The issue of pay transparency has returned to the forefront of labor law debate with the adoption of Legislative Decree no. 96/2026, implementing Directive (EU) 2023/970 and introducing a significant shift in how companies manage and communicate remuneration policies. The reform, which entered into force on 7 June 2026, fits within a broader European strategy aimed at strengthening the principle of equal treatment, with a particular focus on making the criteria underlying pay determination and career progression more transparent. Its scope of application is notably broad: the new rules apply to all employment relationships, including fixed-term, part-time, and executive contracts, and extend even to job applicants during the recruitment phase. Domestic and on-call work relationships, however, remain excluded. One of the most innovative aspects concerns the reinforcement of employees’ right to information. Workers are now entitled to access average pay data broken down by gender and by comparable categories, subject to specific safeguards and limitations on use. From an organizational standpoint, the decree also introduces periodic reporting obligations on the gender pay gap for companies exceeding certain size thresholds, requiring the collection and disclosure of detailed and verified data. Particularly noteworthy is the requirement to engage with trade unions: where unjustified pay disparities are identified, employers must initiate a joint assessment process aimed at identifying and implementing corrective measures. Overall, the new regulatory framework requires companies to rethink their internal pay structures and processes, marking a transition from opacity toward a model based on transparency, accountability, and organizational responsibility.
2026 - Morri Rossetti
