The Ministry of Labour, with memorandum No. 10/2011, gave a broad interpretation of the provisions of the so called “Collegato Lavoro” (Law No. 183/2010) concerning the sanctions application. The Ministry clarified that the 60-day term provided for by Article 16 of Law No. 689/1981 (for the payment of reduced sanctions) is applied to the entire verification proceedings, apart from the ascertained violations. Should the inspection personnel have warned the transgressor for some breaches and have imposed the sanction for the other defaults, the reduced payment could be effected within 105 days from the notice to pay. In fact, it is necessary to add, to the 60 days required by Law No. 689/1981, the 45 days provided for by the “Collegato Lavoro” in order to comply with the notice to pay.
