For companies operating in Italy, the supervisor, known in Italian as preposto, is one of the most important operational roles in the occupational health and safety system. The preposto is the person who supervises work activities, ensures that instructions are implemented and checks that workers perform their tasks safely and in line with company procedures.

This role is particularly relevant for foreign companies because it does not always correspond to a formal job title used at group level. A team leader, shift leader, warehouse coordinator, site supervisor, department lead or production line coordinator may be considered a preposto if, in practice, that person supervises the work of others and has the authority to intervene in daily operations.

Under Italian Legislative Decree No. 81/2008, the preposto has specific legal duties. The role was also strengthened by the 2021 legislative changes and by the new State-Regions Agreement of 17 April 2025, which updated the training framework for supervisors. For this reason, companies should not treat the preposto as a purely internal organisational label: it is a compliance role that must be identified, trained, documented and integrated into the company prevention system.

Preposti at a glance

What is a preposto in the Italian safety system?

Article 2 of Legislative Decree No. 81/2008 defines the preposto as the person who, within the limits of the powers received and the professional skills held, supervises work activities and guarantees the implementation of the employer’s instructions by checking the correct execution of work by workers.

In practical terms, the preposto is the link between the company’s safety organisation and the actual behaviour of workers on the floor, in the warehouse, on site, in the laboratory, in maintenance activities or in any operational area where tasks are performed. The preposto does not replace the employer, the RSPP or the manager, but has a daily supervisory function that is essential for making safety measures effective.

For foreign companies, the key issue is that the role is based on the actual function performed, not only on the job title. If an employee coordinates other workers, assigns tasks, checks that work is carried out correctly or has the authority to stop unsafe behaviour, the company should assess whether that person is acting as a preposto under Italian law.

Why the preposto is important for foreign companies

International organisations often manage safety through corporate policies, HSE managers and global reporting systems. These tools are useful, but Italian law also requires a local operational structure capable of supervising daily work. The preposto is one of the roles that makes this structure visible and effective.

The role is important because many accidents occur not because the company lacks formal documents, but because procedures are not followed in practice, workers use equipment incorrectly, PPE is not worn, unsafe behaviours are tolerated or dangerous conditions are not reported in time. The preposto is expected to supervise, intervene and report within the scope of his or her responsibilities.

From a business point of view, identifying preposti correctly also helps the company demonstrate that the prevention system is not only designed on paper but is implemented in the workplace. This is relevant during inspections, client audits, supplier qualification, insurance reviews and post-incident investigations.

Employer and manager obligations: identifying the preposto

Following the changes introduced by Law No. 215/2021, Article 18 of Legislative Decree No. 81/2008 requires the employer and managers to identify the preposto or preposti for the performance of supervision activities. This means that companies should not leave the role undefined where supervisory functions exist in practice.

The identification should be coherent with the organisation chart, actual reporting lines, job descriptions and the Risk Assessment Document. In many companies, more than one preposto may be needed, especially where there are different departments, shifts, production lines, warehouses, sites or teams operating at different times.

For foreign companies, the internal title used in English may not be decisive. A person called team coordinator, shift leader, lead operator or site lead may need to be treated as a preposto if the person performs supervisory functions. The safest approach is to map the actual organisation and identify who supervises workers in each operational context.

Main duties of the preposto under Article 19

Article 19 of Legislative Decree No. 81/2008 sets out the duties of the preposto. These duties are operational and relate to daily supervision. The preposto must supervise and monitor workers’ compliance with legal obligations, company safety provisions and the correct use of collective and personal protective equipment.

The preposto must also ensure that only workers who have received adequate instructions access areas that expose them to serious and specific risks. The role includes requesting compliance from workers, reporting deficiencies in equipment, PPE or dangerous conditions to the employer or manager, and attending specific training courses.

A particularly important point is the duty to intervene. If the preposto detects unsafe behaviour, the preposto must intervene to modify the behaviour and provide the necessary safety instructions. If non-compliance continues, the preposto must stop the worker’s activity and inform the direct superior. If deficiencies in equipment or dangerous conditions are detected, the preposto must, where necessary, temporarily interrupt the activity and promptly report the issue to the employer or manager.

This makes the preposto a practical control role. The company should therefore ensure that supervisors know not only general safety principles, but also what they are expected to do in real situations: how to intervene, when to stop an activity, who to inform and how to document critical situations.

Preposto of fact: why job titles are not enough

One of the most delicate issues for foreign companies is the so-called preposto di fatto, or de facto supervisor. A person may be considered a preposto because of the actual functions performed, even if no formal appointment letter uses that title.

This can happen when a senior worker coordinates others, when a line leader gives operational instructions, when a site coordinator supervises contractors, or when a warehouse supervisor controls the activity of operators. If the person has real supervisory authority, the company should evaluate the preposto role and the related training and documentation.

Ignoring de facto supervisory functions is risky. In the event of an inspection or accident, authorities may look at what people actually do, not only at the organisational chart. For this reason, formal identification, job descriptions, appointment letters and training records should be aligned with operational reality.

Training requirements for preposti

Under Article 37 of Legislative Decree No. 81/2008, preposti must receive adequate and specific training and periodic updates in relation to their health and safety duties. The current training framework is defined by the State-Regions Agreement of 17 April 2025, Rep. Acts No. 59/CSR.

The 2025 Agreement provides that access to the supervisor course is allowed only after the worker has completed general and specific worker training. The minimum duration of the supervisor course is 12 hours. The course covers the identification of the preposto, the de facto role, duties and obligations, relationships with other prevention roles, risk control, communication, cooperation and intervention methods.

