
Buried in Article 3 of newly-published Law 179/2025 is a game-changer for assignees: non-EU nationals may now begin employment while waiting for the renewal or **conversion** of their residence permit, provided no security objections are raised. The previous rule required applicants to hold the physical permit card before performing any remunerated activity, a bottleneck that often left executives idle for two months.
Scope and limits – The amendment applies to renewals, first-time conversions (e.g., from study or seasonal status to subordinate work) and overdue deliveries of electronic permits. Workers must still meet all standard conditions—valid passport, existing residence, signed contratto di soggiorno—and employers must notify hires through the UNILAV portal. Police authorities retain the power to issue a negative notice that would immediately void the temporary work authorisation.
Business benefits – Multinational companies can now onboard key talent faster, avoiding costly project delays and shadow-payroll complications. HR teams should align internal policies so that new hires sign conditional employment contracts that reference the possibility of a police objection.
Practical tips – 1) Keep digital copies of the receipt (cedolino) that proves a permit is in process—labour inspectors may request it. 2) Coordinate with payroll providers to flag “provisional” social-security status until the card is issued. 3) Update assignment letters to reflect the new legal wording under Article 5(9-bis).
What’s next – The Interior Ministry is expected to release an operational circular clarifying whether the rule also covers self-employment permit conversions. Until then, companies should consult local counsel before applying the provision to freelance or intra-company managerial permits.
Scope and limits – The amendment applies to renewals, first-time conversions (e.g., from study or seasonal status to subordinate work) and overdue deliveries of electronic permits. Workers must still meet all standard conditions—valid passport, existing residence, signed contratto di soggiorno—and employers must notify hires through the UNILAV portal. Police authorities retain the power to issue a negative notice that would immediately void the temporary work authorisation.
Business benefits – Multinational companies can now onboard key talent faster, avoiding costly project delays and shadow-payroll complications. HR teams should align internal policies so that new hires sign conditional employment contracts that reference the possibility of a police objection.
Practical tips – 1) Keep digital copies of the receipt (cedolino) that proves a permit is in process—labour inspectors may request it. 2) Coordinate with payroll providers to flag “provisional” social-security status until the card is issued. 3) Update assignment letters to reflect the new legal wording under Article 5(9-bis).
What’s next – The Interior Ministry is expected to release an operational circular clarifying whether the rule also covers self-employment permit conversions. Until then, companies should consult local counsel before applying the provision to freelance or intra-company managerial permits.









