DLP Insights

Compulsory “Covid-19 Green pass” for employees

Categories: DLP Insights, Legislation | Tag: Covid-19, green pass

01 Oct 2021

Decree Law No. 127 of September 21, 2021 (hereinafter, “Decree“), in force since September 22, has introduced the COVID-19 Green Certification obligation (hereinafter, “Green pass”) to all workers in the public and private sectors.

In particular, from October 15, 2021, through December 31, 2021 (the current end of the “state of emergency”), “anyone carrying out a work activity (…) is obliged, for the purposes of access to the places where the activity is carried out, to possess and exhibit, upon request, the COVID-19 Green Certification“. The obligation concerns all those who, for any reason, carry out their work or training or voluntary activities in workplaces, including on the strength of external contracts.

Green pass controls require employers, to:

before October 15, 2021:

  • define the operating procedures for carrying out the checks, including on a sample basis;
  • identify, by means of a formal act, the person(s) in charge of the checks.

from October 15, 2021 to December 31, 2021:

  • verify the possession and validity of the Green Pass by workers and all those who access company premises for work purposes;
  • report and transmit any violations to the competent Prefecture.

Violation of the above-mentioned obligations may result in the application of administrative sanctions to both employers and workers.


Partners and Associates of the Law Firm De Luca & Partners are available for any further information.


Click here to request the Slides of our recent HR Virtual Breakfast “The return to the company with the Green pass obligation: problems and perspectives“. 

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