Supplementary Social Security Schemes and TFR: What Changes from July 1, 2026
As of July 1, 2026, significant changes concerning supplementary social security schemes and the allocation of TFR will come into effect. The amendments introduced by the 2026 Budget Law, together with the subsequent guidance issued by the Ministry of Labour and the directives of COVIP (the Italian Pension Funds Supervisory Authority), have a direct impact on employers’ compliance obligations and on the information that must be provided to employees.
The main innovation is the introduction of a new automatic enrollment mechanism based on the principle of silent consent (opt-out). In practice, employers will need to pay particular attention to employees’ expressed —or unexpressed — choices, the correct allocation of TFR, and the identification of the appropriate pension fund.
- “First-time employees” are individuals entering employment as employees for the first time.
- Employees who were previously employed, had joined a supplementary pension scheme and subsequently redeemed their individual pension position are not subject to the new automatic enrollment mechanism.
- Conversely, where a change of employment results in the employee no longer meeting the eligibility requirements for the previously selected pension fund, and the accrued pension position has not been redeemed, the automatic enrollment mechanism will apply.
- Before starting TFR transfers and any related employer and employee contributions, employers must verify that the selected pension scheme complies with the COVIP requirements regarding investment pathways and minimum investment options.
- Where the employee is enrolled in the COMETA Fund as the residual/default pension fund, neither employer nor employee contributions are due, unless otherwise provided under the applicable collective bargaining agreement.
- Where the applicable collective agreement does not require pension contributions during the probationary period, the TFR must nevertheless be transferred from the employee’s hiring date, while pension contributions will commence only after successful completion of the probationary period.
What Employers Need to Do
Employers are required to carefully manage the new framework, as the absence of an express choice by the employee may automatically determine both the destination of the TFR and enrollment in a supplementary pension scheme.
In particular, employers will be required to:
- provide employees with clear and comprehensive information;
- collect declarations regarding any previous pension choices;
- monitor the 60-day period from the hiring date;
- correctly apply the silent consent mechanism, where applicable.
To facilitate operational compliance, companies are encouraged to review their internal procedures without delay.
Why Immediate Action Is Important
The new framework represents more than a formal regulatory update. It introduces new information and administrative obligations that require careful implementation, proper documentation, and full compliance from the hiring stage onwards.
Failure to correctly manage employees’ choices or comply with the applicable deadlines may result in errors in both the allocation of TFR and contributions to supplementary pension schemes.
Our Advisory Services
Our firm supports employers in assessing individual cases, preparing the required employee information notices, collecting the necessary documentation, and ensuring the correct management of all related compliance obligations.
We therefore encourage interested companies to contact us promptly. A timely assessment will help ensure proper implementation of the new rules, minimize operational uncertainty, and turn this regulatory change into an opportunity for more effective and structured workforce management.
RIMANI AGGIORNATO SULLE ULTIME NOTIZIE LAW. CLICCA QUI PER SAPERNE DI PIÙ!