• NCLA Temporary Work Agencies – Welfare

Effective September 1, 2025, for employment contracts with an initial or extended duration equal to or greater than six months, failure to comply with the minimum three-day notice period for the communication of an extension will result in the payment to the worker of a lump-sum welfare amount of EUR 20 for each day of notice not respected. This measure aims to fully compensate for any potential disadvantage suffered by the worker due to late communication of the contractual extension.

• NCLA Agriculture (Contracting Services) – Annual Bonus

An annual bonus, differentiated according to years of service with the same company, will be paid in September. In areas where bonuses are already provided, only any difference will be paid.

• NCLA Rural and Artisan Banks – Annual Bonus

The Company Productivity Value will be paid in a single instalment by the end of September. It is due to employees in service in the month of payment who have worked during the reference year, even in the case of part-time or partial absences. The amount is proportionate to the months of service and to the conditions set forth in the contract.

• NCLA Data Processing Centres – Flexible Benefits

Corporate flexible benefits, worth EUR 150 per year, will be paid by the end of September. They are granted to employees employed as of January 1 or hired by August 31, with permanent or fixed-term contracts (minimum three months of service). The amount is not pro-rated for part-time employees and is excluded from severance pay calculations.

• NCLA Social Cooperatives – Temporary Additional Pay Element

Educators classified at level D1 are entitled to a temporary additional pay element of EUR 41 per month, which will be increased by a further EUR 41 starting September 1, 2025, and will cease upon promotion to level D2 from January 1, 2026. The element, shown on payslips as “ETDR Educator,” affects all contractual entitlements but is not retained in case of a change in level or duties.

• NCLA Hotel Company Executives – Collective Superminimum

Executives will receive a salary increase of EUR 200, to be paid in September 2025. This amount is granted as a contractual superminimum and may be offset against increases already granted after December 31, 2019. Offsetting is valid only if expressly stipulated at the time of payment.

• NCLA Metalworkers (Small Industry) – CONFIMI – Welfare

Starting September 1, companies will provide employees with a welfare package worth EUR 200. Benefits can be used by August 31 of the following year, according to the procedures established at company level.

• NCLA Bakers – CONFCOMMERCIO – Welfare Fund

From September 1, 2025, companies must contribute to the financing of Territorial Workers’ Safety Representatives (RLST) with an annual amount of EUR 21. The contribution, equal to EUR 1.75 per month, will be due only after approval of the Regulation defined between the Parties. Companies already subject to territorial contributions are excluded, while newly established companies will pay a proportionate amount based on months covered.

• NCLA Bakers – CONFESERCENTI – Welfare Fund

From September 1, 2025, employers will be required to contribute to the fund for the financing of RLST with an annual contribution of EUR 21. The obligation is subject to the approval of a specific Regulation and does not apply to companies already bound by territorial agreements. Newly established companies or those with first-time hires will pay a proportionate amount based on months covered.

• NCLA Poste Italiane – Union Contributions

From September 2025, the minimum deduction for union contributions is set at 1%, calculated on the basic salary and cost-of-living allowance over 13 monthly payments.

• NCLA Poste Italiane – Canteen

From September 2025, the value of the meal voucher granted to employees working more than 7 hours a day with a break between 12:00 and 15:00 will be increased to EUR 6.30. The same amount applies to shift workers operating over 24 hours and those with a reduced break, in accordance with union agreements. For work not falling under these categories, the voucher will be EUR 4.80.

• NCLA Nursery Schools – FISM – Supplementary Health Care

From September 1, 2025, all employees with a contract longer than three months will be mandatorily enrolled in a supplementary health care fund. The contribution, equal to EUR 7 per month per employee, will be fully paid by the employer. The fund will be selected within 30 days by agreement between FISM and the signatory trade unions.

• NCLA Nursery Schools – FISM – Seniority Pay

From September 1, 2025, employees with at least two years of continuous service with the same institution will receive a monthly seniority allowance, payable over thirteen months. The amount is EUR 15 for levels one to four and EUR 20 for levels five to eight. This amount is in addition to any amounts already accrued under previous contract renewals.

• NCLA Cement and Lime (Industry) – Contractual Contributions

By September 10, 2025, employees not registered with Feneal-Uil, Filca-Cisl, and Fillea-Cgil may notify the company in writing of their decision not to join the extraordinary contribution of EUR 30. This contribution, required upon renewal of the NCLA, is a one-time membership fee intended to support trade union activities. If no objection is made, the deduction will be applied to the October payroll.

Minimum wage increases from September 1, 2025

As of September 1, 2025, minimum contractual wage increases are provided for the following NCLAs:

• NCLA Travel and Tourism Agencies – CONFCOMMERCIO

• NCLA Real Estate Agencies

• NCLA Shipping Agencies

• NCLA Commerce (ANPIT – CISAL)

• NCLA Hotel Chain Executives

• NCLA Vocational Training

• NCLA Toys and Model-Making (Industry)

• NCLA Metalworkers (Small Industry) – CONFAPI

• NCLA Waldensian Institutions

• NCLA Poste Italiane

• NCLA Public Establishments – CONFCOMMERCIO

• NCLA Public Establishments, Catering and Tourism

• NCLA Nursery Schools – FISM

• NCLA Religious Schools – AGIDAE

• NCLA Professional Firms – UNIMPRESA/UNIAP/CONFAIL

• NCLA Tourism – CONFESERCENTI

• NCLA Tourism (Industry)

One-off payments – September 2025

For the month of September 2025, one-off payments are planned for the following NCLAs:

• NCLA Contracted Postal Services

• NCLA Video-Phonographic Sector

• NCLA Private Security (Cooperatives)

• NCLA Private Security (Institutes)

In Judgment No. 103 of 8 July 2025, the Constitutional Court rejected the question of constitutionality raised by the Brescia Court in relation to Article 3 of the Constitution, concerning Article 2, paragraph 1-bis, of Decree-Law No. 463/1983, as amended by Article 23, paragraph 1, of Decree-Law No. 48/2023 (“Labour Decree”). The contested provision stipulates that, in the event of failure to pay social security and welfare contributions withheld from employees’ wages — for amounts not exceeding €10,000 per year — the employer is subject to an administrative fine ranging from one and a half to four times the unpaid amount.

The question raised by the Brescia Court

The constitutional issue was referred in August 2024 by the Brescia Court, acting as a labour court, in proceedings relating to unpaid contributions for the period 2013–2015 amounting to €7,153. Initially, the National Social Security Institute (INPS) imposed an administrative fine of €73,000. Following the entry into force of Decree-Law No. 48/2023, the Constitutional Court ordered the case to be returned for reconsideration, and INPS recalculated the fine, reducing it to €13,714. Article 23 of the Decree provides for a sanction “from one and a half to four times the unpaid amount”, based on the contributions not paid, with the aim of ensuring a proportional and sustainable application for non-compliant parties.

