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Italy Legislative Decree 254/2016

Italy Legislative Decree 254/2016: Italy’s Non-Financial Disclosure Law: Mandatory ESG Reporting for Large Companies

Maílis Carrilho
Written by Maílis Carrilho
Updated on December 2nd, 2025

Summary

Italy’s Legislative Decree 254/2016 requires large public-interest entities to publish annual non-financial statements covering environmental, social, employee, human-rights, and anti-corruption matters. Companies must disclose policies, risks, KPIs, and impacts, supported by limited assurance from an external auditor. While initially implementing the EU NFRD, the decree will gradually be replaced by the broader CSRD framework, but it remains fully enforceable for companies still under its scope during the transition.

Details

Jurisdictions
  • Italy
Exemptions

Legislative Decree 254/2016 is legally binding for large Italian public-interest entities.

Entities must:

Prepare a compliant non-financial statement annually.

Follow reporting methodologies recommended in the decree.

Obtain limited assurance from an external auditor.

Make disclosures publicly accessible.

Address all required ESG topics and risks.

Exceptions:

Applies only to public-interest entities with:

500 employees, and

exceeding balance sheet or turnover thresholds.

SMEs are exempt unless voluntarily adopting the framework.

Some consolidated groups may report at parent level.

Deep dive

2 min read
Updated Dec 2, 2025

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What’s Required

This decree transposes the EU Non-Financial Reporting Directive (NFRD) into Italian law. It requires large public-interest entities to publish an annual non-financial statement covering environmental, social, employee, human-rights and anti-corruption matters.

Reports must describe:

  • Business model and sustainability strategy

  • Policies and due diligence processes

  • Environmental impacts (energy use, emissions, water, waste)

  • Social and labour performance

  • Human-rights management

  • Anti-bribery and compliance measures

  • Principal risks and mitigation actions

Statements must be included in the management report or published separately with the auditor's assurance.

Important Deadlines

  • First applied to the financial year 2017.

  • Annual reporting required.

  • Will be superseded progressively by CSRD obligations from 2024–2028, but remains active until the full CSRD transition is completed.

Current Status

  • Fully in force but transitioning to CSRD.

  • Italian regulators continue to enforce compliance while updating guidance for CSRD adoption.

  • Enforcement is coordinated by Consob and supervisory authorities.

Penalties for Non-Compliance

  • Administrative fines for incomplete or missing disclosures.

  • Sanctions for failure to make statements public.

  • Potential supervisory actions affecting governance and transparency obligations.

Examples of Known Violations

Public reports show cases where companies received warnings for incomplete disclosures, missing KPIs or insufficient risk coverage. No major high-profile fines have been published recently, as enforcement tends to focus on corrective measures rather than punitive sanctions.

Resources


Maílis Carrilho
Added by:
Maílis Carrilho
Sustainability Research Analyst
Maílis Carrilho is a Sustainability Research Analyst (Intern) at Net Zero Compare, contributing research and analysis on climate tech, carbon policies, and sustainable solutions. She supports the team in developing fact-based content and insights to help companies and readers navigate the evolving sustainability landscape.
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Added on Dec 5, 2025 by Maílis Carrilho · Updated on Dec 2, 2025