On 21 September 2021, under Decree-Law 21 September 2021, n. 127, Italy extended its COVID-19 mandatory vaccination and "green certification" and screening system to virtually all public and private work within the country, including work done by independent contractors as well as volunteers and trainees. The measure came into force on 22 September 2021. Existing COVID-19 guidelines on masks, spacing, and sanitation remain in force.
The COVID-19 green certification was created to facilitate free and safe movement of citizens in the European Union during the COVID-19 pandemic. In Italy, the certification is issued exclusively through the National Platform of the Ministry of Health in both digital and paper format.
Decree-Law 21 September 2021, n. 127, amends an earlier decree-law, to provide that from 15 October 2021 until 31 December 2021, for access to workplaces within Italy, it is compulsory to possess and exhibit, upon request, a COVID-19 green certification. Public and private employers are required to enforce the mandate each time a worker enters a workplace. It is also possible for an employer to verify possession of the green certification in advance of the scheduled workplace access by a worker. Failure of a worker to provide the certification is considered an unjustified absence of the worker from work. Employers that do not carry out verifications are liable for fines ranging from €400 to €1,000.
Verification of the green certification can be done with a VerificationC19 app available to employers to allow for daily and automated verifications. There are provisions in the mandate for individuals who, for proven health reasons, cannot receive vaccination against COVID-19, as well as those waiting for certification, those cured of COVID-19 within the previous six months, and others. Although it is possible for a negative COVID-19 test result to be presented in place of vaccination, such tests would have to be conducted every 48 or 72 hours, depending on the test.
The Italian government posted an FAQ webpage addressing a range of questions about the mandate. The European Union's Italy webpage also has FAQs about green certification.
Edward Kowalski, Esq., is Manager, Payroll Information Resources, for the American Payroll Association