Persistence of the constitutional question

Despite the legislative amendment, the referring court maintained that doubts of constitutionality persisted, again highlighting the disproportionate nature of the statutory minimum fine in relation to the actual seriousness of the breach. The Court also stressed the potential for unreasonable outcomes, including the possibility that those failing to pay amounts below the €10,000 threshold might be subject to a harsher sanction than the criminal penalty — when converted into a pecuniary fine — imposed on an employer responsible for higher omissions. Furthermore, according to the Brescia judges, the legislation fails to adjust penalties for omissions caused by external circumstances, disregarding the offender’s personal situation and thereby infringing the principle of equality under Article 3 of the Constitution.

The Constitutional Court’s position

In Judgment No. 103/2025, the Constitutional Court upheld the validity of the provision. In rejecting the constitutional challenge, it first reaffirmed that the legislature enjoys wide discretion in determining applicable penalties for criminal offences and, by extension, for administrative sanctions. The Court also found that the sanction is neither unreasonable nor arbitrary, as the conduct in question involves appropriating funds belonging to employees and intended for the social security system, which finances essential benefits. Consequently, the sanction was deemed proportionate to the seriousness of the conduct and consistent with the level of protection accorded to workers as the weaker party in the employment relationship.

Moreover, when assessing the comparison between criminal and administrative liability, the Court stressed that such a comparison — based purely on arithmetic — lacks genuine legal significance if carried out in isolation. In its view, the observation that exceeding the €10,000 threshold could result in a criminal fine arithmetically lower than the administrative penalty below that threshold fails to take into account the more severe nature of criminal sanctions. Criminal proceedings carry significantly more burdensome indirect consequences, such as accessory penalties or compensation obligations, which materially affect the overall severity of the sanction.

In light of these considerations, the Court found no grounds for declaring the sanction regime for unpaid contributions unconstitutional, recognising the adequacy of the measure in deterring conduct that undermines compliance with social security obligations.

With Judgment No. 115 of 2025, the Constitutional Court declared the unconstitutionality of Article 27-bis of Legislative Decree No. 151/2001, insofar as it fails to grant mandatory paternity leave to an employed intended mother in a female same-sex couple who is registered as a parent in the civil status records.

The case was referred by the Labour Section of the Brescia Court of Appeal in proceedings initiated by Rete Lenford under Articles 2 and 3 of Legislative Decree No. 215/2003 and Article 28 of Legislative Decree No. 150/2011, seeking to establish discrimination against same-sex couples.

The worker, an intended mother, had been denied by the National Social Security Institute (INPS) the mandatory leave granted to employed fathers, on the grounds that she was “not a father,” despite being listed as the second parent on the child’s birth certificate. The court of first instance upheld her claim, ordering INPS to amend its IT system to allow the entry of parents’ tax codes irrespective of gender, with a penalty for each day’s delay in compliance.

However, the worker argued that the ruling did not clearly establish the right of same-sex couples to access parental leave on the same basis as heterosexual couples. This led to the referral to the Constitutional Court.

The contested legal framework

Article 27-bis of Legislative Decree No. 151/2001, introduced by Legislative Decree No. 105/2022, grants employed fathers the right to 10 days of mandatory, fully paid leave to be taken within five months of the child’s birth. It implicitly excludes the intended mother, even when officially recognised as a parent in the civil status records.

The issues raised

The Court of Appeal alleged violations of Article 3 of the Constitution (principle of equality) and Article 117, paragraph 1, in relation to:

• Articles 2 and 3 of Directive 2000/78/EC (equal treatment in employment and occupation),
• Article 4 of Directive (EU) 2019/1158, which extends the right to mandatory leave to the “second equivalent parent.”

The Constitutional Court’s ruling

The Court referred to extensive constitutional case law that values the parental role as a shared responsibility, independent of gender or biological ties (including Judgments No. 285/2010, 105/2018, and 68/2025).

It further noted that a child’s right to maintain a relationship with both parents is safeguarded:

• by the Constitution (Articles 30 and 31),

• by the Civil Code (Articles 315-bis and 337-ter),

• by international and EU instruments (UN Convention on the Rights of the Child, Charter of Fundamental Rights of the EU).

The Court affirmed that intentional parenthood has full legal relevance and that sexual orientation has no bearing on the capacity to assume parental responsibilities. The parental bond is not solely based on biological factors but arises from the conscious assumption of responsibility and the joint commitment to care for the child. In this context, excluding the intended mother from mandatory leave, despite her role being equivalent to that of a father in a heterosexual couple, is manifestly unreasonable.

Accordingly, the Court declared Article 27-bis of Legislative Decree No. 151/2001 unconstitutional insofar as it does not grant mandatory paternity leave to an employed intended mother in a female same-sex couple, both members of which are registered as parents in the civil status records.

Practical implications following the ruling

The decision obliges INPS and employers to recognise and process leave requests submitted by the second mother in female same-sex couples. This may be done via self-certification, provided the parental bond is evidenced in the civil status records.

Beyond its immediate administrative impact, the ruling marks a significant step towards a more inclusive system of protections, in line with developments in European law on work–life balance.

The National Labour Inspectorate, with note no. 5944 of 8 July 2025, intervened on the subject of measures prohibiting working mothers from working, both before and after childbirth.

Among the various points of note regarding inspection activities and the checks that these entail at companies, the note emphasised the central role of the Risk Assessment Document (DVR): in fact, if the DVR reveals the presence of risks for pregnant workers or workers in the post-partum period and it is not possible to assign them equivalent and compatible alternative tasks, the Inspectorate may order a work ban.

The note also reiterated that the request for early suspension from work can be submitted by either the employee or the employer, using the appropriate form available on the INL portal; However, if the request is made by the employer, they must justify the impossibility of reassigning the worker to another compatible job, also taking into account the efficiency of the company organisation.

Finally, the note emphasised that the prohibition measure must be adopted by the National Labour Inspectorate within seven days of receiving the complete documentation submitted by the worker or employer. Only in the event of missing documentation or unclear elements may an on-site inspection be necessary.

It is important to remember that any prohibition takes effect from the date of adoption of the measure by the Inspectorate and not from the date of submission of the application. In the event of rejection, it is also clarified that the Inspectorate will be required to justify its decision and to guarantee the right of the interested party to be heard, as required by current legislation.

The National Labour Inspectorate, with note no. 5944 of 8 July 2025, intervened on the subject of measures prohibiting working mothers from working, both before and after childbirth.

