In short. Posting non-EU workers to Italy, for example Chinese employees of a company based in China, uses one of the quota-exempt channels of the Testo Unico Immigrazione (Consolidated Immigration Act). The channel depends on the activity: Model D for managers and highly specialised staff, Model M for services under a contract for works or services (appalto), Mod. ICT for transfers within a corporate group and letter i-bis for employees of foreign companies controlled by or affiliated with Italian companies. The old Model L is no longer used. The application is submitted online on the Interior Ministry’s Portale ALI.
A foreign company that needs to send its own employees to Italy for a period of time does not go through the Decreto Flussi (Italy’s annual decree setting quotas for foreign workers). Article 27 of Legislative Decree (D.Lgs.) 286/1998 provides for a series of special cases of entry for work outside the quotas, for which the nulla osta (work/entry clearance) can be requested at any time of the year.
The key point is choosing the right form: it depends on what the worker will do in Italy and on the relationship between the foreign company and the Italian one. In this guide we compare the channels available today: Model D, Model M, the intra-corporate transfer (ICT) and letter i-bis. We also explain why Model L, still mentioned in many guides, can no longer be used.
Which forms are used for posting foreign workers to Italy?
The nulla osta application is submitted online on the Interior Ministry’s Portale ALI to the Sportello Unico per l’Immigrazione (Immigration Desk) of the competent Prefettura (the local office of the Interior Ministry). For postings, the main forms are:
- Model D (Modello D): application for a nulla osta for the posting of managers or highly specialised staff (Article 27(1)(a)).
- Model M (Modello M): named application for a nulla osta for employed work for the posting of workers to carry out services under a contract for works or services (Article 27(1)(i)).
- Mod. ICT: nulla osta for the intra-corporate transfer of managers, specialists and trainee employees (Article 27-quinquies), explained in our guide to intra-corporate transfers (ICT).
- Letter i-bis: nulla osta for employees of foreign companies in which an Italian company holds an interest, to be employed at the Italian sites (Article 27(1)(i-bis)).
When is Model D used?
Model D covers the posting of managers or highly specialised staff to a company that has its registered office or branches in Italy, to a representative office of a foreign company whose head office is in a member state of the World Trade Organization, or to the head office in Italy of Italian companies or companies from other EU Member States.
Under Article 40(5) of the implementing regulation (DPR 394/1999), the worker must have particular knowledge classed as highly specialised by the collective agreement and must have been employed for at least six months in the same sector. The posting lasts as long as the actual need, with an overall limit of five years including extensions. Full details are in our guide to Model D.
When is Model M used?
Model M covers employees of a company based abroad, paid directly by that company, who are temporarily transferred to Italy to carry out services under a contract for works or services (appalto) with a client in Italy (Article 27(1)(i)).
The nulla osta is requested by the Italian contracting client (appaltante), is valid for the time needed to complete the works or service and requires, among other things, notice to the trade unions in the sector and compliance with the minimum pay set by the collective agreement. If the employer is based in another EU Member State, the nulla osta is replaced by a notification (paragraph 1-bis). The whole procedure is in our guide to Model M.
Employees of a foreign subsidiary: what does letter i-bis provide?
Letter i-bis of Article 27(1) covers workers who, in the 48 months before the application, have been employed for at least 12 months by companies based in Italy or by companies in which they hold an interest that operate outside the European Union. These companies are identified on the basis of the Italian company’s latest consolidated financial statements. The nulla osta allows these workers to be employed at the Italian sites.
It is the typical channel for an Italian group with plants or branches abroad that wants to bring to Italy staff already trained at its foreign sites. Here too the application is outside the quotas and is submitted online on the Portale ALI. Companies that have signed a memorandum of understanding (protocollo d’intesa) with the Ministry of the Interior replace the nulla osta with a notification (Article 27(1-ter) and (1-quater)).
Is Model L still used?
No. Model L was used for the temporary entry of workers called on to carry out specific functions or tasks (Article 27(1)(g)). That letter was repealed by Legislative Decree 29 December 2016, no. 253, the same decree that introduced the intra-corporate transfer.
Today, to bring an employee of a foreign group to Italy for a limited period, the options to assess are the intra-corporate transfer (Mod. ICT) or, for managers and highly specialised staff, Model D. If the foreign company carries out works for an Italian client, the channel is Model M. Guides and forms that still refer to letter (g) should be considered out of date.
Which form applies to Chinese employees posted to an Italian company?
