Edited by Francesca Tironi, Federica Carelli
At the end of a pilot phase launched on 11 April 2025, the CNEL Information Commission unanimously approved, on 20 April 2026, the new organisational framework of the National Archive of Collective Agreements and Bargaining Arrangements. The reform is, first and foremost, conceptual in nature, as it overcomes the previous logic of mere filing, which allowed any agreement to be registered regardless of its actual application within the productive system, in favour of a criterion based on substantive relevance, linked to the contract’s real diffusion and effective presence in the labour market.
The relevant benchmark therefore becomes the employment data derived from INPS UniEmens flows. Classification is no longer based on declarations made by the parties, but rather on verifiable administrative information, with evident benefits in terms of transparency and data quality.
The new access thresholds
To be included in the main section of the Archive (“National sectoral collective agreements currently in force or remaining effective after expiry”), a national collective bargaining agreement (“NCBA” or “CCNL”) must satisfy the following numerical requirements:
- coverage of at least 5% of employees within a given ATECO division;
- in the case of multi-sector agreements, minimum coverage of 3% of employees in at least one ATECO division.
During the pilot phase of the project, the main threshold had initially been set at 1%, before subsequently being increased to 5%, also following requests from certain employers’ associations advocating for a higher threshold.
Agreements that do not meet this coverage levels are not removed from the Archive; rather, they are placed in a separate section entitled “Other Agreements”, thereby signaling their more limited impact on the labour market without formally denying their existence.
The numerical framework
The figures presented by CNEL President Renato Brunetta depict a highly polarised landscape: only 99 collective agreements attributable to the three main confederations (CGIL, CISL and UIL) provide coverage for more than 97% of the approximately 14.6 million private-sector workers recorded through the UniEmens system. Conversely, the more than 800 agreements executed by smaller organisations affect only a residual group of approximately 350,000 workers, with 438 agreements applied by fewer than 50 companies and 343 relating to fewer than 100 employees overall.
From an analytical perspective, these findings considerably reduce the actual scope of the phenomenon commonly referred to as contractual dumping, namely the practice of adopting collective agreements with lower salary and regulatory standards in order to gain a competitive advantage through reduced labour costs.
Comparative fact sheets and public procurement
A further significant operational development is represented by the introduction of the “standardised contract fact sheets”, already made available for the collective agreements applicable to the market tertiary sector, which overall involves approximately five million workers.
These fact sheets provide an analytical and standardised representation of the main economic and regulatory provisions governed by collective agreements (including minimum salary, 13th and 14th monthly salary payments, sick pay, annual leave, paid leave entitlements, supplementary pension schemes and welfare measures), according to the categories set out in the Italian Public Procurement Code (Legislative Decree No. 36/2023).
The initiative forms part of the CNEL–ANAC Protocol executed on 16 June 2025, which assigned a central role to the CNEL Archive within public procurement procedures. Since then, contracting authorities may — and in practice are now generally expected to — refer to the Archive both for the identification of the collective agreement applicable to the procurement procedure and for the equivalence assessment required under Annex I.01 of Legislative Decree No. 36/2023.
The equivalence assessment therefore no longer takes the form of a discretionary and fragmented evaluation, liable to vary from one authority to another, but rather tends to become a structured technical comparison based on uniform and predetermined comparative parameters.
An important related development: Law Decree No. 62/2026
The reform of the Archive should not be considered in isolation. Law Decree No. 62 of 30 April 2026 (published on the same day in Official Gazette No. 99) introduced the concept of a “fair wage”, linking it to the overall economic treatment (“TEC”) provided by the collective agreements executed by the most representative organisations. The decree does not establish a statutory minimum wage; however, it makes the TEC of the leading sectoral collective agreement a mandatory minimum threshold, including employers applying a different collective agreement.
For companies, the three most immediate practical implications are the following:
(i) as from 1 May 2026, payroll slips must indicate the CNEL alphanumeric code of the applied collective agreement, namely the same code used within the new Archive (Article 11); (ii) access to the Women Bonus, Youth Bonus, ZES Bonus and employment stabilisation incentives is conditional upon payment of a TEC at least equivalent to that provided under the reference sectoral collective agreement; (iii) where a collective agreement is not renewed within 12 months after its expiry date, salaries are automatically adjusted by an amount equal to 30% of the variation in the IPCA (Harmonised Consumer Price Index).
The connection with the Archive reform is both evident and direct. In order to apply the decree in practice, to identify the “leading” sectoral collective agreement, verify whether an employer complies with the relevant salary thresholds, and determine eligibility for incentives, it is necessary to have a system capable of objectively distinguishing between widely applied agreements and “marginal” ones.
This is precisely the function performed by the new CNEL classification system, with its updated distinction between “sectoral agreements” and “other agreements”, built on INPS employment data. Without such an informational infrastructure, the conditional framework established by the decree would lack any institutional benchmark on which to operate.
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