Extracurricular Internships, Sanctioning Aspects, and Transitional Provisions

News no. 31/2022

The National Labor Inspectorate, with Note no. 1451 of July 11, 2022, provides clarifications regarding the regulations applicable to extracurricular internships initiated before and continued after the entry into force of Budget Law no. 234 of December 30, 2021, offering elucidations on applicable sanctions, as well as any contribution recoveries stemming from "fraudulently" conducted internships.

As announced in our News of January 18, 2022, Budget Law no. 234/2021, Article 1, paragraphs 720 to 725, has introduced significant innovations regarding internships, stipulating that within 180 days of its entry into force, an agreement should have been reached between the Government, the Regions, and the autonomous provinces of Trento and Bolzano, within the Permanent Conference, for the adoption of new Guidelines (the currently effective ones date back to 2017).

Starting from the premise that internships are redefined as an educational pathway alternating between study and work, aimed at professional orientation and training, also capable of improving the match between labor supply and demand, and that, when functional to obtaining a formally recognized academic qualification, an internship is defined as “curricular,” the legislator has established the following criteria, which will form the basis for drafting the new Guidelines:

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