FC CONSULTING & MANAGEMENT

Employment · Contribution incentives

Hiring incentives and SIISL: job posting requirement from 1 December 2026

Ministerial Decree no. 134 of 5 October 2026 links the publication of job positions on SIISL to access to contribution incentives. For hires from 1 December, publication must take place before or at the time of hiring.

By Francesco Cavallo · Chartered Accountant and Statutory Auditor

12 October 2026

Reading time: 5 min

Italy's Ministry of Labour has announced the signing of Decree no. 134 of 5 October 2026, implementing Article 14, paragraphs 1-4, of Decree-Law no. 159/2025, converted into Law no. 198/2025. The measure sets out the operational framework linking publication of job positions on the Sistema Informativo per l'Inclusione Sociale e Lavorativa (SIISL) to access to contribution incentives.

From 1 December 2026, for hires covered by the new rules, the job position must be published on SIISL before or at the time of hiring, and the relevant position identifier must be reported in the UNIEMENS filing.

What changes for employers

The new requirement directly affects the workflow used by employers planning subsidised hires. The Ministry has clarified that, for hires made from 1 December 2026, publication of the position on SIISL must be completed before or at the same time as the hire.

The position identifier must then be included in the UNIEMENS filing in accordance with instructions to be issued by INPS. This means the SIISL step must be coordinated with both the hiring process and the subsequent use of the incentive.

Trial period until 30 November

For hires made between 1 April and 30 November 2026, publication of the position on SIISL remains optional and failure to publish does not result in the loss of the contribution relief.

During this trial period, a position may also be published after the hire for traceability and monitoring purposes. In that case, it is automatically archived by SIISL and is not visible to candidates.

What can be managed through SIISL

The decree also strengthens SIISL as an operational tool for employers and intermediaries. The platform is expected to allow users to review available contribution incentives, simulate the benefits potentially applicable to the employer, worker and vacancy, and obtain information needed for correct UNIEMENS reporting.

SIISL may also be used, as an alternative to regional systems, for mandatory employment communications relating to the start, extension, transformation and termination of employment relationships, without duplicating filings.

A new workflow for subsidised hires

For hires starting from 1 December, employers should therefore build the SIISL check into their internal hiring process before claiming the contribution incentive.

Practical checklist

Before proceeding with a subsidised hire

01 · Identify the applicable incentive

02 · Check employer and worker requirements

03 · Publish the vacancy on SIISL on time

04 · Keep the position identifier

05 · Complete the hire correctly

06 · File the mandatory employment communication

07 · Report the identifier in UNIEMENS

08 · Check the applicable INPS instructions

The full decree is still undergoing registration

As of 12 October 2026, the Ministry of Labour states that the decree and its technical-operational annex have been sent to the competent control bodies for registration. Once registered, both documents will be published in the Ministry's legal-publicity section.

Before the new system becomes fully operational, employers should therefore review the final text, the technical annex and INPS instructions, particularly to determine exactly which incentives are covered and how the UNIEMENS reporting must be completed.

What employers should do now

Businesses planning subsidised hires from December should begin treating SIISL publication as an integral part of the hiring procedure.

In practical terms, the process becomes: job offer → SIISL → hire → mandatory communication → UNIEMENS → incentive. A preventive check can help avoid a procedural omission affecting access to an otherwise available contribution benefit.

This article is for general information only and does not replace an assessment of the individual case or verification of the final implementing instructions.