Introduction
Decree-Law No. 62 of April 30, 2026 (the “Decree”), entitled “Urgent provisions on fair wages, incentives to employment, and against digital illegal hiring practices” addresses one of the most debated issues in the Italian and European labor law landscape: the definition of fair and adequate remuneration. The measure follows in the footsteps of Directive (EU) 2022/2041 on adequate minimum wages in the European Union and expressly references, among its underlying principles, Articles 35, 36, and 39 of the Constitution, as well as Directive (EU) 2023/970 on pay transparency and Directive (EU) 2024/2831 on work via digital platforms.
Key changes
Following are the main changes introduced by the Decree:
Fair wages
The most significant provision is provided by Article 7, which introduces the concept of a “fair wage”, anchoring the remuneration benchmark referred to in Article 36 of the Constitution to collective bargaining agreements and, specifically, to the national collective bargaining agreements (NCBAs) entered into by the trade unions that are comparatively more representative at the national level.
To address the issue of so-called wage dumping, the provision prohibits collective agreements signed by different organizations from providing for remuneration lower than that of the sector’s relevant NCBA and, for sectors without contractual coverage, sets as the minimum threshold the remuneration provided by the NCBA whose scope of application is most closely connected to the employer’s business activity.
Incentives to employment
By repealing the provisions introduced at the end of 2025, the legislator intervenes on the system of social security contribution exemptions by introducing:
The “Women’s Bonus 2026”
The “Women’s Bonus 2026,” i.e., a 100% exemption from social security contributions, for a maximum of 24 months, for employers who hire on a permanent basis women who have either been without regular paid employment for at least 24 months, or who have been without regular paid employment for at least 12 months and who belong to one of the categories referred to in letters b) through g) of the definition of “disadvantaged worker” referred to in Article 2 of Commission Regulation (EU) No. 651/2014 of June 17, 2014.
In each case up to a limit of EUR650 per month.
(Increased to EUR800 for female workers residing in the Special Economic Zone for Southern Italy (Single SEZ)).
The “Youth Bonus 2026”
The “Youth Bonus 2026,” namely a 100% exemption, for a maximum of 24 months, for the permanent hiring of non-executive employees under 35 who have either been without regular paid employment for at least 24 months, or who have been without regular paid employment for at least 12 months and who belong to one of the categories referred to in letters b) through g) of the definition of “disadvantaged worker” referred to in Article 2 of Commission Regulation (EU) No. 651/2014 of June 17, 2014.
In each case up to a limit of EUR500 per month.
(EUR650 for workers hired at locations or production units situated in certain regions of the Single SEZ).
The “SEZ 2026 Bonus”
The “SEZ 2026 Bonus,” which is reserved, for a maximum of 24 months, for employers with no more than ten employees who hire, on a permanent basis within the Single SEZ, individuals over 35 who have been unemployed for at least 24 months.
With a 100% exemption up to a limit of EUR650 per month.
The “Incentive for permanent hiring”
The “Incentive for permanent hiring,” a 100% exemption for the conversion to permanent agreements , during the period from August 1–December 31, 2026, of fixed-term agreements with a total duration not exceeding 12 months, established by April 30, 2026, up to a limit of EUR500 per month.
This last exemption applies to workers under 35 who have never been employed on a permanent basis, excluding executives.
A key element is that access to the above social security contribution exemptions is contingent upon the individual remuneration paid to the worker not being lower than the “fair wage” determined in accordance with Article 7 of the Decree. This conditional mechanism serves as a concrete measure against wage dumping.
Wage monitoring and institutional infrastructure
The Decree also establishes a highly complex institutional infrastructure for monitoring and collecting wage data. Specifically, Article 8 provides that the CNEL, INPS, ISTAT, INAPP, the National Labor Inspectorate, and other entities shall collaborate to collect and share, in an integrated and interoperable manner, wage data disaggregated by gender, age, disability, economic sector, and company size.
The CNEL will be tasked with drafting, at least annually, a national report on wages broken down by homogeneous economic sectors, to be submitted to Parliament. In addition, an administrative archive of company-level and regional collective agreements is to be established within 30 days of the Decree’s conversion into law.
With a view to greater transparency, the legislator has also provided, effective upon the Decree’s conversion into law, for the obligation to indicate, with reference to job postings published on the SIISL platform, the applicable NCBA—identified by the unique alphanumeric code assigned pursuant to Article 16-quater of Decree-Law No. 76 of July 16, 2020, converted, with amendments, by Law No. 120 of September 11, 2020—and the compensation corresponding to the job classification and contractual level.
Measures against digital illegal hiring practices and to protect platform workers
The Decree also introduces measures aimed at protecting platform workers.
Article 12 establishes the principle that substance prevails over form in the classification of the employment relationship: what matters are the actual conditions under which the work is performed, regardless of the formal classification assigned by the parties.
Furthermore, the legislator expressly provides that when there are indications of control or direction—including through algorithmic management —the relationship must be presumed to be of a subordinate nature, unless proven otherwise.
Article 14, on the other hand, imposes obligations on digital platforms to inform workers about the automated or algorithmic systems used for assigning tasks, determining compensation, evaluating performance, and suspending or terminating access to the platform, as well as the worker’s right to obtain an intelligible explanation of automated decisions and a review through human intervention.
Furthermore, Article 15 of the Decree strengthens protections for delivery riders by introducing the requirement to access the platform via SPID, CIE, or CNS, or through an account linked to a single tax identification number with multi-factor authentication, and prohibiting the transfer of the account to third parties.
Finally, the Decree also requires the principle to maintain a single employment ledger for workers using the platform, effective July 1, 2026, as well as the obligation to provide basic training through the SIISL platform within 30 days of the first work assignment.
Conclusions
Although it does not introduce a statutory minimum wage —effectively disregarding the expectations of those who had hoped for its establishment —the Decree marks a paradigm shift.
By expressly making access to the social security contribution exemptions provided for therein contingent upon the individual compensation paid to the worker being no lower than the overall remuneration determined pursuant to Article 7, the legislator seeks to ensure that it is not mere hiring that is incentivized, but rather hiring which guarantees workers a level of remuneration consistent with the parameters established by law.
On an operational level, the advice for employers is to immediately begin adapting their internal processes: from identifying the correct applicable NCBA, to aligning individual compensation with the parameters of Article 7, to fulfilling the new transparency obligations.
Finally, it is recommended that businesses pay particular attention to the numerous implementing decrees still required for the new regulatory framework to become fully operational, as it will ultimately be the conversion into law—and above all administrative and judicial practice—that will reveal the true scope of this measure which, while not establishing a legal minimum wage, aims to reshape the relationship between collective bargaining agreements, incentives, and wage protection.
