The 14 October deadline requires companies with more than 50 employees to submit the two-year personnel report for 2020-2021, governed by Article 46 of Legislative Decree 198/2006. This obligation was reformulated by law no. 162/2021. This was issued to continue the gender equality process – a European objective included in the NRP.
The changes concerning the Report involve:
– lowering of threshold from 100 to 50 employees for companies subject to the obligation;
– more specific data to be reported.
The 29 March 2022 interministerial decree specified that, when companies have several production units, the report must include personnel of all production units and individual production units with more than 50 employees. For companies below the size threshold the report submission is optional.
The document must contain personnel remuneration data, including any additional components, such as allowances, bonuses and fringe benefits. The provision’s goal is to overcome one of the main obstacles to combat the gender pay gap. Under the previous wording, the personnel report data was excessively aggregated and compromised the transparency of remuneration systems and criteria applied to assess individual professional expertise. The penalties for failure to submit the report remain unchanged. These can include the suspension for 12 months of the contribution benefits in non-compliance cases. Penalties of up to € 5,000 are applied to incomplete or false reports.
Law no. 162/2021 introduced Article 46 bis to the Equal Opportunities Code, which sets the rules for companies to obtain “Gender Equality Certification.” This certifies the policies and measures adopted by employers to reduce the gender gap.
The reference values and parameters to obtain certification are identified in the Uni Pdr 125 2022 standard procedure, issued on 16 March 2022. This document, called “Uni/Pdr Reference Standard Procedure 125:2022 containing the criteria, parameters and technical guidelines to obtain gender certification” was issued by the Uni standardisation body and resulted from a technical round table with the relevant ministries.
Continue reading the full version published in Il Quotidiano del Lavoro of Il Sole 24 Ore.