Among the various points of note regarding inspection activities and the checks that these entail at companies, the note emphasised the central role of the Risk Assessment Document (DVR): in fact, if the DVR reveals the presence of risks for pregnant workers or workers in the post-partum period and it is not possible to assign them equivalent and compatible alternative tasks, the Inspectorate may order a work ban.

The note also reiterated that the request for early suspension from work can be submitted by either the employee or the employer, using the appropriate form available on the INL portal; However, if the request is made by the employer, they must justify the impossibility of reassigning the worker to another compatible job, also taking into account the efficiency of the company organisation.

Finally, the note emphasised that the prohibition measure must be adopted by the National Labour Inspectorate within seven days of receiving the complete documentation submitted by the worker or employer. Only in the event of missing documentation or unclear elements may an on-site inspection be necessary.

It is important to remember that any prohibition takes effect from the date of adoption of the measure by the Inspectorate and not from the date of submission of the application. In the event of rejection, it is also clarified that the Inspectorate will be required to justify its decision and to guarantee the right of the interested party to be heard, as required by current legislation.

On 15 July 2025, the National Labour Inspectorate (INL) issued Notice No. 288, providing clarification on the procedures for obtaining the additional credits established by Ministerial Decree No. 132/2024, which introduced the credit-based licence system. Under the provisions of the decree, the initial allocation of 30 credits may be increased to a maximum of 100, upon demonstration of specific qualifying criteria. These include: the length of registration with the Chamber of Commerce, with points awarded proportionally to the number of years of registration; certification of an Occupational Health and Safety Management System (SGSL) compliant with UNI EN ISO 45001; adoption of an Occupational Health and Safety Management and Organisation Model (MOG-SSL) validated by a joint body; possession of SOA certification in category I or II; and a positive assessment issued by a joint body following consultancy and monitoring activities. The INL also outlines the procedures for rectifying any errors concerning additional requirements entered in the credit-based licence portal.

The legal representative (or an authorised delegate) may amend the information directly, provided such amendments are made prior to the score update, which generally occurs each night between midnight and 3:00 a.m. Should the correction not be carried out within the specified timeframe, the request for amendment must be submitted to the relevant local office of the Labour Inspectorate. Finally, it is specified that, should an inspection reveal that the enterprise does not meet one or more of the declared additional requirements, the inspection personnel may proceed with their invalidation, subject to confirmation by the Head of the relevant Office.

CCNL Executives of Zootechnical Bodies – Contractual vacation allowance

In August 2025, in the absence of contract renewal, Executives and Directors with the “Quadro” classification are entitled to a provisional wage element equal to 50% of the programmed annual inflation rate, calculated on minimum contractual wages. These provisional amounts are to be considered advances against what will be paid following the renewed CCNL, effective from its initial start date.

Minimum wage increases from August 1, 2025

As of August 1, 2025, minimum contractual wages will increase under the following CCNLs:

• CCNL Footwear Industry;
• CCNL Funeral Services (FENIOF).

CCNL Expirations – August 2025

The following CCNLs will expire in August 2025:

• CCNL Advanced Tertiary Sector (ANPIT, CONFIMPRENDITORI, UNICA, CISAL);
• CCNL Education, Training and Culture Bodies – FIDEF (formerly CONFIMPRESEITALIA).

With Circular No. 10/E of July 3, 2025, the Revenue Agency provided clarification on the tax treatment of mixed-use vehicles (cars, motorcycles, mopeds) assigned to employees, outlining three different calculation regimes.

2025 Budget Law regime

Paragraph 48 of the 2025 Budget Law replaced letter a) of paragraph 4 of Article 51 of the TUIR, introducing a new fringe benefit taxation regime for mixed-use vehicles to support ecological transition. The new regime, applicable from January 1, 2025, sets the fringe benefit at 50% of the amount corresponding to a standard annual mileage of 15,000 km, based on ACI tables. This percentage drops to 10% for fully electric vehicles and 20% for plug-in hybrid electric vehicles. To apply this regime, the following conditions must all be met starting from January 1, 2025: (i) the vehicle must be newly registered; (ii) the mixed-use contract must be signed; (iii) the vehicle must be assigned (delivered) to the employee.

Transitional regime under Article 6, paragraph 2-bis, of Decree-Law No. 19/2025

To ensure a smooth transition and protect business and employee expectations, a transitional provision was introduced. This provision states that the previous regime (in effect as of December 31, 2024) continues to apply to: (i) vehicles assigned for mixed use from July 1, 2020, to December 31, 2024; (ii) vehicles ordered by the employer by December 31, 2024, and assigned for mixed use between January 1, 2025, and June 30, 2025.

Even for this second case, the registration and contract must have been completed between July 1, 2020, and June 30, 2025. Furthermore, if a vehicle qualifies under the transitional regime but the 2025 regime is more favourable (e.g., for electric vehicles), the more advantageous regime applies.

“Normal value” regime excluding business use

For all other cases not covered by the new or transitional regimes, the general rule in Article 51, paragraph 3, of the TUIR applies. Under this rule, the fringe benefit value is based on the “normal value” as per Article 9 of the TUIR but only for the private-use portion. Business use must be excluded if it can be objectively and documentably identified.

An example is a vehicle ordered by December 31, 2024, with a contract signed in 2024 but delivered to the worker in July 2025. Since the delivery is after June 30, 2025, the transitional regime does not apply, and the normal value rule must be used.

The circular also addresses two specific cases. First, contract extensions: if the duration of an existing contract is extended, it does not constitute a new contract, so the original tax rules continue to apply throughout the extension period.

Second, vehicle reassignment to another employee: this is treated as a new contract, so the tax regime in effect at the time of reassignment applies. For reassignments:

1. if reassigned in 2025 and delivered by June 30, 2025 (original order by 12/31/2024), the transitional regime applies;
2. if delivered after June 30, 2025, the normal value rule applies;
3. if reassigned with a new contract and delivery in 2025 for a vehicle registered in 2025, the 2025 Budget Law regime applies.

In conclusion, Circular No. 10/E of July 3, 2025, offers an important interpretive clarification on fringe benefits related to mixed-use company vehicles, clearly outlining the three applicable regimes based on contractual and timing conditions.

With Circular No. 102 dated June 16, 2025, INPS has provided operational instructions for applying the incentive to postpone retirement, as set out in Article 1, paragraph 161, of the 2025 Budget Law (Law No. 207/2024). This new regulation replaces the one introduced by the 2023 Budget Law (Law No. 197/2022), expanding the range of potential beneficiaries. The measure no longer targets only workers who meet the requirements for flexible early retirement but also those who, by December 31, 2025, qualify for ordinary early retirement.

To benefit from the incentive, one must have alternatively met the requirements for either of the two types of early retirement outlined in the law. Specifically, for flexible early retirement, known as “Quota 103”, eligibility requires being at least 62 years old and having at least 41 years of contributions. For ordinary early retirement, the required contribution period is 41 years and 10 months for women, and 42 years and 10 months for men, regardless of age.

