As of August 6, 2026, a new obligation is in force under the inter-ministerial decree of June 22, 2026 (Ministry of Labour, Ministry of the Interior, MAECI), published in the Official Gazette (G.U.), General Series no. 191 of August 19, 2026, implementing Article 14(6) of Decree-Law no. 159/2025 (converted into Law 198/2025). The decree applies to the “proposing entities” running vocational and civic-linguistic training programs abroad under Article 23 of Italy’s Consolidated Immigration Act (TUI), and requires them to register with SIISL — the Information System for Social and Labour Inclusion — the foreign nationals who complete the training successfully. For companies using Article 23 as an outside-quota channel to bring in staff from abroad, this is one more compliance step to build into the timeline, not just paperwork.
What the proposing entity must do
Registration is not a single step: the decree breaks it down into several stages, some with a set deadline.
| Requirement | How | Deadline |
|---|---|---|
| Transmission of the list of trained workers | System-to-system integration with the Piattaforma Ingressi Formati all’Estero (Foreign Trainees Entry Platform) | Upon successful completion of training |
| Completion and verification of contact data | Review and update on the SIISL platform | No fixed deadline set |
| Follow-up with workers who have not activated their account | Notice urging the worker to activate their SIISL account | 15 days from non-activation |
Why it matters for the hiring company too
Once active, the profile generates a pre-filled CV built from the worker’s training record, visible to employers in the relevant sectors, not only to the company that funded or promoted the program. That’s simply how SIISL is designed to work, as a labour-matching platform, and it’s worth keeping in mind if you’re investing in an Article 23 program expecting to keep the trained candidates for yourselves: in practice, it pays to move as fast as possible between the end of training and the nulla osta request, to shorten the window in which the profile is visible to others.
One issue the decree leaves open. The text refers to the “proposing entity,” but in practice many Article 23 programs are run day to day by a delegated party distinct from the entity formally proposing the project. The decree does not clarify how a delegated party should operate on SIISL on the proposing entity’s behalf. This isn’t an isolated gap: a similar concern, regarding the obligation to publish job offers under Article 14(1), was already raised with the Ministry by CNDCEC (Italy’s national accountants’ council) in mid-June 2026, with no official response to date. We have sent a clarification request by certified email (PEC) to the relevant Ministry office and will update give an update as soon as we receive a response.
This article was prepared by Nexum Global Mobility for the ETL GLOBAL’s Global Mobility Group. Visit the group’s dedicated page to learn more and get in touch for further assistance.
