COMPLIANCE UPDATE | Biennial workforce report for 2024–2025
In February 2026, the Ministry of Labour opened the reporting process for the biennial report on the employment situation of male and female personnel for 2024–2025 (Italian Ministry of Labour, notice of 24 February 2026) pursuant to Article 46 of Legislative Decree no. 198/2006, the so-called “Equal Opportunities Code”. Employers with more than 50 employees are required to file the report, while smaller employers may do so voluntarily. The deadline was subsequently moved to 15 May 2026.
The report collects information on workforce composition, recruitment, professional categories, promotions, training, remuneration and terminations. It is therefore not simply an administrative headcount exercise. When read across different categories, the data may reveal patterns that deserve an explanation, including concentration of one gender in lower grades, differences in access to variable pay or a disproportionate impact of exits and restructuring measures.
For multinational employers, preparation may be more difficult than expected. Global HR systems, Italian payroll data and local organisational charts do not always use the same job categories or reporting periods. Employees on leave, executives, part-time workers and personnel who changed status during the two-year period must be treated consistently. Last-minute extraction increases the risk of internal discrepancies or figures that cannot later be explained.
The report is also connected with Italy’s gender-equality framework and may be relevant to certification, public procurement and access to certain benefits. Trade-union representatives and equality bodies may obtain access in accordance with the applicable rules. An inaccurate filing can therefore create both regulatory and litigation risk.
Employers should use the reporting exercise as a controlled equal-pay and progression review. Before filing, HR, payroll and legal teams should reconcile the data, identify unexplained differences and record the legitimate factors behind them. Where a disparity cannot be justified, the safer course is to understand and address it rather than assume that an aggregated report will attract no attention.