Holiday and Working Time: UK Working Time Regulations vs Italy (D.Lgs 66/2003 and CCNL)

UK and Italian working-time law both come from the EU Working Time Directive, so the bones look familiar. The differences are in how holiday is counted, how much CCNLs add, and the fact that Italy has no individual opt-out from the 48-hour week.

UK holiday: 5.6 weeks including bank holidays  

The Working Time Regulations 1998 give workers 5.6 weeks of paid holiday a year (28 days for a five-day week, capped at 28 days). Employers can include the eight bank holidays in England and Wales within this total. See gov.uk on holiday entitlement . Irregular-hours and part-year workers have accrual rules introduced from April 2024.

Italian holiday: 4 weeks plus public holidays plus CCNL leave  

Article 10 of Legislative Decree 66/2003 gives at least four weeks of paid holiday a year. At least two weeks must be taken in the year they accrue (consecutively if the employee asks), and the rest within 18 months of the end of that year, unless the CCNL says otherwise. Holiday cannot be replaced by a payment except when employment ends.

On top of this:

• Public holidays are separate and paid. Italy has a list of national holidays set by law (Law 260/1949 and later amendments) plus the local patron saint’s day. From 2026 there are 12 that can fall on a working day (Easter Sunday aside), after Law 151/2025 restored 4 October (St Francis). If a holiday falls on a Sunday, the CCNL usually gives an extra day’s pay.
• ROL and ex-festività: many CCNLs grant additional paid leave hours (riduzione orario di lavoro and hours replacing abolished holidays). Depending on the agreement, these can add the equivalent of one to two weeks a year.

So an Italian employee often ends up with more paid time off than a UK employee on statutory terms, and it is spread across three different buckets that payroll must track.

Working time limits  

The UK opt-out is the most visible difference. A UK employee can sign a written agreement to work more than 48 hours on average ( gov.uk ). Italy has no such mechanism. The 48-hour average applies, and overtime must stay within the annual caps and be paid with the premiums set by the CCNL. Senior managers (dirigenti) and some autonomous roles are partially excluded from the limits.

Normal hours and overtime  

In Italy the normal working week is 40 hours (article 3), and many CCNLs set a lower figure. Hours beyond this are overtime (lavoro straordinario), limited to 250 hours a year unless the CCNL sets otherwise, and paid at a premium. In the UK overtime pay is contractual, and many salaried professionals are expected to work “reasonable additional hours” without extra pay. That expectation does not carry over: an Italian employee on a standard level who regularly works late is accruing paid overtime.

Remote work and the right to disconnect  

Italian “lavoro agile” (smart working) under Law 81/2017 requires an individual written agreement covering how work is done away from the office, rest periods and the technical and organisational measures to ensure disconnection. In the UK, flexible working is a request process, and the Employment Rights Act 2025 strengthens the employer’s duty to justify refusals. For a fully remote Italian hire, the contract and the remote work terms need to fit the CCNL.

Holiday pay and payout  

Both countries require holiday pay to reflect normal remuneration. In Italy, unused holiday is paid out only when employment ends; otherwise it must be taken. Letting holiday build up is a cost and compliance risk, as contributions on unused holiday can become due after the 18-month deadline.

August and company shutdowns  

Italian working culture is organised around summer. Many businesses and clients close for one to three weeks around mid-August (Ferragosto, 15 August), and CCNLs allow employers to schedule collective holiday periods after consulting staff representatives. A UK company may not want to shut down, but should expect Italian clients and suppliers to be unavailable and staff to request leave at the same time. Plan cover and deadlines early in the year, and agree holiday planning rules that fit both the business and the two-week rule for the current year.

Common mistakes UK employers make  

• Counting public holidays inside the four weeks. In Italy they are additional, unlike the UK option to include bank holidays in 5.6 weeks.
• Paying holiday instead of letting it be taken. Payment in lieu is allowed only on termination.
• Asking for an opt-out. There is no Italian equivalent; the 48-hour average applies.
• Ignoring ROL hours. They are paid leave entitlements and accumulate on payslips.
• Treating salaried staff as “no overtime”. Unless the role is managerial or the CCNL provides an all-in arrangement, extra hours are paid.

What this means if you hire through an EOR  

The EOR’s payroll tracks holiday, public holidays, ROL and overtime under the CCNL, and puts the balances on each payslip. Your managers approve leave and should encourage people to take it within the legal windows. Avoid UK assumptions about “unlimited” hours for salaried staff, and agree remote working terms at offer stage. Our contract checklist covers the documents needed.

The bottom line  

UK and Italian working-time rules share a European foundation, but Italy gives more paid time off once public holidays and CCNL leave are added, does not allow an opt-out from the 48-hour average, and pays overtime by default. Budget for the extra leave, plan around August and agree remote-work terms at the start. Then the rules become routine payroll, not a source of disputes.

Related guides for UK companies  

• Written statement vs Italian contract and CCNL
• SSP vs Italian sick leave
• Maternity, paternity and parental leave
• Italy vs UK overview and the cost calculator

General information, not legal advice. Contact us to check the CCNL rules for a role.