Extracurricular internships, sanctions profiles, and intertemporal regime

News . 31/2022

The National Labor Inspectorate, with Note No. 1451 of July 11, 2022, provides clarification on the regulations applicable to extracurricular internships that began before and continued after the entry into force of Budget Law No. 234 of December 30, 2021, providing explanations on the applicable penalties, as well as any contribution recoveries resulting from internships carried out in a "fraudulent" manner.

As announced in our News January 18, 2022, Budget Law No. 234/2021, in Article 1, paragraphs 720 to 725, introduced important changes regarding internships, stating that within 180 days of its entry into force, an agreement should be reached between the Government, the Regions, and the autonomous provinces of Trento and Bolzano, at the Permanent Conference, in order to adopt new Guidelines (those currently in force date back to 2017).

Starting from the assertion that internships are redefined as a training program alternating between study and work aimed at career guidance and professional training and capable of improving the match between labor supply and demand, and that, if it is functional to the achievement of a formally recognized qualification, the internship is defined as "curricular," the legislator has defined the following criteria, which will form the basis for the drafting of the new Guidelines:

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