Additionally, the incentive is aimed at employees who choose to continue working, opting to waive the payment of the “IVS” share of social security contributions due from the worker. According to the law, the worker may choose not to have their share of contributions paid by the employer and instead receive the equivalent amount directly in their payslip. However, the employer’s contribution obligation remains, and the IVS quota due from the employer continues to feed the worker’s social security account according to standard rules.

It is important to note that the worker can exercise this waiver only once in their working life. Furthermore, the circular provides for the possibility of revoking the waiver — also allowed only once — effective from the first day of the month following the communication.

Applicable treatment of the incentive

A key aspect of the measure is the tax treatment of the amounts paid to the worker in place of the IVS contributions the employer would have paid on their behalf. According to the 2025 Budget Law and confirmed by the Revenue Agency’s Resolution No. 45/2025, these amounts are subject to the provisions of Article 51, paragraph 2, letter i-bis) of the TUIR, meaning they do not count towards taxable employment income. As a result, they are paid in full to the worker, tax- and contribution-free.

Start and end of the benefit

As clarified by the INPS circular, the exemption starts based on when the worker chooses to exercise the waiver. If exercised before meeting retirement eligibility, the exemption starts on the date the requirements are met. If exercised on or after the eligibility date, it starts on the first day of the following month. The end of the benefit is triggered not only by revocation but also by specific conditions, including reaching the statutory retirement age or obtaining a direct pension, except for the ordinary disability allowance.

Compatibility with other incentives

According to the circular, the incentive is compatible with other contribution reductions that apply exclusively to the employer’s share. However, it cannot be combined with incentives affecting the worker’s contribution share. Therefore, if the employment relationship already includes a full or partial reduction of the worker’s contribution share, this retirement deferral incentive does not apply.

Starting July 1, 2025, to benefit from the “Youth Bonus” provided for by the Cohesion Decree (Decree-Law No. 60/2024, converted into Law No. 95/2024) an additional requirement must be met: net employment growth.

This was announced by INPS through message No. 1935 dated June 18, 2025, issued in agreement with the Ministry of Labour and Social Policies. The incentive is aimed at permanent hires and conversions to permanent contracts for workers under the age of 35 and consists of a 100% exemption from social security contributions payable by the employer, up to a maximum of €500 per month per worker.

The measure is also conditional on the absence of previous permanent employment relationships.
The additional requirement, effective from July 1, was introduced following guidance from the European Commission, which requested that net growth in the total number of employees in the company be included among the eligibility criteria for spending under the youth employment incentives programme.

INPS’s message also notes that, in accordance with the new provisions, the application form already in use for requesting the contribution exemption has been updated. A mandatory declaration must now be included, made pursuant to Article 47 of Presidential Decree 445/2000, whereby the employer certifies the achievement and maintenance of net employment growth.

In response No. 188 of July 10, 2025, the Italian Revenue Agency clarified the scope of the amendments introduced by Decree-Law No. 84/2025 to the 2025 Budget Law (Law No. 207/2024), concerning the tax treatment of reimbursements for expenses incurred by employees during business travel.

The updated legislation limits the traceability requirement to expenses incurred within the national territory, thereby excluding those incurred abroad from the obligation.

Specifically, the Agency stated that:

• the traceability requirement introduced by the 2025 Budget Law applies exclusively to expenses incurred in Italy;
• for travel abroad, in order for reimbursements to remain non-taxable, it is not necessary to use traceable payment methods for expenses related to meals, accommodation, travel, and non-scheduled public transport services.

In line with the current regulatory framework, the Agency confirmed that, in the case of travel abroad, the absence of traceable payments — including those made in cash — does not affect the tax-exempt status of the reimbursement. These amounts remain excluded from employment income and are therefore not subject to taxation.so spese, che resta escluso dal reddito da lavoro dipendente e, dunque, non è soggetto a tassazione.

1. NCLA A.I.A.S. – Incentive Bonus

Employees who work at least 258 days between July 1 and June 30 of the following year are entitled to a gross annual bonus of €500. For each day of absence, €16 is deducted. If days worked exceed 258, up to a maximum of 269, the bonus increases by €16 for each additional day. The bonus is paid in a lump sum with July’s salary. A working week is considered to consist of six days.

2. NCLA Airports (AIR TRANSPORT) – Wages

In July 2025, the application of the “anomalous increment (+ IIS)” continues, serving as full economic compensation for the period January 1, 2020 to December 31, 2022, as per Article 14 of the Strategic Facilities section and Article 11 of the Low-Traffic Facilities section. The increment applies to employees in service as of January 1, 2023, covering the period up to December 31, 2025.

3. NCLA Airports (AIR TRANSPORT) – Handlers Section – Wages

Employees receive a daily allowance of €2.38 for each day of actual attendance. For those not working rotating shifts (H16 or H24) and not eligible for the shift allowance under Article H20, the daily allowance is €3.62. This allowance is all-inclusive and does not contribute to severance pay (TFR).

4. NCLA Airports (AIR TRANSPORT) – Professional Superminimum

A 2% revaluation of the professional superminimum is granted for the period from January 1, 2020 to December 31, 2022, per Article 16(1) of the Strategic Facilities section and Article 13 of the Low-Traffic Facilities section. It applies only to employees in service as of January 1, 2023.

5. NCLA Rural and Artisan Banks – Working Hours

Starting July 1, 2025, the weekly working time is set at 37 hours.

6. NCLA Cement and Lime (INDUSTRY) – Contractual Contributions

By July 31, 2025, companies must inform non-union workers that the signing trade unions (Feneal-UIL, Filca-CISL, Fillea-CGIL) request an extraordinary membership fee of €30 for the contract renewal. No deduction is applied to union members. Workers can opt out by notifying the employer in writing by September 10, 2025.

7. NCLA Chemical and Pharmaceutical (INDUSTRY) – Contractual Contributions

According to the signing trade unions, non-union employees will be subject to a €25 one-time deduction in July 2025 as a contribution toward the contract renewal.

8. NCLA Chemical and Pharmaceutical (INDUSTRY) – Duration and Start Date

The renewal agreement of April 15, 2025, takes effect on July 1, 2025, and remains valid until June 30, 2028.

9. NCLA Executives of Zootechnical Entities – Contractual Gap Allowance

From July 1, 2025, in the absence of a new agreement, Executives and Directors with “Quadro” status are entitled to a temporary allowance equal to 50% of the planned annual inflation rate, based on contractual minimum wages. These amounts will be considered as advances on future contract terms.

