Regulations

Law 198/2025 - the site badge

Decree-law 159 of 31 October 2025, converted with amendments by law 198 of 29 December 2025, provides that companies working on building sites under public or private contracts and subcontracts, and in the further higher-risk sectors to be identified by decree of the Minister of Labour and Social Policies, give their employees the identification card with a unique anti-counterfeiting code: the site badge (art. 3, paragraph 2).

The card is the one already required by art. 18, paragraph 1, letter u), and art. 26, paragraph 8, of D.Lgs. 81/2008 and by art. 5 of law 136/2010 (see below): used as a badge carrying the employee's identifying details, it is made available to the worker in digital form too, through national digital tools interoperable with the SIISL platform. For the Ispettorato Nazionale del Lavoro the badge does not replace the identification card: it adds the unique anti-counterfeiting code to it (circular 1/2026).

How it is put into practice, including the control and safety measures on site, the monitoring of workforce flows through technology and the kinds of information processed, is left to an implementing decree of the Minister of Labour and Social Policies, in agreement with the Minister of Infrastructure and Transport and after consulting, among others, the Garante per la protezione dei dati personali (art. 3, paragraph 3). For the Inspectorate, the badge's new features become fully operational only once that decree is adopted (circular 1/2026).

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Decree-law 19/2024 - the patente a crediti

Since 1 October 2024, companies and self-employed workers operating on temporary or mobile sites must hold the patente a crediti, issued in digital form by the Ispettorato Nazionale del Lavoro; those who only make supplies or provide intellectual services are excluded, and so are companies with an SOA qualification of class III or above (art. 27, paragraphs 1 and 15, of D.Lgs. 81/2008, as replaced by art. 29, paragraph 19, of decree-law 19/2024, converted by law 56/2024).

The licence starts at thirty credits and allows work on temporary or mobile sites with at least fifteen (art. 27, paragraph 5). Credits are deducted for the violations listed in annex I-bis (paragraphs 6 and 7-bis), and after an accident on those sites causing a death or a permanent disability the Inspectorate may suspend the licence as a precaution for up to twelve months (paragraph 8). Below fifteen credits, companies and self-employed workers cannot operate there, apart from completing the work in progress once more than 30 per cent of the contract's value has been carried out (paragraph 10).

Decree-law 159 of 31 October 2025, converted by law 198 of 29 December 2025, doubled the minimum penalty for working without the licence, or without the equivalent document, or with a licence below fifteen credits — an administrative penalty proportionate to the value of the works, with a statutory minimum, not subject to a formal warning to comply, plus exclusion from public works for six months — and made the deductions for undeclared work immediate, on notification of the inspection report (art. 27, paragraphs 7-bis and 11, as amended by art. 3, paragraph 4, of decree-law 159/2025). The issue of the licence, its precautionary suspension, further credits up to the maximum of one hundred and the recovery of deducted credits are governed by Ministry of Labour decree 132 of 18 September 2024; the Ispettorato Nazionale del Lavoro's operational guidance is in circular 4/2024 and, for the changes made by decree-law 159/2025, in circular 1/2026.

The client or the responsabile dei lavori, even when entrusting the works to a single company or a self-employed worker, checks the technical and professional suitability of the main contractors, the executing companies and the self-employed workers under Annex XVII (art. 90, paragraph 9, letter a), of D.Lgs. 81/2008), asks the executing companies for the declaration of their average annual workforce and of the collective agreement applied (letter b)) and checks that the executing companies and the self-employed workers hold the patente a crediti — or the equivalent document or, for companies exempt under art. 27, paragraph 15, an SOA qualification certificate of class III or above — subcontracting included (letter b-bis)). For the Ispettorato Nazionale del Lavoro the check of the licence is made when the works are awarded and concerns holding the licence, not the truth of the requirements the company has self-certified. Failing to check suitability is a criminal offence (contravvenzione) under art. 157, paragraph 1, letter b); failing to check the licence or the SOA certificate is an administrative offence under art. 157, paragraph 1, letter c). A company or self-employed worker working without the licence, or with fewer than fifteen credits, is liable in its own right (art. 27, paragraph 11).

CantiereGo records the state and the credits of every employer's licence: under 15 credits with no exception in force, or suspended or revoked, its workers' badges turn red. For a single site, the company can give the client and the safety coordinator an inspector access code, time-limited and read-only, that shows the licence of every firm and self-employed worker on the site, with the day the company checked it, the SOA qualification where it is the ground for the exemption, and the DURC, as the company recorded them.

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D.Lgs. 81/2008 - the tesserino di riconoscimento

In work under contracts and subcontracts, the employer must give workers an identification card with a photo, the worker's personal details and the employer's name (Testo unico sulla sicurezza, D.Lgs. 81/2008, art. 18, paragraph 1, letter u), and art. 26, paragraph 8). Workers must display it (art. 20, paragraph 3), and self-employed workers carry their own, with their personal details (art. 21, paragraph 1, letter c)).

Law 136 of 13 August 2010 (art. 5) adds the hire date and, in case of subcontracting, the authorisation; for self-employed workers, the name of the client. D.Lgs. 81/2008 penalises the employer and the manager, for each worker, when staff are not given the card (art. 55, paragraph 5, letter i)), and the worker who does not display it (art. 59, paragraph 1, letter b)).

Holding a valid single certificate of contribution regularity (DURC) is one of the requirements for the patente a crediti (art. 27, paragraph 1, letter c)): CantiereGo records its state and expiry for every employer, and an irregular or expired DURC turns its workers' badges red.

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GDPR and the Garante - workers' data

Badge and attendance data are workers' personal data. The company using CantiereGo processes them as controller and gives workers the notice of art. 13 of Regulation (EU) 2016/679; A176lab processes them on its behalf as processor (arts. 4 and 28).

Art. 4 of the Statuto dei lavoratori (law 300/1970) governs the tools from which remote monitoring of workers' activity may also derive: they may be installed after a collective agreement or, failing one, with the authorisation of the Ispettorato Nazionale del Lavoro (paragraph 1). That rule does not apply to the tools a worker uses to do the work or to the tools that record access and attendance (paragraph 2). In either case, the information collected may be used for all purposes connected with the employment only if the worker is given adequate information on how the tools are used and how checks are carried out and in compliance with D.Lgs. 196/2003 (paragraph 3). Whether a punch with a position falls under paragraph 1 or paragraph 2 is for the employer to assess with its adviser: this page does not say. CantiereGo shows the geolocation notice in the wallet before the first punch with a position, and never stores the coordinates: only the distance from the site and the accuracy of the fix.

Attendance is kept for the period the company sets, 5 to 10 years from the end of the employment, with a legal hold that suspends deletion.

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SIISL

The Sistema Informativo per l'Inclusione Sociale e Lavorativa (SIISL) is set up at the Ministry of Labour and Social Policies and built by INPS (art. 5 of decree-law 48 of 4 May 2023, converted by law 85/2023): it is the web platform giving access to job and training opportunities.

Decree-law 159/2025 refers to it because it provides that the identification card is made available to the worker in digital form too, through national digital tools interoperable with the SIISL (art. 3, paragraph 2). It is named here as a regulatory reference: CantiereGo does not connect to it.