Credit-based site licence: how to meet the requirements of Article 27, Legislative Decree 81/08

Legal basis and who is required to hold one

The credit-based site licence was introduced by Decree-Law No. 19 of 2 March 2024, converted with amendments by Law No. 56 of 29 April 2024, which rewrote Article 27 of Legislative Decree 81/08. It has been mandatory since 1 October 2024 for companies and self-employed workers physically operating on temporary or mobile construction sites as defined in Article 89, paragraph 1, letter a) of Legislative Decree 81/08. Exempt are: pure material supply without installation, purely intellectual services (design, works supervision, safety coordination), and companies holding an SOA qualification certificate of category III or higher, for works consistent with that qualification category.

How to apply and the requirements to self-certify

The application is submitted online through the Italian National Labour Inspectorate's portal (servizi.ispettorato.gov.it), self-certifying that the requirements under Article 27 are met: registration with the Chamber of Commerce, a valid DURC (certificate of contribution compliance) and tax compliance certification (self-certifiable under Article 46 of Presidential Decree 445/2000); fulfilment of training obligations towards workers, possession of a risk assessment document (DVR) and appointment of an HSE manager (RSPP) (attestable through a substitutive declaration of notoriety under Article 47 of Presidential Decree 445/2000). The application procedure and the information shown on the licence are set out in Ministerial Decree No. 132 of 18 September 2024 (Official Gazette No. 221 of 20 September 2024).

Scoring: starting points, how to earn them, how to lose them

The licence is issued with an initial allocation of 30 credits. Ministerial Decree 132/2024 also sets out the criteria for earning up to 100 additional credits, awarded for length of registration, holding an SOA qualification, adoption of an ISO 45001-certified safety management system, investment in health and safety, and training track record. Credits are lost following final rulings related to serious or fatal accidents and other violations specified by law; an amendment introduced by Decree-Law 159/2025 (paragraph 7-bis of Article 27) also provides that, for violations relating to undeclared work, the deduction applies automatically as soon as the inspection report is notified, without waiting for the ruling to become final.

Below 15 credits

A licence with fewer than 15 credits does not allow the holder to operate on construction sites subject to the requirement, except for completing work already under way at the time of the last deduction, where at least 30% of the contract value has already been carried out and the legal conditions are met. Penalties for operating without a valid licence or below 15 credits were increased by Decree-Law 159/2025, which raised the minimum fine from €6,000 to €12,000. The licence is also revoked if a false declaration is established during a check carried out after issuance; a new licence can be requested twelve months after revocation.

Recovering deducted credits

Through Note No. 4634 of 24 June 2026, the Italian National Labour Inspectorate provided initial operational guidance and the forms for requesting the recovery of deducted credits, for both companies and self-employed workers: a procedure distinct from requesting additional credits, with its own requirements and documentation to be verified case by case.

Official sources

• Legislation — Art. 27, Legislative Decree No. 81 of 9 April 2008, as amended by Decree-Law 19/2024 (converted by Law 56/2024) and Decree-Law 159/2025 — Normattiva.it (Italian)
• Italian National Labour Inspectorate — Credit-based licence portal (Italian)
• Ministerial Decree No. 132 of 18 September 2024 — Official Gazette No. 221 of 20 September 2024
• Italian National Labour Inspectorate — Circular No. 4/2024 and Note No. 9326 of 9 December 2024 (penalty regime); Note No. 4634 of 24 June 2026 (credit recovery)

The regulatory framework for the credit-based site licence has been amended several times since its introduction in 2024: we check the current version of Article 27 and the most recent INL operational notes before any assessment of a specific case. To check your own position, contact us.