In short. Model D (Modello D) is the application for a nulla osta (work/entry clearance) used when posting managers to Italy or highly specialised staff (Art. 27, paragraph 1(a), of the Testo Unico Immigrazione, the Consolidated Immigration Act). It falls outside the quotas and is submitted on the Portale ALI (the Ministry of the Interior’s online application portal). The worker must have worked for at least six months in the same sector, and the posting can last a maximum of five years, including extensions.
When a company with its registered office or branches in Italy needs a manager or a technician with rare skills who is employed abroad by an associated company, it can request their posting with Model D. This is one of the special cases under Article 27 of Legislative Decree 286/1998, regulated in detail by Article 40 of the implementing regulation (DPR 394/1999).
In this guide we look at the requirements, documents, procedure and duration. To choose between the different posting models, read the guide to posting non-EU workers to Italy.
Who can use Model D for posting managers to Italy?
Under Article 27, paragraph 1(a), the application concerns managers or highly specialised staff assigned to:
- companies with their registered office or branches in Italy;
- representative offices of foreign companies whose head office is in a Member State of the World Trade Organization;
- head offices in Italy of Italian companies or of companies from other European Union Member States.
The posting is normally to a branch, a subsidiary or a company in the same group. If the link between the companies does not appear in the visura camerale (Chamber of Commerce company report), it must be proved with translated and legalised foreign documents (see our guide to apostille and legalisation of foreign documents).
What requirements must the worker meet?
Article 40, paragraph 5, of DPR 394/1999 sets out three conditions:
- Qualification: the worker is a manager, or has particular knowledge that the applicable collective agreement classifies as highly specialised.
- Experience: they have been employed for at least six months in the same sector before the temporary transfer.
- Fixed duration: the posting is linked to a genuine need and lasts a maximum of five years, including extensions.
Which documents are needed for Model D?
The list may vary between Prefetture (local government offices). As a reference, the information sheet of the Friuli Venezia Giulia Region lists the following for the first nulla osta:
- two marche da bollo (revenue stamps) of €16;
- the worker’s passport;
- identity document of the legal representative, with residence permit if a foreign national;
- translated and legalised posting letter;
- documents on the link between the companies, if it does not appear in the visura;
- certificate of suitable accommodation;
- the company’s financial statements and latest tax return;
- certificate of social security coverage, for countries with social security agreements.
What must the posting letter contain?
It must state at least the sending company and the Italian company, the worker’s role and skills, the start date of the employment relationship, the expected length of the posting, the place of work in Italy, pay and working conditions, and the commitment to meet social security contribution obligations.
How does the Model D procedure work?
- Online application with Model D on the Portale ALI, to the competent Sportello Unico per l’Immigrazione (Immigration Desk).
- Nulla osta and contratto di soggiorno (residence contract): if the application is approved, the legal representative or a delegate signs the contratto di soggiorno at the Sportello and the nulla osta is sent to the consulate.
- Visa: the worker applies for a work visa at the Italian consulate in their country of residence.
- Entry: within eight days of arrival, the worker signs the contratto di soggiorno and the forms for the permit at the Sportello Unico (see our guide to the declaration of presence in Italy).
- Permit: the application is sent to the Questura (police immigration office) with the kit postale (post office application kit); with the receipt, the worker can start working.
Companies that have signed a memorandum of understanding with the Ministry of the Interior can use a simplified procedure: the nulla osta is replaced by an online notification (Art. 27, paragraphs 1-ter and 1-quater).
How long does the permit last and what happens at the end?
The nulla osta and the permesso di soggiorno (residence permit) last as long as the posting and can be extended within the overall limit of five years. The permit does not allow the holder to work for other employers.
At the end of the posting, or even earlier, the worker can be hired by the Italian host company, with the related mandatory notification. In this case, the permit is updated to reflect the new employment relationship.
Frequently asked questions
Is Model D subject to the Decreto Flussi quotas?
No. The posting of managers and highly specialised staff with Model D is outside the quotas of the Decreto Flussi, Italy’s annual decree on entry quotas for non-EU workers, so the application can be submitted on the Portale ALI at any time of the year rather than on a click day.
How long must the worker have worked for the foreign company?
Under Article 40, paragraph 5, of DPR 394/1999 the worker must have been employed for at least six months in the same sector before the temporary transfer to Italy. They must also be a manager or have knowledge that the applicable collective agreement classifies as highly specialised.
How long can the posting last?
The posting lasts as long as the genuine need that justifies it, up to a maximum of five years including extensions. The nulla osta and the residence permit last as long as the posting, and the permit does not allow the holder to work for other employers in Italy.
What is the difference from the ICT model (Mod. ICT)?
The Mod. ICT follows Article 27-quinquies: it requires membership of the same group and at least three months of employment, with a maximum of three years. Model D follows Article 27(a), with six months of experience and up to five years. Which route applies must be assessed case by case; see the guide to intra-corporate transfers (ICT).
Can the worker be hired in Italy after the posting?
Yes. At the end of the posting, or even earlier, the worker can be hired by the Italian host company, which must file the mandatory notification of employment. The residence permit is then updated to reflect the new employment relationship with the Italian company.
Official sources
- Testo Unico Immigrazione, Art. 27, paragraph 1(a) – Normattiva
- DPR 394/1999, Art. 40 – Normattiva
- Friuli Venezia Giulia Region – information sheet on the posting of managers and highly specialised staff
Sources checked on 15 October 2026. Documents and amounts may vary: always check the latest instructions from the competent Sportello Unico before submitting.
How can SH Immigration Specialists help?
SH Immigration Specialists supports companies in checking the requirements, preparing the posting letter and company documents, completing Model D on the Portale ALI and handling the visa and permit stages. The outcome depends on the competent authorities. For an assessment, 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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