Take a company based in China that needs to send some employees to an Italian company for a period of time. The choice of form depends on the activity:
- if they are coming to manage or to bring highly specialised skills to a company in the same group or one with a registered office or branch in Italy, Model D is considered or, if the group requirement and the three-month length-of-service requirement are met, the Mod. ICT;
- if they have been employed for at least 12 months, in the last 48, by a Chinese company in which the Italian company holds an interest, and are coming to work at its Italian sites, letter i-bis is considered;
- if the Italian company has entrusted the Chinese company with works or a service under a contract (appalto), and the employees are coming to carry it out, Model M is used.
In all cases, foreign documents, such as the posting letter or the company register extract, must be translated into Italian and legalised by the Italian consular authority, unless an international agreement exempts them. See our guide to apostille and legalisation of foreign documents.
What do these postings have in common?
- Outside the quotas: the application does not depend on the Decreto Flussi click days (the dates on which quota applications can be submitted online).
- Online application: on the Portale ALI, to the competent Sportello Unico per l’Immigrazione.
- Work visa: after the nulla osta is issued, the worker applies for it at the Italian consulate.
- Arrival in Italy: within eight days of entry, the worker goes to the Sportello Unico for the formalities relating to the permesso di soggiorno (residence permit).
- Temporary nature: the permit is tied to the posting and, in general, does not allow work for other employers.
- Memorandum of understanding: for Model D and letter i-bis, companies that have signed a protocollo d’intesa with the Ministry of the Interior send a notification instead of applying for a nulla osta (Article 27(1-ter) and (1-quater)).
- Checks: since 2025 (Decree-Law 146/2025), Article 27 provides for checks on the truthfulness of the employer’s declarations.
Which mistakes should be avoided when posting foreign workers?
- Wrong channel: using Model D for a group employee who falls under the intra-corporate transfer, or the other way round.
- Outdated forms: filing a Model L, which no longer has a legal basis.
- Undocumented contract: sending workers without a written contract for works or services or without notifying the trade unions in advance.
- Different activity: employing the worker on a site or service other than the one stated in the application.
- Pay: failing to guarantee at least the minimum set by the applicable Italian collective agreement.
Frequently asked questions
Does posting foreign workers to Italy fall under the Decreto Flussi?
No. Postings under Article 27 of the Consolidated Immigration Act are special cases outside the quotas, so they do not depend on the Decreto Flussi click days. The nulla osta application can be submitted at any time of the year, online on the Portale ALI, to the competent Sportello Unico per l’Immigrazione.
Who submits the nulla osta application?
The party in Italy indicated by the law: the company or Italian office for Model D, the Italian contracting client for Model M, and the company based in Italy for letter i-bis. The application is sent online through the Portale ALI to the Sportello Unico per l’Immigrazione of the competent Prefettura, not by the worker.
What is the difference between Model D and Mod. ICT?
Both concern managers and specialised staff. Mod. ICT follows Article 27-quinquies, with its own requirements: same group, at least three months of employment and a maximum of three years. Model D follows Article 27(1)(a), with six months in the sector and a five-year limit. The right channel must be checked case by case.
Can posted workers stay in Italy after the posting?
In general, no: the residence permit is tied to the posting and does not allow work for other employers. For Model D there is the possibility of being hired by the Italian company at the end; in other cases a new procedure is needed.
Does Model L still exist?
No. Model L corresponded to Article 27(1)(g) of the Consolidated Immigration Act, which was repealed by Legislative Decree 253/2016. Today temporary transfers within a group follow the Mod. ICT, Model D or, for employees of foreign companies in which an Italian company holds an interest, letter i-bis.
Must posted workers be paid under Italian collective agreements?
Yes. They must receive at least the minimum pay set by the collective agreement for the sector, and social security contributions must be paid, subject to any social security agreements between Italy and the country of origin.
Do foreign documents need to be translated and legalised?
Yes, as a rule. The posting letter, the company register extract and other foreign company documents must be translated into Italian and legalised by the Italian consular authority or apostilled, unless an international agreement exempts them. Always check the instructions of the competent Sportello Unico before submitting the application.
Official sources
- Testo Unico Immigrazione, D.Lgs. 286/1998, Article 27 — Normattiva
- DPR 394/1999, Article 40 — Normattiva
- Portale Servizi ALI — Ministry of the Interior
The sources were consulted on 15 October 2026. Forms and instructions may vary between Prefetture: always check the latest guidance from the competent Sportello Unico.
How can SH Immigration Specialists help?
SH Immigration Specialists helps companies posting foreign workers to Italy identify the right channel, prepare the posting letter and company documents, complete the form on the Portale ALI and follow the visa and permit stages. The outcome depends on the competent authorities. For an assessment of your case, contact us. All our services for companies are on the page hiring foreign workers in Italy.
This content provides general information and does not constitute legal advice.
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