10. NCLA Pool Installers and Maintainers (CONFLAVORO – CONFSAL) – Holiday Bonus

By early July 2025, the 14th-month salary will be paid to employees hired before January 31, 2023. It corresponds to the actual wage as of the previous June 30. This benefit remains in force as a more favorable condition, as it was eliminated for those hired from February 1, 2023 onward.

11. NCLA Social Assistance Institutions – MISERICORDIE – Wage Guarantee Element

Misericordie organizations without second-level agreements by December 31, 2014, will pay a gross amount of €80 with July’s salary as a wage guarantee element.

12. NCLA Metalworkers – FEDERAT – Welfare

As of July 1 of each year, companies must provide employees who have completed their probationary period with welfare benefits worth €200, to be used by June 30 of the following year.

13. NCLA Bus Rental with Driver – Distinct Wage Element

Starting in July, employees in level C2 receive a gross monthly allowance of €40 for 14 months, as a wage guarantee element. This amount is proportional for other levels, includes all economic effects, and is not included in severance pay or contributions to the Priamo Fund.

14. NCLA Umbrella Manufacturing (INDUSTRY) – Complementary Pension

From July 1, 2025, employer contributions to the PREVIMODA complementary pension fund will increase to 2.30%. The employee’s contribution remains at 1.50%.

15. NCLA Leather and Tanning (INDUSTRY) – Complementary Pension

From July 1, 2025, employer contributions to the PREVIMODA pension fund will increase to 2.30%, with employee contributions remaining at 1.50%.

16. NCLA Funeral Services FENIOF – Supplementary Health Insurance

From July 1, 2025, the mandatory employer contribution to the EST Health Fund increases by €3 per month.

17. NCLA Cleaning – Seniority Increments

As of July, the biennial seniority increase for office staff applies. The value is 6.25% of the current base wage and the cost-of-living allowance as of August 1, 1983.

18. NCLA Accounting and Tax Auditors – Contractual Gap Allowance

Employees are entitled to a Contractual Gap Allowance (I.V.C.) for the period from September to December 2024. The amount varies by grade and is proportioned for part-time employees or those hired during that period. It will be paid in three installments: February, July, and November 2025.

19. NCLA Professional Firms – Condominium Administrators – Welfare

In July, employees who completed probation receive 50% of their annual contractual welfare benefit. The remaining 50% is provided in December. The annual minimum value is €1,200 for managers and €600 for all other levels.

20. NCLA Cable Transport – Paid Leave

Starting July 1, 2025, the annual amount of paid personal leave increases from 64 to 72 hours, to be used in 4-hour blocks, during periods of low company activity and compatible with operational needs.

Minimum Wage Increases from July 1, 2025

As of July 1, 2025, minimum contractual wages will be increased for the following NCLAs (translated and abbreviated for brevity, full names available upon request):

• NCLAAirports (Air Transport)
• NCLAAirports – Handlers
• NCLABreeders & Zootechnical Consortia
• NCLAAirline Catering
• NCLACeramics (Industry)
• NCLAChemicals & Pharmaceuticals (Industry)
• NCLACinematography
• NCLALand Reclamation Consortia
• NCLAExecutives of Maritime Agencies
• NCLAExecutives in Commerce
• NCLAExecutives in Road Transport Companies
• NCLAExecutives of General Warehouses
• NCLAGas and Water
• NCLAGraphic, Publishing (Artisan)
• NCLASocial Assistance Institutions – UNEBA
• NCLALamps and Cathode Ray Tubes (Industry)
• NCLAMaritime (CONFITARMA – office staff)
• NCLAMaritime
• NCLAMetalworkers (Artisan)
• NCLAMetalworkers (Artisan) – CONFLAVORO
• NCLABus Rental with Driver
• NCLADental Technicians
• NCLAGoldsmiths & Silversmiths (Artisan)
• NCLAGyms and Sports Facilities
• NCLAGym and Sports Collaborators
• NCLACleaning
• NCLACleaning & Multiservices (Confcommercio)
• NCLADelivery Services (telegrams, express)
• NCLAGlass Industry
• NCLAAudiovisual
• NCLAPrivate Security (Institutes)

One-Time Payments – July 2025

The following NCLAs provide for lump-sum “one-time” payments in July 2025:

• NCLAInsurance Agencies – SNA
• NCLAAirports – Airport Operators
• NCLACommerce – CONFCOMMERCIO
• NCLACommerce – CONFESERCENTI
• NCLAExecutives of Cooperatives
• NCLAModern Organized Distribution
• NCLAFedercasa
• NCLAPort Companies
• NCLATertiary and Services – SISTEMA IMPRESA/CONFSAL

With Circular no. 95 of May 26, 2025, INPS incorporated the changes to parental leave introduced by Article 1, paragraph 179, of Law no. 213 of December 30, 2024 (2025 Budget Law), which amended Article 34 of Legislative Decree no. 151/2001. The new provisions apply exclusively to employees, excluding self-employed workers and those registered with the INPS Separate Management scheme.

New allowances

As of January 1, 2025, allowances for the first three months of parental leave have been significantly increased. The first month remains set at 80% of the salary, as already established under 2023 regulations. The second month, previously compensated at 60%, is also raised to 80%. The third month, which until 2024 provided an allowance of 30%, will now also be covered at 80%. The amendment introduced by the 2025 Budget Law does not add additional months of paid parental leave, but solely increases the allowance for the first three months.

Start date and conditions

The new allowance rates apply to parents whose maternity or paternity leave ends after December 31, 2024. The parental leave must be taken within the first six years of the child’s life, or within six years of entry into the family in case of adoption or foster care. It is therefore essential to consider both the birth or entry date of the child and the end date of the mandatory leave, which represents the key condition for eligibility for the increased allowance.

Duration, distribution, and compatibility

The maximum duration of parental leave remains ten months in total for both parents, extendable to eleven months if the father takes at least three months. The three months with 80% compensation can be used by only one parent or split between both, even overlapping. After these three months, the next six remain payable at 30%, while any additional months are unpaid unless specific income requirements are met.

Application process

To obtain the benefit, an online application must be submitted through the official INPS channels. Applicants may use the Institute’s online portal or contact accredited patronage services.

Operational instructions

The circular also includes key operational guidance for employers. To align payrolls with the new measures, employers must carry out reimbursement adjustments for retroactive allowances from January 1 to June 30, 2025. These adjustments will be managed via the contribution reports for July, August, and September 2025, following technical instructions that will be issued in a dedicated communication.

With Ruling no. 147/E of June 4, 2025, the Italian Revenue Agency provided clarifications on the conditions required to apply the favorable tax regime set out in Article 51, paragraph 2, letter g) of the Italian Income Tax Code (TUIR), in relation to a stock allocation plan for employees. The Agency reiterated certain well-established principles in the matter, while also offering operational guidance for companies wishing to benefit from the tax relief.

