PUBLIC-HEALTH EMPLOYMENT UPDATE | Law no. 18/2022
In February 2022, Parliament converted Decree-Law no. 1/2022, which had introduced compulsory vaccination for persons aged 50 and over and related workplace-access requirements.
Workers in the relevant age group needed the enhanced Green Pass to access the workplace during the statutory period. Employers were responsible for controls, while absence and pay consequences followed the emergency legislation. The rules did not authorise unrestricted collection of vaccination records.
International employers face the difficult combination of rapidly changing national rules, strict privacy requirements and global return-to-office policies. A manager’s request for medical proof could go beyond what the Italian verification process permits
Employers should have used designated checking procedures, minimised stored information and kept access control separate from any later conduct process. Disciplinary action required its own proportionality and procedural assessment rather than an automatic reaction to health status.