General counsel compensation in Italy: benchmarks, and the levers that close.

Start with what the state actually fixes. The collective agreement for dirigenti of companies producing goods and services, renewed by Confindustria and Federmanager on 13 November 2024 and in force from 1 January 2025 to 31 December 2027, sets a Trattamento Minimo Complessivo di Garanzia that rose to 80,000 euro for 2025 and to 85,000 euro from 2026, from 75,000 euro in 2023. Il Sole 24 Ore reported the same steps on the day of signature and put the covered population at about 80,000 managers in post. That figure is a classification floor, tested each 31 December against the whole guaranteed treatment. It is not a market rate for a head of legal, and it is not a Milan rate for anything.

A floor is not a market, and a market model is not an offer. What the same renewal did to the rest of the package matters more to a buyer than the floor does. Adoption of a variable scheme linked to indices or results became obligatory for every covered employer, with maternity, paternity and parental leave counted into the calculation, as the Gianni & Origoni client note of 25 November 2024 records. For a company that cannot move base, that is the first contractual fact worth knowing: the variable must exist. Nothing in the agreement fixes its target percentage, its metrics or its payout curve, so the whole of that instrument is available to design and none of it is available to omit.

Underneath the negotiation sit the components that accrue regardless. Article 2120 of the Civil Code accrues trattamento di fine rapporto at one thirteen-point-five of annual pay, revalued each 31 December at 1.5 percent plus 75 percent of the ISTAT FOI index, and includes the cash equivalent of non-occasional benefits in kind while excluding expense reimbursements. The Cassazione labor section restated that scope in ordinance 30331 of 17 November 2025: absent an explicit collective exclusion, non-occasional sums that are not reimbursements enter the accrual. A buyer who treats severance as an exit problem has already mispriced the seat, because it is a monthly cost settled later.

Deferred pay comes first, because in 2026 it also became a cash-flow question. Law 199 of 30 December 2025, at Article 1, paragraph 203, widened the duty to pay accruing severance into the INPS treasury fund rather than keep it on the company's own books: on the prior calendar year's average headcount, the threshold is 60 employees for 2026 and 2027, 50 for 2028 to 2031, and 40 from 1 January 2032, with INPS Circular 12 of 5 February 2026 setting out the mechanics and the monthly amount computed net of the 0.50 percent contribution under Law 297/1982. Entry is definitive: a later fall in headcount does not reverse it. A growing Italian group that crossed 60 employees during 2025 lost the use of that money from January 2026, which is a balance-sheet fact and not a candidate-facing one, and it is exactly the kind of change that arrives in a compensation discussion as an unexplained tightening.

Complementary pension is the second, and the 2024 renewal moved it in the company's direction on purpose. Previndai's contribution schedule, on rates in force from 1 January 2025, sets a company contribution of 4 percent of pensionable pay with an annual floor of 4,800 euro plus a further 2 percent, against 2 percent from the manager, all inside a 200,000 euro annual cap, with the option for the firm to take on one of the manager's two points by agreement. Previndai's own worked example, on 80,000 euro of pensionable pay, puts the total contribution at 8,000 euro, of which 6,400 is the company's. Gianni & Origoni's note of 25 November 2024 confirms the split moved from four and four to six and two at that cap, and records death and invalidity cover rising to 300,000 and 400,000 euro. Two contribution points changing hands is not a headline; over a five-year tenure it is a material transfer that no salary benchmark captures.

Over the trailing three years Sartori's Milan mandate telemetry records 17 closed in-house searches, with a 93 percent completion rate, a median of 16 working days between offer and signature, and a typical timeline of four to seven months from brief to start date. Counter-offer incidence on those mandates ran 26 percent over the same three years. Nine of the 17 were priced on a manager classification and eight on a middle manager or first-manager band, and the classification was settled before the search opened in only eleven of them. That last figure is the operational heart of this article: a third of the files re-opened the question that decides the floor, the pension instrument and the maximum restraint after candidates were already in process.

The interview base is separate from the mandate base and larger. Across 250 structured interviews with Milan general counsel, heads of legal and senior in-house counsel, the 96 respondents sitting inside family-controlled groups over a rolling 24-month window described their variable pay as discretionary and unwritten; 61 of those 96 said the scheme had never been reduced to writing at all. Read against the contractual obligation that has applied to covered industrial employers since January 2025, that is not a preference. It is a gap between what a company believes it is offering and what its own collective agreement requires it to have.

The second cut is the one foreign-owned buyers lose offers on. Of the same cohort, the 71 respondents employed by Italian subsidiaries of foreign parents were asked, over the same 24-month window, whether they could state the grant-date value of their own long-term award. Nineteen could. The rest described the instrument by name and could not price it. A candidate who cannot value the component that is supposed to justify a lower Italian base will discount it to zero when a competing offer arrives with a car, a written welfare plan and a paid restraint attached.

Sartori's coverage of this market is built from the same records the findings come from: roughly 5,000 lawyers mapped in Milan sit inside a global research program of nearly 1.5 million mapped lawyer profiles, thousands of mandate and process records, and quarterly market surveys running since 2019.

The uncomfortable number is ours. Four of the 17 closed mandates ran past seven months, and all four were at family-controlled groups where the classification was re-opened after an offer had gone out. We do not get to describe that as a market condition: it is a brief we accepted without settling the question first, and the fix is a specification discipline rather than a sourcing one. Our own files also carry no reliable value for the equity component in the majority of foreign-parent packages we advise on, which means the single most important variable in that column is one our data cannot see.