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

Media mentions
Partner Marius Tollenaere discussed how a digital “Super-Agency” could streamline Germany’s skilled migration.

Blog post
Senior Immigration Program Manager Alexia Prior and Senior Immigration Programme Consultant Julia Daoud discuss the importance of crisis preparedness in the face of geopolitical instability, emphasizing proactive strategies and resilience planning.

Video
In this Mobility Minute, Immigration Consultant Caryn Esther Fisher discusses recent South African citizenship updates.

Awards
Partner F. Joseph Paldino, Senior Associate Clark Cannon and Associate Mallorie Mecham are recognized in Utah Business’s 2025 Legal Elite.

Media mentions
Partner Daniel Pierce discussed how heightened immigration enforcement is causing employers to review work authorization and staffing decisions.

Fragomen news
Fragomen announces it is deepening its capabilities in the Philippines with a new office in Bonifacio Global City, the leading business and lifestyle district in Metro Manila.

Blog post
Associates Ali Ali and Charlotte Roberts discuss how UK employers can sponsor skilled workers using discounted salary rates to meet immigration requirements.

Media mentions
Partner Marius Tollenaere betont, dass die Chancenkarte die Einreise von Fachkräften nach Deutschland erleichtern, bürokratische Hürden abbauen und die Effizienz durch eine bessere digitale Integration und weniger Kontaktpunkte steigern kann.

Media mentions
Partner Abeer Al Husseini emphasises that mobility providers are essential for navigating regulatory frameworks, integrating Saudi nationals into the private sector and ensuring compliance with Saudisation policies, all of which support Saudi Arabia's Vision 2030.

Blog post
In this blog, Maja Sugui and Priyanka Gadekar explain how to obtain a Police Clearance Certificate in Germany, and the changes for the apostille and final certification request in 2025.

Media mentions
Country Manager María Inés Menvielle outlines Argentina’s updated immigration rules and their implications for business and foreign talent.

Media mentions

Media mentions
Partner Marius Tollenaere discussed how a digital “Super-Agency” could streamline Germany’s skilled migration.

Blog post
Senior Immigration Program Manager Alexia Prior and Senior Immigration Programme Consultant Julia Daoud discuss the importance of crisis preparedness in the face of geopolitical instability, emphasizing proactive strategies and resilience planning.

Video
In this Mobility Minute, Immigration Consultant Caryn Esther Fisher discusses recent South African citizenship updates.

Awards
Partner F. Joseph Paldino, Senior Associate Clark Cannon and Associate Mallorie Mecham are recognized in Utah Business’s 2025 Legal Elite.

Media mentions
Partner Daniel Pierce discussed how heightened immigration enforcement is causing employers to review work authorization and staffing decisions.

Fragomen news
Fragomen announces it is deepening its capabilities in the Philippines with a new office in Bonifacio Global City, the leading business and lifestyle district in Metro Manila.

Blog post
Associates Ali Ali and Charlotte Roberts discuss how UK employers can sponsor skilled workers using discounted salary rates to meet immigration requirements.

Media mentions
Partner Marius Tollenaere betont, dass die Chancenkarte die Einreise von Fachkräften nach Deutschland erleichtern, bürokratische Hürden abbauen und die Effizienz durch eine bessere digitale Integration und weniger Kontaktpunkte steigern kann.

Media mentions
Partner Abeer Al Husseini emphasises that mobility providers are essential for navigating regulatory frameworks, integrating Saudi nationals into the private sector and ensuring compliance with Saudisation policies, all of which support Saudi Arabia's Vision 2030.

Blog post
In this blog, Maja Sugui and Priyanka Gadekar explain how to obtain a Police Clearance Certificate in Germany, and the changes for the apostille and final certification request in 2025.

Media mentions
Country Manager María Inés Menvielle outlines Argentina’s updated immigration rules and their implications for business and foreign talent.

Media mentions