The New Decreto Flussi: Key Innovations in Italy’s System for the Regular Entry of Foreign Workers

The decree-law of 3 October 2025, no. 146—now before Parliament for conversion—introduces a structural overhaul of the rules governing entry quotas and, more broadly, the relationship between regular migration and the labour market.
This reform does not merely adjust existing procedures; it redesigns procedural milestones, introduces automated controls, expands entry channels, and adapts the legal framework to evolving economic and demographic needs.

It follows the path opened by the reforms of 2023 and 2024, but with a clear intention to stabilise what has worked and correct the elements that have created procedural or administrative imbalances.

1. A new starting point for the deadline to issue the nulla osta: ending the uncontrolled “automatic approval” mechanism

One of the technically most relevant changes concerns the dies a quo for issuing the nulla osta for subordinate employment.
The deadline no longer runs from the date of submission (the so-called click day), but from the moment in which the application is actually assigned to an available quota.

Previously, thousands of applications remained outside the quota for weeks or months, while the deadline continued to run, triggering silenzio-assenso (automatic approval) before the administration could conduct any assessment.
The new mechanism eliminates this inconsistency and restores procedural rationality and legal certainty.

2. Systematic verification of employers’ declarations across all entry channels

A core pillar of the reform is the permanent and generalised extension of automated verification of employers’ declarations.
The digital platform cross-checks data from Unioncamere, the Revenue Agency, INPS and AgID, blocking the procedure where discrepancies emerge.

This mechanism—initially tested only for the 2025 flow decree—now becomes structural and is extended to all non-quota entry channels listed in Articles 27, 27-bis, 27-ter, 27-quater, 27-quinquies and 27-sexies of the Consolidated Immigration Act (TUI).

The reform finally overcomes the outdated model of unverified self-certification, a long-standing vulnerability in a sector exposed to fraud, unlawful intermediation and contractual dumping.

3. Mandatory pre-completion of forms and a three-application limit for employers

The pre-completion phase, introduced experimentally for 2025, is now made permanent and becomes a prerequisite for participating in the click day.

In addition, individual employers may submit no more than three applications per annual quota.
The limit does not apply to professional intermediaries (employers' associations and certified labour consultants), who must ensure the proportionality of applications to the economic and organisational capacity of the enterprise.

This measure is intended to curb the widespread past abuse of mass applications submitted without any genuine hiring capacity—a return to the principle of real, not fictitious, labour demand.

4. The right to work while waiting for a conversion of the residence permit

The reform rewrites Article 5(9-bis) TUI, aligning the right to work during administrative processing with practical reality: the right is now expressly recognised not only for renewals and first issuances, but also for conversions.

Given the well-known delays in administrative procedures, this provision safeguards employment continuity and prevents individuals from falling into irregularity due solely to administrative backlog.
The right remains conditional on possession of the receipt confirming submission of the application.

5. A unified one-year duration for residence permits for victims of trafficking, domestic violence and labour exploitation

The decree harmonises the various “special cases” permits, extending their initial duration from six months to one year and aligning them with the time realistically needed for social and labour integration programmes.

Particularly important is the extension of eligibility for the Assegno di Inclusione (Inclusion Allowance) to holders of permits issued under Articles 18 and 18-bis, in addition to victims of labour exploitation already covered since 2024.
This reinforces the idea that protection must include economic and social support measures, not only a residence document.

6. A triennial extension of non-quota entries for domestic workers assisting elderly or disabled persons

After the 2025 pilot phase, the special non-quota entry channel for domestic caregivers assisting persons over 80 or individuals with disabilities is extended for the years 2026–2028.

This responds to demographic pressures: Italy is the oldest country in the EU, and the sector of home and personal care is structurally dependent on foreign workers.
The three-year continuity improves predictability for families and operators.

7. Re-activation of the international volunteering entry channel

The entry channel created in 2018 for foreign volunteers (Article 27-bis TUI), never implemented due to the lack of annual decrees, is finally made operational.
The new system provides for a triennial entry quota, enabling non-profit entities to plan projects over a multi-year framework.

8. Family reunification: deadline increased from 90 to 150 days

The deadline for issuing the family reunification nulla osta is extended from 90 to 150 days.
The new timeframe acknowledges the complexity of the required socio-economic checks and aligns national legislation with the European framework, which allows up to nine months for decision-making.

9. Strengthening the fight against labour exploitation: permanent operation of the “Caporalato” Task Force

The Task Force against labour exploitation is made permanent and opens participation to legally recognised religious entities.
This reflects a pragmatic approach: religious organisations often play a crucial role in early identification of exploitation and in providing assistance in agricultural regions with high seasonal labour demand.

10. Continued involvement of the Italian Red Cross in managing the Lampedusa hotspot

The decree extends to 2027 the authorisation for the Ministry of the Interior to rely on the Italian Red Cross for the management of the Lampedusa crisis point.
The decision is grounded in the positive outcomes achieved and the need for operational continuity in one of the most sensitive nodes of the national reception system.

---

Final Remarks

The 2025–2027 Decreto Flussi represents a procedural and structural turning point: a system no longer centred on the click day alone, but on verified information, digital interoperability, realistic deadlines and targeted entry channels.

At the same time, it strengthens protection measures for the most vulnerable and consolidates non-quota entries in sectors structurally dependent on foreign labour.

Overall, the decree modernises Italy’s migration governance, aligning it more closely with labour market needs and the broader management of regular migration pathways.

---

Avv. Fabio Loscerbo