Greater transparency in recruitment, clarity on pay criteria, and monitoring obligations for the gender pay gap for larger companies. These are the cornerstones of the European pay transparency directive (2023/970), transposed into Italian law by means of a dedicated decree. The new law has a very broad scope, applying to all public and private employers and all subordinate employment relationships, including fixed-term, part-time and managerial contracts (apprenticeships, domestic work and on-call work remain excluded). Here is a closer look at the new rules, most of which came into force on 7 June 2026.

What's new, from gross annual salary in job listings to the right to know average pay

One of the most immediate changes concerns recruitment. Job advertisements will have to state the expected starting salary or the relevant pay range, along with the provisions of the collective bargaining agreement applicable to the role. Furthermore, during the selection process, employers will not be able to ask candidates about their previous salaries, nor obtain that information indirectly through companies or professionals engaged in recruiting.

The decree also addresses internal transparency. Workers will have the right to know the criteria used to determine pay, pay levels and career pay progression. They will also be able to request information on average pay levels, broken down by gender, for people performing the same work or work of equal value. The company will be required to respond within two months. In any case, only average figures are involved: it is not permissible to ask what a specific colleague earns. But how is "the same work" and "work of equal value" defined? The Italian decree refers to national collective bargaining agreements.

What it means for companies to report the gender pay gap

Companies with at least 100 employees will also face gender pay gap reporting obligations. The data to be disclosed includes the mean and median pay gap, variable pay components, the distribution of men and women across pay quartiles, and pay differences between worker categories. The first deadlines will kick in on 7 June 2027 for companies with at least 150 employees. From that date, firms with between 150 and 249 employees will be required to report data every three years, while those with at least 250 employees will have to do so annually. For companies with between 100 and 149 employees, the first reporting date is set for 7 June 2031.

The decree also introduces a specific threshold: if the data reveals a mean pay gap of at least 5 per cent between men and women in a given job category, and the difference is neither justified by objective, gender-neutral criteria nor corrected within six months, the employer will be required to carry out a joint pay assessment together with worker representatives. The analysis must identify the causes of the gap and any corrective measures to be adopted.

The Italian transposition decree also provides for the establishment of a monitoring body within the Ministry of Labour and Social Policies. Its tasks include collecting and publishing the gender pay gap data reported by companies, analysing the causes of pay disparities, monitoring complaints and legal proceedings relating to pay discrimination, and periodically transmitting information to the European Commission.