🇮🇹 Italy: small-employer progression exemption and existing discrimination sanctions clarified

Our Italy review corrects progression-criteria coverage and adds the decree’s express link to existing benefit and public-contract sanctions. It also removes an unsupported calendar-year assumption from comparator-pay information.

Article6(3) exempts employers below50 employees from disclosing progression criteria; pay-setting criteria and information rights have separate rules. The annual-gross/hourly pay definition does not establish the comparator-information observation year or hours divisor. Article9(3) allows national group aggregation only where a unitary group pay policy makes the data more reliable. Article13 applies Equal Opportunities Code Article41: established discrimination can lead to benefit revocation and, in serious or repeated cases, exclusion from future benefits or public contracts for up to two years, subject to the conciliation exception. The six-month uncorrected-gap condition triggers JPA; corrective measures after assessment are required within a reasonable period.

Apply the under50 progression exemption carefully and keep other transparency duties in place. Do not hard-code an unverified information year or calculation method. Review discrimination and procurement exposure, retain separate legacy biennial-report controls, and check final technical rules before configuring new reporting submissions.