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Extracurricular internships, penalty profiles and intertemporal regime

News n. 31/2022



The National Labor Inspectorate, in Note No. 1451 of July 11, 2022 intervenes with clarifications regarding the rules applicable to extracurricular internships initiated before and continued after the entry into force of Budget Law No. 234 of Dec. 30, 2021, providing clarifications regarding applicable penalties, as well as any contribution recoveries resulting from internships carried out in a "fraudulent" manner.

As predicted in our News of January 18, 2022, Budget Law No. 234/2021, in Article 1, paragraphs 720 to 725, introduced important novelties regarding internships, stating that within 180 from its entry into force an agreement between the government, the regions and the autonomous provinces of Trento and Bolzano should have been reached in the Permanent Conference in order to adopt new Guidelines (those still in force date back to 2017).


Starting from the assertion that internship is redefined as a study-work alternation training aimed at vocational guidance and training also capable of improving the matching of labor supply and demand, and that if it is functional for the attainment of a formally recognized degree, the internship is defined as "curricular," the following criteria have been defined by the legislature to be the starting point for the drafting of the new Guidelines:


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