Last Updated on October 14, 2025
Publication of Decree Law no. 146 of 3 October 2025, introducing a series of amendments to the Consolidated Immigration Law (Italian Legislative Decree 286 of July 25, 1998), with the aim of simplifying entry procedures for work purposes, strengthening authenticity and transparency controls and protecting certain categories of permits.
The new measure continues and strengthens some of the measures already included in Italian Decree Law no. 145/2024 (see our newsflash “New provisions for the entry of foreign works and the fight against the gangmaster system” of 15 October 2024) and aims to make management of the legal entry of foreign workers more efficient and transparent.
Application for Work Authorisation
In line with the experimental provisions for 2025, the following have been made structural in the procedure for submitting applications for authorisation for subordinate employment, including seasonal work:
- the mechanism of pre-filling applications: employers can pre-fill application forms on a Ministry of the Interior portal before the date set for submission (so-called “click day“). The pre-filled forms will then be checked for accuracy by the administrations;
- a maximum limit of 3 requests per year for employers submitting applications as private users. This limit does not apply to applications submitted by union organisations or qualified professionals, who must nevertheless ensure that the number of applications is proportionate to the company’s turnover or revenue.
Issue of work authorisation
The Decree has significant impact on the procedures for obtaining authorisation, changing the deadline for its issue, which now starts from the moment the request is allocated to the entry quota, rather than from when the application is submitted. In this way, timing of the procedure is linked to the actual availability of a quota, effectively lengthening the time required to process applications.
Mandatory accuracy checks have also been introduced for statements by employers, host organisations and research institutes.
Working while awaiting a permit
The right of foreign nationals to reside legally in Italy and to work temporarily – already provided for in cases of “waiting” for residence permits to be issued or renewed – has now also been extended to include conversion.
This ensures greater legal certainty for both workers and businesses during long bureaucratic waiting times, ensuring full continuity of business.
Permits for special cases and Inclusion Allowance
The duration of the special residence permit issued to foreigners for reasons of social protection, violence and labour exploitation is extended from six months to one year, and is renewable, in order to facilitate the social and professional integration of victims.
In addition, holders of such permits are eligible for the Inclusion Allowance, as an exception to the long-term residence requirements normally required by law.
“Out-of-quota” Entries
Foreign workers to be employed in the family or social-healthcare sector in favour of people with disabilities or the “elderly” are still classed as a type of entry over and above the quotas also for the years 2026, 2027 and 2028.
Fighting modern slavery
The Decree strengthens the fight against modern slavery and to the labour exploitation by expanding the composition of the existing Operational Committee in the agricultural sector and the range of individuals who can access the funding from the Fund against the illegal recruitment of foreign labour.
We await the Government’s definition of the entry flows for work for the three-year period 2026-2028.
Our Global Mobility team is at your disposal for any support or clarification you may need.
For further information: comunicazione@toffolettodeluca.it
