The Credit-Based License in Construction: Operational Instructions from the Inspectorate

1. The fact

   According to reports by outlets such as Il Sole 24 Ore, October 1, 2024, marked the official launch of the credit-based license obligation for companies and self-employed workers operating in temporary or mobile construction sites. The initial phase was characterized by an intense technical debate regarding the functionality of the National Labour Inspectorate (INL) portal and the procedures for submitting self-certifications.

   Currently, the situation is in a phase of full administrative operation. The issuance of Circular no. 4 on September 23, 2024, by the INL provided the necessary clarifications for managing the transitional period, establishing that until October 31, 2024, it is possible to operate by sending a certified email (PEC), while the obligation to submit the final application on the portal by the end of the month remains. The news is part of a structural reform of workplace safety, aiming to condition access to construction sites on the possession of minimum documentary and training requirements.

2. 

   The rules at stake

   The core regulation is contained in Article 27 of Legislative Decree 81/2008, as recently amended.

   1. Ministerial Decree 132/2024 establishes the regulation for issuing the license, which is issued in digital format with an initial score of 30 credits.
   2. Mandatory requirements include registration with the Chamber of Commerce, possession of DURC (social security compliance), DVR (risk assessment), and DURF (fiscal regularity), in addition to fulfilling training obligations.
   3. Sanctions for those operating without a license or with a score below 15 credits are severe: an administrative penalty of 10% of the work value is provided, with a minimum of 6,000 euros, plus exclusion from participating in public works for 5 years.

3. What the jurisprudence says

   Given the novelty of the regulation, there are no specific rulings on the credit-based license yet, but higher court jurisprudence has already consolidated principles on similar legal concepts.

   1. Regarding social security compliance, it has been clarified that possession of requirements must be continuous, not limited to the moment of site access.
   2. Administrative jurisprudence has also specified that measures to revoke or suspend enabling titles must respect the principle of proportionality, ensuring the sanction is adequate to the severity of the non-compliance found by the supervisory body.

5. Analysis drafted and verified with edit.legal

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8. What it teaches professionals

   1. Constantly monitor the validity of the DURC, as its expiration can automatically invalidate the license.
   2. Do not stop at sending the transitional PEC but complete the procedure on the INL portal to avoid forfeiture of the title.
   3. Verify that every subcontractor holds a license with at least 15 credits to avoid challenges regarding site supervision.
   4. Update the DVR in real-time with every organizational change, as revocation for false declarations rarely admits excuses of blameless ignorance.

References: Articolo 27 D.Lgs. 81/2008D.M. 18 settembre 2024 n. 132Circolare INL n. 4/2024D.Lgs. 231/2001

Editorial oversight: Avv. Federico Papa·ICAMUpdated 23 September 2026Content drafted with AI support and subject to editorial source checks. Despite these controls, inaccuracies may remain: reports and rectification requests are welcome. Report a correction