Redundancy fund in derogation for companies with production units located in five or more Regions and Autonomous Provinces. Operating Instructions. Accounting instructions. Change in the chart of accounts
*** 1. Introduction and regulatory framework
With circular letter no. 58 of 7 May 2020, the management of the measures to support income provided for by the decree-law of 17 March 2020, n. 18, converted, with amendments, by law 24 April 2020, n. 27, relating to the hypothesis of suspension or reduction of work activity due to events attributable to the epidemiological emergency from COVID-19 for the benefit of companies with production units located in five or more Regions and autonomous Provinces, so-called multi-localized, as established by the decree interministerial 24 March 2020 to article 2.
The measures relating to social safety nets provided for by decree-law no. 18/2020, were, therefore, extended by the decree-law of 19 May 2020, n. 34, converted, with amendments, by law 17 July 2020, n. 77. Subsequently, the decree-law of 16 June 2020, n. 52 (repealed by article 1, paragraph 2, of the aforementioned conversion law no.77 / 2020, which does not affect the effects produced and the legal relationships that arose) made further changes to the discipline of wage integration interventions, which also affected the redundancy fund payments in derogation.
The inter-ministerial decree of 20 June 2020, n. 9, issued by the Minister of Labor and Social Policies, in agreement with the Minister of Economy and Finance, and published on the website of the Ministry of Labor and Social Policies on 2 July 2020, established the procedures for implementing the provisions introduced with the aforementioned decree-law no. 34/2020, dividing the financial resources and providing for the consequent overall spending limits between the different institutional subjects responsible for the recognition of the treatments, as well as dictating, in article 1, the procedures for submitting applications for access to the wage supplement in derogation.
Following the circular no. 86 of 15 July 2020, which for the general aspects is considered referred to here, this message illustrates the innovations introduced in the matter of derogation redundancy fund (CIGD) by decree-law no. 34/2020, converted, with amendments, by law no. 77/2020, and by the decree-law n. 52/2020, with particular regard to the redundancy fund in derogation for the benefit of the so-called multi-location companies and operational indications are provided for the correct management of the flow of concession measures, as well as for the payment of services.2. “Covid-19 Emergency” wage supplementation treatment authorized by the Institute
. Article 71, paragraph 1, of decree-law no. 34/2020, amending the decree-law n. 18/2020, introduced articles 22-ter, 22-quater and 22-quinquies.
In particular, paragraph 1 of article 22-quater provides that the wage supplementation benefits in derogation, for the periods subsequent to the first nine weeks, are authorized by INPS, at the request of the employers.
Therefore, employers who have already been authorized by the Ministry of Labor and Social Policies to CIGD treatments for a total of nine weeks, regardless of the actual use of the entire authorized period, for subsequent periods of reduction or suspension of work activity (further five weeks) until 31 August 2020, they must electronically transmit the request for the concession directly to the Institute, which having verified the authorization relating to the previous period (nine weeks), having ascertained compliance with the spending limits and other requirements set by the standard – will authorize and provide the service.
In cases where employers have been authorized for periods of less than nine weeks, they will have to apply to the Ministry of Labor and Social Policies for the completion of this period, using the usual methods.
The rule therefore binds the granting of the additional five weeks to the fact that employers have already been authorized at least the first nine weeks of layoffs in derogation, without prejudice to the possibility of authorizing a longer period for companies located in municipalities. of the so-called “red areas” and for those with production units located in the so-called “yellow regions”. With a view to simplifying the procedures and to optimize the management of the requests, the Institute, in preparation for the admission of multi-location companies to the treatments in derogation of its competence, will verify the presence of an authorization provision referring only to the first nine weeks. It is understood that, for the same production unit, even partially coinciding periods with the ministerial or regional decree cannot be authorized. The request of the five weeks foreseen by the decree-law n. 34/2020 entails the non-proposability of applications for the further periods provided for by decree-law no. 18/2020 for these territorial areas.
