Article 14, second paragraph, of the Third Sector Code provides that "Third sector entities with revenues, annuities, proceeds or revenues however denominated in excess of one hundred thousand euros per year must in any case publish annually and keep updated on their website, or on the website of the association network referred to in article 41 to which they belong, any emoluments, fees or considerations for any reason attributed to the members of the administrative and control bodies, to the executives as well as to the associates".

The Ministry of Labour, with Note dated 12 January no. 293, provided clarification on how to fulfill the aforementioned obligation:

  1. The obligation to publish, from a subjective point of view, does not concern the generality of the ETS, but only the organizations with revenues, annuities, proceeds or revenues however denominated in excess of one hundred thousand euros per year: through this delimitation, the attention of the legislator in the ' avoid burdening smaller ETSs with obligations that are disproportionate to the aim of transparency pursued, in the terms clarified in the text of the Note.
  2. The object of the publication are the emoluments, fees or considerations for any reason attributed to the following categories of recipients: holders of corporate offices, executives and associates.
  3. A nominative publication will not be necessary whenever it will be possible to publish information valid for all subjects belonging to a certain category (e.g. specifying the treatment envisaged both for the members of the control body and the increase due to the chairman of the same; or identifying one or more salary categories among managers and specifying the gross salary associated with each of them). On the other hand, the publication of an aggregate datum is considered completely insufficient (since it is not characterized by levels of transparency in line with the provisions of the law), since different positions could be found within it which would not be brought into focus by those who were interested in the information. Equally, the amounts due by way of "salary" must be kept separate from those paid by way of "particular indemnity" (for example, parameterized to the days on which a particular body meets) or "reimbursement of expenses" (in this case, since it is of sums attributed against documented expenses, it may be sufficient to identify the number of beneficiaries, the average amount, the maximum and minimum amount recognized).

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