Italy: EU Blue Card Professional Experience Pathway Now Available, Labor Market Testing and Other Rules Clarified
April 3, 2024

Effective March 29, 2024, the Italian government has published an implementing circular clarifying practical elements with respect to its November 2023 revised EU Blue Card legislation. Importantly, following publication of this circular, the professional experience applicant pathway is now available. Prior to this March 2024 circular, this pathway – which applies to individuals who may lack academic qualifications but have either five years of professional experience in a relevant role or three years of experience in the information technology sector – was not practically available (despite the November 2023 laws formally creating this pathway). Additionally, the circular clarified the documentary requirements for such applicants, who must submit an employment contract and payslips (which must be legalized if they are from a non-EU country) and can also provide an optional letter describing their professional experience from the Italian sponsoring company. This documentary process is simpler and quicker than the Declaration of Value process, which continues to be necessary for any EU Blue Card applicants relying on academic qualifications, and which generally takes two months upon submission of documentation.
Additionally, the circular establishes that EU Blue Card sponsoring employers must be able to prove that no local workers (of any nationality, provided they are registered with the employment office in Italy) are available for the applicable position. To do so, sponsors must submit a modulo richiesta personale form with the employment office. Italian authorities then have 15 days to respond with local candidates. If no response is forthcoming, employers can move forward with the Blue Card application. If a local candidate is proposed, the employer may still decide whether such a candidate is an adequate fit for the proposed role (including following interviews with the individual). Exceptions to this labor market testing requirement apply to certain highly-qualified individuals who currently hold a residence permit for research or an EU ICT permit, with additional exceptions possibly forthcoming.
Separately, following publication of the circular, EU ICT work permit holders can obtain an EU Blue Card without leaving Italy and cancelling their EU ICT work and residence permit. This was not previously possible and will make it easier for these individuals to stay and work in-country.
This alert is for informational purposes only. If you have any questions, please contact the global immigration professional with whom you work at Fragomen or send an email to [email protected].
Explore more at Fragomen
Blog post
Media mentions
Senior Associate Isabel Schnitzler outlines the key compliance considerations for employers with employees working across the EU.
Podcast
Associates Stephanie D. Weaver and Julia Manacher examine immigration issues emerging in a popular reality television series, including K-1 visa denials, consular non-reviewability, fraud findings and changing adjudication policies.
Blog post
Manager Dr. Adela Schmidt examines common misconceptions in German citizenship law, including birthright citizenship, dual citizenship, citizenship by descent and naturalization processing, and explains why eligibility often depends on specific legal requirements, timelines and documentation.
Awards
Partner Audrea Golding, Senior Associate Kyle Sommer and Senior Talent Development Director Wendy Milici have been named finalists in the 2026 TLC Lions Human Awards Americas, recognizing their contributions to human-centered leadership, workplace culture and inclusion.
Media mentions
Fragomen and SICPA have launched a global joint venture to develop an end-to-end digital identity platform that enables secure identity verification, document authentication and verifiable credential management.
Media mentions
Senior Counsel Mitch Wexler discusses how potential changes to H-1B visas, employment-based green cards and OPT could impact employers’ workforce planning and compliance obligations.
Media mentions
In a Leaders in Motion interview with World Business Travel Forum, Partner Ali Haider and Nomadic CEO Carsten Østberg discuss recent travel and mobility developments across the Middle East and practical considerations for employers managing cross-border talent in the region.
Media mentions
Partner Rachel Beardsley explains how new DHS guidance clarifies that dairy employers may use the H-2A program when they can demonstrate a temporary or seasonal labor need.
Fragomen news
Fragomen and SICPA announced the formation of a global joint venture to advance next-generation digital identity solutions for governments, enterprises and individuals.
Blog post
Senior Associate Kyle Sommer and Adam Schwartz, Director in the Global Mobility practice at Andersen, discuss how immigration and tax considerations intersect across common US immigration classifications and why early coordination can help travelers, employers and advisors reduce compliance risks and make more informed mobility decisions.
Blog post
Media mentions
Senior Associate Isabel Schnitzler outlines the key compliance considerations for employers with employees working across the EU.
Podcast
Associates Stephanie D. Weaver and Julia Manacher examine immigration issues emerging in a popular reality television series, including K-1 visa denials, consular non-reviewability, fraud findings and changing adjudication policies.
Blog post
Manager Dr. Adela Schmidt examines common misconceptions in German citizenship law, including birthright citizenship, dual citizenship, citizenship by descent and naturalization processing, and explains why eligibility often depends on specific legal requirements, timelines and documentation.
Awards
Partner Audrea Golding, Senior Associate Kyle Sommer and Senior Talent Development Director Wendy Milici have been named finalists in the 2026 TLC Lions Human Awards Americas, recognizing their contributions to human-centered leadership, workplace culture and inclusion.
Media mentions
Fragomen and SICPA have launched a global joint venture to develop an end-to-end digital identity platform that enables secure identity verification, document authentication and verifiable credential management.
Media mentions
Senior Counsel Mitch Wexler discusses how potential changes to H-1B visas, employment-based green cards and OPT could impact employers’ workforce planning and compliance obligations.
Media mentions
In a Leaders in Motion interview with World Business Travel Forum, Partner Ali Haider and Nomadic CEO Carsten Østberg discuss recent travel and mobility developments across the Middle East and practical considerations for employers managing cross-border talent in the region.
Media mentions
Partner Rachel Beardsley explains how new DHS guidance clarifies that dairy employers may use the H-2A program when they can demonstrate a temporary or seasonal labor need.
Fragomen news
Fragomen and SICPA announced the formation of a global joint venture to advance next-generation digital identity solutions for governments, enterprises and individuals.
Blog post
Senior Associate Kyle Sommer and Adam Schwartz, Director in the Global Mobility practice at Andersen, discuss how immigration and tax considerations intersect across common US immigration classifications and why early coordination can help travelers, employers and advisors reduce compliance risks and make more informed mobility decisions.