The regulatory framework: Art. 51, paragraph 2, letter g) of the TUIR

The regulation provides that the value of shares granted to employees does not contribute to employment income, up to an annual limit of €2,065.83, provided that certain requirements are met. Specifically, the benefit may be granted if the shares are offered to all employees or to homogeneous categories, if the value does not exceed the set limit, and if the shares are held for at least three years from the allocation date.

The case in question

In the case under review, the applicant company—referred to as “Company Alfa”—had set up a plan involving the allocation of shares to employees, excluding certain specific categories: fixed-term employees, general managers, and executives with strategic responsibilities.

The question posed to the tax authority concerned the possibility of applying the tax benefit despite these exclusions. Specifically, it asked whether the plan could still be considered compliant with the requirement of being addressed to the “generality of employees” or a “homogeneous category,” as required to access the tax benefit.

Clarification by the Agency: objective criteria and consistency with company policies

In its response, the Revenue Agency referred to previous rulings, notably Resolution no. 3/E of 2002, Resolution no. 378/E of 2007, and INPS Circular no. 11 of January 22, 2001, reiterating that the “generality of employees” requirement can also be met in a substantive sense, i.e., referring to the group of permanent employees.

Alternatively, the benefit can be granted when shares are offered to a “homogeneous category” of employees, provided that this category is identified based on objective, consistent, and non-discriminatory criteria. The Agency stressed that the term “category” does not necessarily have to be interpreted in a legal sense but may refer to parameters relevant to the company’s organization, such as job level, duties performed, type of contract applied, or business area.

In this case, the exclusion of executives with strategic responsibilities and general managers was deemed legitimate, as these individuals are covered by a separate Long-Term Incentive Plan (LTI) already included in the company’s compensation policy. The Agency recognized that such an exclusion does not violate the principle of non-discrimination but fits within a coherent overall strategy aligned with the company’s organizational and management goals.

The Agency’s reply confirms, in line with previously expressed positions, that the tax relief for stock allocation can apply even if the plan does not involve the entire company population. What matters is that the offer targets a sufficiently broad and homogeneous group of employees, identified through transparent and verifiable criteria, without arbitrary or discriminatory exclusions.

Furthermore, the Agency reaffirmed that having separate plans tailored to the role and responsibilities of individual employees may justify differences in treatment, provided these differences serve the purpose of effective personnel management.

Ruling no. 147/E of June 4, 2025, thus confirms that, within the limits and conditions set by the TUIR, stock allocation plans may be selectively structured, provided that access is based on objective and justifiable criteria.

With Circular no. 96 of May 26, 2025, INPS summarizes the regulatory framework concerning absences from work for blood donation by employees and provides private employers with operational instructions for obtaining reimbursement of wages paid for the days or hours of leave taken by donor employees. The right to remuneration is recognized for absences due to blood donation and is also extended to employees deemed unfit to donate, limited to the time required to assess eligibility. In both cases, the remuneration is advanced by the employer, who can subsequently request reimbursement from INPS.

As clarified in the circular, reimbursement may occur through offsetting: the employer is required to complete the UNIEMENS flow, indicating the informational data related to the type of absence that occurred in the month of the event, as well as the data specifically referring to the offsetting of the advanced remuneration, in accordance with the operational instructions contained in the same circular. Alternatively, for employers who do not use the offsetting system, it is possible to submit a direct reimbursement request, exclusively online, no later than the end of the following month.

The circular states that the employer must retain the documentation related to the employee’s participation in the donation for ten years. In particular, for employees who made the donation, the medical certificates confirming the minimum amount of 250 grams of blood collected must be kept, in order to validate the right to the paid day off and corresponding remuneration, as well as the declaration issued by the donor confirming the actual use of the paid day and the gratuity of the donation. For employees deemed unfit, the certificate must be retained indicating the employee’s personal details, the tax code of the healthcare institution or association to which the collection unit belongs, the reason for the unfitness, and the time spent at the transfusion center.

With Circular No. 95 of May 26, 2025, INPS clarified the changes introduced by the Budget Law 2025 on parental leave compensation. As of January 1, 2025, employed parents will be eligible for three months of parental leave compensated at 80%. The measure is applicable to parents who end their maternity – or paternity – leave after December 31, 2024, or in case of birth or entry into the family on or after January 1, 2025.

What changes for the employees?

It is important to note that there is no increase in the total number of months of parental leave, but rather an increase in the allowance for three of the months already provided. The three months compensable at 80 percent can be taken by both parents, even in a split mode or entirely by only one, as long as it is within six years of the child’s life or within six years of the child’s entry into the family in the case of adoption or foster care, and in any case no later than the child’s coming of age.

What about for businesses?

The Circular provides operational instructions on the new Uniemens codes to be used as of January 2025 and clarifies the retroactive adjustment requirements for contribution reports to be made in July, August and September 2025 if the 30 percent allowance was initially applied.

The Wage Guarantee Element (so called EGR) is a one-off payment provided by several National Collective Labour Agreements as a form of compensation with an equalizing purpose. The employer pays the EGR to the employee, and it is subject to taxation and social security contributions under current legislation.

Generally, the payment of the EGR is conditional upon the absence of second-level bargaining that provides for performance-related bonuses, as well as the absence of additional economic treatments beyond those set by the collective agreement.

The amount, the recipients, the impact on contractual institutions such as additional monthly payments and severance pay, and the methods of payment of the EGR are defined autonomously by each individual NCLA.

Examples of NCLAs that include the EGR

NCLA for Graphic Arts and Publishing (Industry)

Since 2012, the NCLA for Graphic Arts and Publishing (Industry) has granted a gross annual amount of €250.00 (or less, to offset any additional treatments) to permanent employees who have been in service since January 1st of each year, work in companies without second-level bargaining, and have not received individual or collective additional economic benefits in the previous three years beyond those provided by the NCLA.
The EGR is paid with the April salary of the following year. In case of early termination of employment, the amount is granted in proportion to the full months of service worked.

NCLA for Telecommunications

Starting in 2011, the NCLA for the Telecommunications sector provides a gross annual EGR of €260 (or less—offsetting any additional economic treatments) to permanent employees working in companies without second-level bargaining on performance bonuses and who have not received additional individual or collective economic treatments beyond those set by the NCLA in the previous year.

The EGR is paid in a single installment in April each year.

At company level, the NCLA allows employers to extend the EGR to fixed-term employees with contracts longer than six months and to other forms of subordinate employment.
The amount is adjusted proportionally in cases where the employee worked less than a full year or has a part-time contract.

If the employment relationship ends before the payment month, the accrued EGR must be settled with the final pay.

