Prepared by Marzio Scaglioni and Silvia Capobianco

As of 1 December 2026, employers intending to benefit from incentives and social security contribution relief for new hires will be required to publish open positions on the SIISL (Information System for Social and Employment Inclusion). Failure to publish the vacancy will make it impossible to access the social security contribution relief available for incentivized hires. The new requirement was announced by Andrea Piscopo, Director General for Innovation at the Italian Ministry of Labour, during the National Convention of Labour Consultants, “Towards the Profession of the Future: Role, Skills and Vision”, and was subsequently formalized through the signing by the Minister of Labour and Social Policies of Decree No. 134 of 5 October 2026, implementing Article 14, paragraphs 1 to 4, of Decree-Law No. 159/2025, as converted into Law No. 198/2025, thereby confirming the end of the transitional period currently in force.

SIISL is the national digital platform managed jointly by the Ministry of Labour and Social Policies and INPS and constitutes the public infrastructure through which active Labour market policies, training pathways and tools matching labor supply and demand are integrated. Established to promote social and employment inclusion, the system is now also assuming a central role in employment incentive measures, becoming a mandatory step for companies intending to benefit from social security contribution relief. 

The pilot phase, launched on 1 April 2026, allowed employers to publish job offers on the portal on a voluntary basis. From 1 December 2026, this option will become an actual requirement for access to hiring incentives. 

The measure forms part of a broader process aimed at strengthening active labor market policy tools and monitoring employment incentives. As provided for by Article 14 of Decree-Law No. 159/2025, the objective is to promote transparency in the labor market, ensure equal opportunities to access job offers, strengthen health and safety protection in the workplace, and monitor more effectively the impact of public measures supporting employment. In this context, SIISL becomes the point of connection between companies’ recruitment needs and the control and monitoring objectives pursued by public authorities. 

Once fully operational, based on the procedures to be defined by the implementing ministerial decree provided for under Article 14, paragraph 5, of Decree-Law No. 159/2025, the vacancy must be published before the hire; a unique link between the vacancy and the Mandatory Employment Notification must be ensured; and this association must also be tracked in the UniEmens filings by correctly linking the id_vacancy to the tax identification number of the hired employee. This system will enable the competent authorities to verify that the conditions required to benefit from social security contribution incentives are met and to monitor the effectiveness of public employment support measures. 

In preparing job vacancies to be published on the SIISL platform, particular attention should also be paid to pay transparency requirements. Legislative Decree No. 96 of 7 May 2026, implementing Directive (EU) 2023/970, grants candidates the right to receive information on the initial remuneration or the relevant salary range, determined on the basis of objective and gender-neutral criteria, either in the job advertisement itself or, in any event, prior to the interview.

Based on the information currently available, the requirement is generally expected to apply to social security contribution incentives and employment bonuses financed through public resources, thereby reinforcing the principle of transparency in the use of incentives aimed at promoting employment. 

An important exception concerns the incentive granted for the conversion into open-ended employment of fixed-term employment relationships involving workers under the age of 35 in their first stable employment. In this respect, INPS Circular No. 72/2026 clarified that the requirement to publish the vacancy on SIISL does not apply, since the measure supports the permanent employment of a worker already employed by the company rather than a hire resulting from the search for a new resource on the labor market. 

The new provision introduces an additional formal requirement for incentivized hires and will require particular attention from HR and Payroll functions and labor consultants. Companies wishing to continue benefiting from social security contribution relief must therefore promptly update their internal procedures, ensuring that vacancies are correctly published on SIISL before the employment relationship is established. Otherwise, even where all other statutory requirements are met, the social security contribution relief may not be granted.