PUBLIC-HEALTH EMPLOYMENT UPDATE | Decree-Law no. 1/2022
Decree-Law no. 1 was adopted on 7 January 2022 during the Omicron wave and extended Italy’s vaccination strategy to all persons aged 50 and over.
For work access, the legislation requires the enhanced “Green Pass” for covered workers during the specified period. Employers have to organise checks and apply statutory consequences, but they do not become entitled to collect full medical histories or create their own vaccination database.
Understandably, foreign employees wanted one return-to-office rule across Europe. Italian emergency law changed frequently and used specific national certificates and age-based requirements, making a uniform policy legally unreliable.
The Italian entity should nominate checkers, provide privacy instructions and document only what the law required. Managers should be told not to ask employees for diagnostic or vaccination details outside the official verification process.