This amount is excluded from the calculation base of the severance pay and is quantified by also considering its impact on direct and indirect wage elements, whether legally or contractually mandated, and therefore includes them.

NCLA for Clothing Industry

The NCLA for the Clothing Industry, with the aim of promoting company-level bargaining, grants an EGR of up to €350 gross to employees in companies without such bargaining and who do not receive other individual or collective economic treatments beyond those provided by the collective agreement.

This amount is paid with the January salary and is reduced accordingly by any additional individual treatments paid in the previous year.

Full payment is made to workers employed from January 1st to December 31st, while it is calculated in twelfths for those employed for only part of the year.

Proportional adjustment is also provided for part-time workers.

As of July 1, 2024, the National Collective Labor Agreement (NCLA) for the metalworking industry has officially entered the Extended validity regime, thereby maintaining the full validity of all contractual provisions.

What does this mean for companies?

All contractual provisions will continue to apply, including those related to corporate welfare. Specifically, by June 1, 2025, companies will be required to provide their employees with €200 in flexible benefits, as stipulated in Article 17 of the collective agreement. Employees may also choose to allocate these amounts to the Cometa Pension Fund or the Metasalute Healthcare Fund, according to each Fund’s rules.

Our team remains available to assist you with managing the related obligations.

1. NCLA Insurance Agencies – SNA – Production Bonus

In the June 2025 payslip, a production bonus will be paid to eligible employees, provided they are employed during the payment month.

2. NCLA Food Industry – Supplementary Health Care

Starting from 1 June 2025, employees may voluntarily contribute an additional €2 per month for 12 months to the health fund.

3. NCLA Breeders and Zootechnical Consortia – Seniority Increments

From June 2025, a gross monthly difference amount will be paid, calculated by comparing current seniority increments with those accrued up to 31 December 2024.

4. NCLA Autoferrotranvieri – Mobility – Compensation

By June 2025, companies must reach an agreement on working hours to balance productivity and work-life balance. A €40 gross monthly payment for 12 months depends on this agreement. Without it, only 50% will be paid from 1 January 2026. Alternatively, this amount can be converted into two paid leave days.

5. NCLA Footwear (Small Industry) – Wage Guarantee Element (WGE)

In June each year, the WGE is paid to employees employed from 1 January to 31 December of the previous year. It is proportionally reduced for shorter employment periods and adjusted for part-time workers.

6. NCLA Cement and Lime (Small Industry) – Wage Guarantee Element

In June, a €150 gross WGE is paid to employees in companies without second-level bargaining, employed on permanent contracts, fixed-term contracts longer than 6 months, or other subordinate work types, provided they were employed on 1 January and received only minimum NCLA compensation.

7. NCLA Cement and Lime (Industry) – Wage Guarantee Element

In June, a €170 gross annual WGE is paid to permanent employees in companies without second-level bargaining, who received only NCLA compensation in the previous year. The amount is reduced if additional compensation was received.

8. NCLA Ceramics (Industry) – Wage Guarantee Element

A €100 gross WGE is paid in June to permanent employees employed on 1 January in companies without company or territorial bargaining, who received only NCLA compensation in the past four years. The amount is reduced if additional compensation was received.

9. NCLA Social Cooperatives – Holiday Bonus

In June, the fourteenth monthly salary is paid, equivalent to half a month’s salary as of the payment month. For employees who started or ended employment during the year, the amount is prorated based on months worked, counting any period over 15 days as a full month.

10. NCLA Managers of Rural and Artisan Banks – Disability and Handicap

By June, an annual €1,500 contribution is paid for each dependent family member with a certified disability.

11. NCLA Journalists (Local Broadcasting) – Editorial Allowance

By 30 June, tele-radio journalists receive a €258.23 editorial allowance, which is excluded from other contractual compensation calculations except for severance pay.

12. NCLA Stone Industry (Small Industry) – Wage Guarantee Element

In June 2025, a €150 gross WGE is paid to permanent employees, fixed-term employees with contracts longer than 6 months, and other subordinate workers employed on 1 January in companies without second-level bargaining, who received only NCLA compensation.

13. NCLA Stone Industry (Industry) – Wage Guarantee Element

In June, a €210 gross annual WGE is paid.

14. NCLA Metalworkers – FEDERDAT – Wage Guarantee Element

In June 2025, a €190 gross annual WGE is paid in a single installment, prorated based on months worked in the previous year.

15. NCLA Metalworkers (Cooperatives) – Wage Guarantee Element

In June, a €485 gross annual WGE is paid to employees in cooperatives without second-level bargaining, who received only NCLA compensation in 2024. The amount is reduced if additional compensation was received.

16. NCLA Metalworkers (Industry) – Wage Guarantee Element

In June, a €485 gross annual WGE is paid to employees employed on 1 January 2025 in companies without second-level bargaining, who received only NCLA compensation in 2024. The amount is reduced if additional compensation was received.

17. NCLA Metalworkers (Cooperatives) – Compensation

By 1 June each year, companies must provide employees with welfare tools worth €200, to be used by 31 May of the following year.

18. NCLA Metalworkers (Small Industry) – CONFAPI – Wage Guarantee Element

In June, a €485 gross annual WGE is paid to employees employed on 1 January 2025 in companies without second-level bargaining, who received only NCLA compensation in 2024. The amount is reduced if additional compensation was received.

19. NCLA Metalworkers (Small Industry) – Wage Guarantee Element

Employees employed on 1 January in companies without second-level bargaining, who received only NCLA compensation in 2024, receive a €485 gross annual WGE in June. The amount is reduced if additional compensation was received.

20. NCLA Metalworkers (Small Industry) – CONFAPI – Training and Professional Development

Employees who did not complete the 24 hours of continuous training by 31 December 2024 may do so by 30 June 2025. Unused training hours after this date will expire.

21. NCLA Metalworkers (Industry) – Welfare

By 1 June, companies must provide employees with welfare tools worth €200, to be used by 31 May of the following year.

22. NCLA Urban Waste Collection (Private Companies) – Compensation

To ensure clarity on costs and contractual treatments, a methodology linked to actual inflation has been defined. In June 2025, based on inflation variations compared to the forecast of 3.44%, a €15 adjustment to base salaries may be applied. The adjustment occurs only if inflation exceeds the forecast by at least 0.5%; otherwise, the amount remains allocated to the performance bonus or is not consolidated.

23. NCLA Goldsmiths and Silversmiths (Industry) – Wage Guarantee Element

In June, a €250 gross annual WGE is paid to employees employed on 1 January in companies without second-level bargaining, who received only NCLA compensation in 2024. The amount is reduced if additional compensation was received.

24. NCLA Funeral Services – ASNAF – Wage Guarantee Element

In June, employees employed on 1 January 2025 in companies without second-level bargaining receive an additional monthly salary between €1,000 and €1,800, depending on their job category.