The same Agreement requires refresher training for preposti every two years, with a minimum duration of 6 hours, and also whenever changes in risks or the emergence of new risks make it necessary. The refresher should relate to the supervisor’s tasks and to the technical, organisational and procedural prevention measures adopted following the company’s risk assessment.

The delivery method must also be checked carefully. Under the 2025 Agreement, supervisor training and supervisor refresher training may be delivered in physical attendance or synchronous videoconference, but not through asynchronous e-learning. This is a frequent issue for multinational companies that rely heavily on global e-learning platforms.

How preposti interact with the DVR, RSPP and RLS

The preposto role should be connected to the wider prevention system. The Risk Assessment Document identifies risks and prevention measures; the RSPP supports the employer in defining technical and organisational measures; the RLS represents workers and participates in consultation; the preposto checks that procedures and instructions are applied in everyday work.

For example, if the DVR identifies a risk connected with forklift operations, chemical handling, work at height, machinery or manual handling, the preposto must understand the relevant operating rules and supervise their application. If the preposto identifies unsafe behaviour or deficiencies, the information should flow back to managers, the employer and the prevention system.

This connection is important because the preposto should not be trained in isolation. Training, procedures and instructions should reflect the actual risks and control measures identified in the DVR. A generic supervisor course without connection to the company’s real operating context may not be enough to support effective supervision.

Appointment letters and documentation

Italian law focuses on the identification of preposti, and companies should be able to demonstrate that the role has been properly managed. In practice, many organisations use written appointment or identification letters to clarify the role, scope, department, reporting line and duties of each preposto.

Useful documentation normally includes the organisational chart, the list of identified preposti, appointment or identification letters, job descriptions, training certificates, refresher deadlines and procedures explaining how supervisors must report unsafe conditions or stop unsafe activities.

For foreign companies, documentation should be understandable both to local Italian stakeholders and to headquarters. Bilingual documentation can be useful, but the Italian legal terms should not be lost. The word preposto should normally be retained alongside the English working term supervisor.

Common mistakes made by foreign companies

The first common mistake is failing to identify preposti because the company does not use the Italian job title. In Italy, the legal analysis is based on the actual function performed.

A second mistake is assuming that a manager or RSPP automatically covers the preposto role for all operational areas. The RSPP provides technical support, while the preposto supervises daily work. These functions are different.

A third mistake is assigning supervisor training too late or treating it as a generic leadership course. The preposto training must meet Italian legal requirements and should be completed before or as early as possible when the person performs the supervisory function.

A fourth mistake is relying on asynchronous e-learning for supervisor training or refresher training. Under the 2025 Agreement, e-learning is not allowed for these courses.

A fifth mistake is not updating the supervisor list after reorganisations, new shifts, new sites, changes in production or changes in reporting lines. The preposto map should be reviewed whenever the organisation changes.

Practical checklist for companies

Foreign companies with employees in Italy should verify whether any workers perform supervisory functions. They should map team leaders, shift leaders, warehouse supervisors, site coordinators, production supervisors and any other roles that supervise work activities.

The company should then verify whether these people have been formally identified as preposti, whether they have completed worker general and specific training, whether they have completed the 12-hour supervisor course, whether refresher training is planned every two years and whether the delivery method used is compliant with the 2025 Agreement.

The company should also check whether supervisors know how to intervene in case of unsafe behaviour, how to stop unsafe activities, how to report dangerous conditions and how to interact with managers, the RSPP, workers and the RLS.

Quick workflow: managing preposti in Italy

FAQ

Is the preposto mandatory in every company in Italy?

The role is required where the organisation includes people who supervise work activities and ensure operational compliance. If supervisory functions exist, the company must identify the relevant preposto or preposti.

Can a team leader be considered a preposto?

Yes. If a team leader actually supervises workers, gives operational instructions or checks that work is performed correctly, the company should assess whether the person is acting as a preposto under Italian law.

Does the job title determine whether someone is a preposto?

No. The actual function is more important than the title. A person may be a de facto preposto even if the contract or organisational chart uses a different title.

Who identifies the preposto?

The employer and managers must identify the preposto or preposti for supervision activities, according to the company organisation and actual operational structure.

What are the main duties of a preposto?

The preposto supervises workers, checks compliance with safety rules and company procedures, ensures correct use of PPE and collective protection measures, reports deficiencies and dangerous conditions, and intervenes or stops activities when required.

Is preposto training additional to worker training?

Yes. The 2025 State-Regions Agreement states that access to the supervisor course is allowed only after completion of general and specific worker training.

How long is the preposto training course?

The minimum duration is 12 hours under the State-Regions Agreement of 17 April 2025.

How often must preposto training be updated?

Refresher training must be completed every two years, with a minimum duration of 6 hours, and whenever changes in risks or new risks make it necessary.

Can preposto training be delivered through e-learning?

No. Under the 2025 State-Regions Agreement, supervisor training and supervisor refresher training cannot be delivered through asynchronous e-learning. Physical attendance and synchronous videoconference are allowed.

Can the RSPP replace the preposto?

No. The RSPP provides technical support to the employer, while the preposto performs operational supervision. They are different roles.

Can a foreign manager be relevant for preposto duties?

Potentially yes, if the person actually supervises work activities in Italy and has operational authority. However, the practical ability to supervise and intervene must be assessed carefully.

What should a company do after a reorganisation?

It should review the list of preposti, update appointment or identification records, check training status and ensure that the DVR, procedures and reporting lines remain consistent with the new structure.

How Frareg can support foreign companies

Frareg supports companies operating in Italy in identifying preposti, mapping supervisory functions, planning mandatory training and refresher training, preparing role documentation and integrating supervisor duties into the wider occupational health and safety system.

For English-speaking companies, the objective is to make the Italian preposto role understandable, documented and manageable, while aligning local legal requirements with group-level HR, HSE and compliance processes.