with severe consequences for non-compliance. The legislation reverses the burden of proof in discrimination cases, prohibits pay secrecy clauses, and grants government agencies unprecedented access to corporate pay structures through automated reporting systems.

ItalyEmployment and HR
Sara Mandelli (Baldi & Partners)
Sara Mandelli (Baldi & Partners)
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As the European Union Pay Transparency Directive ends an era of pay secrecy, Italy’s Legislative Decree No. 96/2026 introduces a framework that balances corporate simplification with significant litigation risks. For employment lawyers and multinational companies, understanding this shift is crucial. The new landscape transforms equal pay from a human resources objective into a rigorous legal mandate with severe evidentiary consequences for non-compliant employers.

A central pillar of the Italian legislation – and a strategic defence mechanism for companies – is the statutory “presumption of conformity” assumption. Employers applying National Collective Labour Agreements (CCNLs) signed by the most representative trade unions are legally presumed to comply with equal pay principles regarding their classification systems. While this saves companies from the heavy burden of creating complex, internal systems from scratch to weigh the value of different jobs, legal counsels must still

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