25. NCLA Auxiliary Services (ANPIT – CISAL) – Compensation

Employees employed (regardless of category or contract type, provided they work at least 20 hours per week) who have passed the probation period receive welfare amounts between €250 and €1,000, with 50% paid in June 2025 and the remaining 50% in December 2025. These amounts must be used within 12 months of being made available.

26. NCLA Textiles (Small Industry) – UNIONTESSILE – Wage Guarantee Element

In June, a €240 gross WGE is paid. The amount is comprehensive of all legal and contractual entitlements, including severance pay, and is paid in full to employees employed from 1 January 2024. It is prorated for others, considering any period over 15 days as a full month, and adjusted for part-time workers.

27. NCLA Freight Transport and Shipping – CONFETRA – Working Hours

For traveling personnel in Qualification 1 with G-H pay parameters, it is possible to deviate from the standard 39-hour workweek by applying a discontinuous regime through company agreements with trade unions. The discontinuous workweek limit reduces from 44 hours to 43 hours starting 1 June 2025, and to 42 hours from 1 January 2026. Existing agreements remain in effect until the new limits are implemented.

Minimum Wage Increases from 1 June 2025

Effective 1 June 2025, minimum wage increases are scheduled for the following NCLAs:

• NCLA Animation, Tourist Entertainment, Babysitting – FEDERTERZIARIO – UGL;
• NCLA Agriculture (Third-Party Services);
• NCLA Hotels – CONFCOMMERCIO;
• NCLA Campsites and Tourist Villages – CONFCOMMERCIO;
• NCLA Chemical and Pharmaceutical (Industry);
• NCLA Credit Sector;
• NCLA Metalworkers (Cooperatives);
• NCLA Metalworkers (Industry);
• NCLA Metalworkers (Small Industry)
• NCLA Metalworkers (Small Industry) – CONFIMI;
• NCLA Pens, Pencils, and Brushes – (Industry);
• NCLA Public Establishments – CONFCOMMERCIO;
• NCLA Public Establishments, Catering, and Tourism;
• NCLA Beach Resorts – CONFCOMMERCIO;
• NCLA Thermal Spas;
• NCLA Tourism – CONFESERCENTI;
• NCLA Tourism – CONFCOMMERCIO;
• NCLA Tourism – FEDERDAT;
• NCLA Tourism (Industry);
• NCLA Private Security (Cooperatives);
• NCLA Private Security (Institutes).

One-off Payments for June 2025

For the month of June 2025, the following NCLAs provide for the disbursement of one-off payments (“Una Tantum”):

• NCLA Paper Industry (Small Industry);
• NCLA Executives (Small Industry);
• NCLA Graphic and Publishing Sector (Small Industry);
• NCLA Tourism (Industry).

NCLA Expirations – June 2025

The following NCLAs are set to expire in June 2025:

• NCLA Mooring Operators and Boatmen;
• NCLA Cleaning Services (CONFLAVORO);
• NCLA Professional Firms – Condominium Administrators.

In recent note no. 2504 dated April 10, 2025, the Ministry of Labour and Social Policies, in response to a request for clarification from the National Council of the Labour Consultants’ Order (CNO), provided further details regarding Circular no. 6/2025. This circular contains initial operational guidelines related to the innovations introduced by the “Labour-Linked Act” (Law no. 203/2024), including the procedure for “resignation by conclusive conduct.”

The New Procedure and Ministerial Clarifications

According to Article 19 of Law no. 203/2024, in cases of “unjustified absence of the employee extending beyond the period established by the applicable national collective labour agreement (NCLA) or, if not provided, exceeding fifteen days”, and where the employee has neither submitted an explanation nor filed formal telematic resignation, the employer may activate the resignation by conclusive conduct procedure by notifying the local Labour Inspectorate. The employment relationship will then be considered terminated on the initiative of the worker.

The law thus explicitly acknowledges that an employment relationship can be terminated through what is known as resignation by conclusive conduct (or de facto resignation), allowing the employer to interpret the worker’s unexcused absence over a certain period as an intent to terminate the employment.

Communication to the Labour Inspectorate, which initiates this process, can only be made after a suitable period of unexcused absence, defined by the collective agreements or, in their absence, longer than 15 days.

In Circular no. 6/2025, the Ministry clarified that the 15-day period stipulated by law serves as a minimum legal threshold. Once this period has elapsed, the employer may notify the territorial Labour Inspectorate. If a different period is established by a collective agreement, it will apply only if it is longer than the legal minimum. If it is shorter, the legal period of 15 days must be observed, following the general principle that contractual autonomy may only modify legal provisions in melius (i.e., to the benefit of the worker).

The Ministry also introduced a clarification not explicitly stated in the law: the employer may initiate the resignation by conclusive conduct procedure not before the 16th day of unexcused absence, with the option to file the communication to the Inspectorate at a later time.

Likewise, the 15-day minimum must also be respected for sending the UNILAV notice of employment termination. The communication to the Inspectorate marks the start (dies a quo) of the 5-day period allowed for submitting the mandatory notice to the public employment service.

It is important to note, as stated in the second part of Article 19 of Law no. 203/2024, that once the procedure is activated, the Labour Inspectorate may verify the accuracy of the report, and the worker may demonstrate either that they provided a valid justification or that they were unable to do so due to force majeure or reasons attributable to the employer.

Note no. 2504 of April 10, 2025

Following clarification requests from the CNO, the Ministry addressed further details in Note no. 2504 of April 10.

Firstly, the Ministry clarified the legal status of the 15-day threshold for unjustified absence: while the law does not establish this period as mandatory and unalterable, it serves as a fallback measure in the absence of contractual provisions. Therefore, collective agreements could, in principle, define shorter periods.

However, the Ministry, while acknowledging the residual nature of the legal term, expressed caution, interpreting the phrase used by the legislator (“in the absence of a contractual provision, exceeding fifteen days”) as a sign that shorter durations should not be used, out of prudence. Thus, even though the law does not explicitly forbid shorter timeframes, it is considered that no interpretation should worsen the worker’s legal position, in order to prevent potential abuse or distortion of the employment relationship.

Additional Interpretative Clarifications

In response to further queries by the CNO, the Ministry also clarified what happens in the following cases:

1. If the Labour Inspectorate, after verifying the facts, finds the legal conditions unmet, the employer must reinstate the employment relationship. If the employer disagrees with the findings or considers the employee’s explanations insufficient, there will be no automatic reinstatement—the decision remains with the employer.
2. If the employee submits their resignation (even for just cause) after the procedure has started but before it takes effect, such resignation will take precedence over the resignation by conclusive conduct. In the case of resignation for just cause, the reasons will be assessed in the appropriate venues.