EU LEGISLATIVE UPDATE | Directive (EU) 2022/2041
Directive (EU) 2022/2041 entered into force on 14 November 2022 after publication in the Official Journal.
The Directive seeks adequate minimum wages and stronger collective bargaining while respecting national wage-setting systems. It does not oblige a Member State whose wages are set through collective agreements to create a statutory minimum. Italy therefore retained its distinctive framework centred on CCNLs and Article 36 of the Constitution.
Foreign businesses often ask for a single Italian minimum-wage number. The answer depends on the applicable collective agreement, classification and total mandatory package. A low-cost agreement may also be tested judicially against constitutional adequacy.
Before hiring, employers should identify a representative CCNL that fits the activity, classify the role correctly and review all mandatory salary elements. Minimum-pay compliance is a legal architecture question, not merely a payroll threshold.