BLOG · 9 JUN 2026 · 4 MINREAD

Legislative Decree 96/2026: what changes for companies with pay transparency

With Legislative Decree 96/2026, in force since 7 June 2026, Italy transposes EU Directive 2023/970 on pay transparency, introducing new obligations set to reshape the labour market.

by Itineris

We had already anticipated it, but now it's reality. With Legislative Decree 96/2026, in force since 7 June 2026, Italy officially transposes EU Directive 2023/970 on pay transparency, introducing new obligations set to significantly reshape the labour market. The right to privacy still stands: you won't be able to see colleagues' pay. The decree introduces measures to define objective pay and career-progression criteria, and the possibility for staff to obtain clarifications.

Why the new rules exist

Despite progress in recent years, the gender pay gap remains a problem across Europe. One of the main obstacles to closing it is a lack of transparency: workers often don't have the information they need to understand whether unjustified pay differences exist, and companies aren't required to make the criteria used to set pay clear.

The new rules tackle exactly this, introducing tools that make pay policies more transparent and comparable.

The main changes

during recruitment and hiring, an obligation to state the pay or salary range in job ads and postings

it is no longer possible to ask candidates about pay received in previous or current jobs

companies with more than 50 employees must make available the criteria used for pay progression

employees can request information on average pay levels, broken down by sex, for categories doing the same work or work of equal value; the organization must respond within two months

an obligation to inform staff annually of their right to request such information

an obligation to collect and analyse data on the gender pay gap, including variable components, the median gap and quartile distribution

where unjustified differences of 5% or more exist, an obligation to take corrective measures within six months, otherwise a joint assessment with workers' representatives

a reporting obligation for organizations with more than 100 employees (annual above 250, every three years between 100 and 250)

a ban on contractual clauses that limit the ability to disclose information about one's own pay

within 180 days, the establishment of a monitoring body at the Ministry of Labour

The decree adopts a precise definition of "pay level": the comparison concerns gross annual and gross hourly pay, i.e. continuous and stable components; non-structural individual items such as bonuses or temporary discretionary benefits are excluded. The goal is not to standardise salaries but to ensure that any differences are based on objective, non-discriminatory criteria.

What companies should already be doing today

reviewing the structure of their pay policies

revisiting the criteria used to grant raises and career progression

ensuring pay data is available

identifying any pay differences and assessing whether they are justified by objective criteria

building the capacity to produce clear, comprehensive reports and analysis

The role of UNI/PdR 125

Many of the activities required by UNI/PdR 125 — monitoring indicators, collecting data, measuring the gender pay gap, structured HR processes — provide a useful basis for tackling the new obligations. The certification does not replace the legal requirements but helps build a management system already geared towards measurement and continuous improvement.

Transparency as a strength

Reducing the gender pay gap is not just about meeting an obligation: pay transparency is increasingly important for attracting talent, strengthening people's trust and demonstrating commitment to social sustainability. Legislative Decree 96/2026 is not only a new requirement but an opportunity to rethink pay policies in a more transparent, merit-based way.

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