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COVID-19 update

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On 16 September 2021, the Italian Government approved the decree that imposes, starting from 15 October 2021, the so-called “green pass” as a mandatory requirement in order to access to the workplace.

Please mind that, as of today, we do not have the final version of the decree but only a draft. Therefore, some changes may take place before it becomes effective.

We will keep you posted as soon as the final version of the decree will be published (probably early this week).

In the meantime, please find below a preliminary overview of the content of the decree:

  • from 15 October 2021 to 31 December 2021, any individual working in the private sector is required to possess and, if required, show a valid COVID-19 green certificate (so-called green pass). Such obligation also applies to all the individuals who enter workplaces in the private sector to carry out work, even under external contracts;
  • the employers are required to implement internal procedures regulating how the checks of the green passes will be carried out and the subjects who will perform such checks. Specific sanctions (administrative sanctions and/or suspension of the activity) are provided for the employers that fail to comply with such obligation.
  • the employees without a green pass will not be allowed to access the workplace and can be suspended from work without payment of the salary. No disciplinary sanctions can be applied to such employees. On the contrary, an employee without a valid green pass who accesses to the workplace can be subject to disciplinary sanctions.


For the sake of completeness, the green pass is released further to either:


  • the completion of the vaccination cycle (green pass valid for 9 months);
  • the recovery from the virus (validity of 6 months from the recovery);
  • the negative result of a molecular or rapid antigen test (validity of 48 hours from the test - note: an extension to 72 hours is likely);
  • the recovery from the virus after the administration of the first dose of vaccine or at the end of the vaccination cycle (validity of 12 months from the recovery).


We remain available should you need any clarification and we will keep you posted once the final version of the decree will be published in the Italian Official Gazette.


Labour team





This information is for guidance purposes only and should not be regarded as a substitute for taking legal advice. Please refer to the full terms and conditions on our website.

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