PRIORITY 1
1. Job postings & pre-employment job advertisements
Content: indication of the starting compensation or the relevant compensation range to be assigned to the position (e.g., annual gross salary, including any individual salary supplement and variable compensation, if applicable), based on objective and gender-neutral criteria, as well as the relevant provisions of the applicable collective bargaining agreement (CCNL) concerning the position.
Form: drafting of the text using gender-neutral wording with respect to both the role and the compensation offered. It is prohibited to request, either directly or indirectly, the candidate’s salary history.
2. Transparency of information
Content: making accessible to employees the criteria used to determine pay levels and salary progression (companies with more than 50 employees).
Form: updating (if necessary) the information notice pursuant to the Transparency Decree (Legislative Decree No. 152/1997) published on the company intranet or provided to employees.
3. Information on pay levels
Content: information on average pay levels, broken down by gender, for categories of workers performing the same work or work of equal value.
Form 1: Annual notice to all employees of their right to receive such information and of the procedures for exercising that right.
Form 2: In the event of a written request from an employee (including through trade unions and Equality Bodies), which may be submitted once per year, the company must respond within 2 months. The obligation may also be fulfilled by publishing the information on the company intranet (not necessarily exhaustively).
For all activities
Measures must be implemented in a manner accessible to persons with disabilities and taking into account the specific needs arising from the particular type of disability.
PRIORITY 2
(companies with more than 100 employees)
Content: communication of data relating to:
a) the gender pay gap;
b) the gender pay gap in complementary or variable components of remuneration;
c) the median gender pay gap;
d) the median gender pay gap in complementary or variable components of remuneration;
e) the percentage of female and male employees receiving complementary or variable components of remuneration;
f) the percentage of female and male employees in each pay quartile;
g) the gender pay gap among workers by category of workers, broken down by basic salary or wages and by complementary or variable components of remuneration.
Companies applying a unified group-wide compensation policy may provide such information by aggregating data at national level.
Form 1: collection and submission of the relevant data to the monitoring body (within the Ministry of Labour) by the following deadlines:
- companies with more than 249 employees: by 7 June 2027
- companies with 150–249 employees: by 7 June 2027, and every 3 years thereafter
- companies with 110–149 employees: by 7 June 2031, and every 3 years thereafter
Form 2: information regarding the gender pay gap among workers by category, broken down by basic salary or wages and by complementary or variable components of remuneration, must be made accessible to employees, trade unions and, upon request, to the competent authorities, which may require employers to provide clarifications. Employers must respond within 60 days.
