OFFICIAL INTERPRETATION | Ministry of Labour Interpello no. 1/2025
In Advance Ruling (“Interpello”) no. 1/2025, issued on 18 September, the Italian Ministry of Labour addressed the application of the new State-Regions training agreement to workers who do not ordinarily perform production tasks.
The clarification confirmed a practical principle: training follows the risks emerging from the employer’s assessment. Workers who genuinely do not enter production departments may follow the low-risk route, but a contractual title or organisational label cannot override actual exposure.
This matters in international businesses where engineers, managers or office employees occasionally visit warehouses, laboratories or construction areas. A central HR system may classify them as office staff even though their Italian activities require additional instruction.
Employers should compare job descriptions, access permissions and travel patterns with the risk assessment and training matrix. Occasional operational access should be planned, and local managers should not improvise site visits for personnel whose training is incomplete.