Italy’s Green Pass program, one of the world’s strictest COVID-19 vaccination and testing requirements, requires employers to establish internal procedures to ensure their employees' compliance.
Background: In order to enter the workplace, employees must provide a “Green Pass,” i.e., certification of:
- Full vaccination,
- Having recovered from COVID-19 within the past 6 months, or
- A negative swab test taken in the past 48-72 hours.
Employees bear the financial burden of testing, which is approximately €200 per month. However, unions have been pushing for employers to pay for the testing.
Workers who fail to comply with the Green Pass requirement may be suspended without pay and fined up to €1,500 ($1,760). Employers can let employees work from home if the job permits. However, remote work shouldn’t be an alternative for those who elude vaccines, according to the government’s FAQ.
For the period of unpaid suspension (unjustified absence), dismissal or disciplinary proceedings are prohibited.
Companies should ensure Green Pass compliance for all workers, including contractors and third-party workers.
For more on the policy, you can access BEERG Executive Director Tom Hayes’ interview with Lea Rossi and Marco Sideri, partners at leading Italian employment law firm Toffoletto De Luca Tamajo.
Outlook: The decree has received resistance from employers and unions, who are concerned that certain industries will be severely affected by worker absences and contribute to already existing labor shortages. Imposing vaccine mandates in the workplace is being debated worldwide, with governments increasingly taking the view that workplace health and safety should not be put at risk by unvaccinated or untested workers. HR Policy Global will continue to monitor and analyze new measures passed by global governments responding to the COVID-19 pandemic.