In this regard, it is recalled that for companies with production units located in the municipalities referred to in article 22, paragraph 8-bis, of decree-law no. 18/2020 so-called “red zones” – as well as employers located outside the aforementioned municipalities but with workers resident or domiciled in the same municipalities, the grantable exemption redundancy fund has a maximum extendable duration of an additional three months compared to nine weeks provided for the generality of employers (twenty-two weeks overall), while for employers with production units located in the regions referred to in article 22, paragraph 8-quater, of decree-law no. 18/2020 so-called “Yellow Regions” – as well as those located outside the aforementioned Regions but with workers resident or domiciled in the same Regions,2.1 Additional period of layoffs in derogation
Employers who have fully used the period previously granted up to the maximum duration of fourteen weeks, for the purpose of accessing the additional four-week period – which may be requested for periods even prior to 1 September 2020 they will have to submit a specific application to the Institute.3. Financial resources
In order to cover the overall costs associated with the treatment in derogation, including the notional contribution and related allowances for the family unit (ANF), the inter-ministerial decree no. 9/2020 assigned the Institute a total of 900 million euros for the year 2020.4. Presentation of the application. Authorization of
the service With message no. 2856/2020 the provisions of the interministerial decree n. 9/2020, which established the procedures for implementing article 22-quater of decree-law no. 18/2020, according to which the redundancy fund payments in derogation, for the periods subsequent to the first nine weeks, are authorized by INPS, at the request of the employers.
Consequently, employers who have already authorized the entire period due, according to the indications previously provided, can apply to the Institute for a further period of five weeks, starting from 23 February 2020 to 31 August 2020, and, a once the aforementioned five weeks have been fully used, for any further four weeks for periods up to 31 October 2020.
Preliminarily, we remind you that employers who have been authorized for periods of less than at least nine weeks must submit an application for the completion of the weeks due to Ministry of Labor and Social Policies, before being able to forward the request to the Institute for the further five and any subsequent four weeks.
Therefore, due to the recent attribution to INPS of the application relating to the CIG in derogation for multi-location companies (2 July 2020), the IT procedure for submitting applications was made available from 24 July 2020 (see message no. 2946 / 2020). Employers who have mistakenly submitted an application for treatments other than the CIGD to which they would have been entitled or in any case with errors or omissions that have prevented its acceptance, may submit the application in the correct manner within thirty days from the communication of the error by the ” Administration of reference, under penalty of forfeiture, even pending the revocation of any concession provision issued by the competent Administration.
With regard to the methods of submitting applications, please refer to the information provided with message no. 2946/2020.
The applications must be accompanied by the trade union agreement, by the list of workers interested in the suspension or reduction of working hours, which shows the quantification of the hours of suspension, with the relative amount, company and unit data that benefits from the treatment, the reason for the intervention and the name of the referent of the application.
With message no. 2328/2020, instructions were provided for a management flow for sending applications to the Institute, so-called “simplified”, which allows companies that have multiple production units to submit a smaller number of applications, unifying them into merging production units, homogeneous by activity and by geographical location. Companies that have taken advantage of this possibility will have to submit applications for further periods using the same criterion as the merging production units.
On the “Sistema Unico” the aforementioned questions will be identified by the intervention code 667 and event code 673 and will be identified with the description “Multi-localized INPS derogation”.
This type of service in derogation is also defined by a provision of the Headquarters manager (or the delegated manager), with reference to the competent INPS territorial structure in relation to the single production unit.5. Method of payment of the service
As regards the type of payment, for multi-location companies, in addition to direct payment, there is also the possibility of anticipating the service and recovering the amount with the contribution adjustment system.5.1 Redundancy fund as an exception to balance
Article 70, paragraph 1, letter g), of decree-law no. 34/2020 added, in article 22 of the decree-law n. 18/2020, converted, with amendments, by law no. 27/2020, paragraph 6-bis which provides, exclusively for multi-location companies, that the treatment of CIGD can be granted with the modality of the adjustment and reimbursement of the service, as established in article 7 of Legislative Decree no. . 148/2015.
In order to ensure timely monitoring of the expenditure associated with the provision of the treatment in question, for the authorizations relating to ministerial decrees referring to periods of granting of CIGD, the companies concerned will use the methods of displaying the balance with the “Ticket system in the Uniemens flow. “, according to the instructions set out below.5.1.1 Use of the Event Code
For all CIGD events referred to in article 22, paragraph 4, of decree-law no. 34/2020 – managed with the “Ticket” system, companies must indicate the event code “CDR” (“Cassa Integrazione Guadagni in Waiver Request”), both in case of redundancy fund requested (not yet authorized) and after having received the authorization, and the code “T” must also be indicated in.5.1.2 “CIGD with Ticket”. Method of displaying the adjustment
Wage supplementation treatment in derogation for which the periods of 9, 13 or 22 weeks have already been authorized by the Ministry of Labor.
For the adjustment of advance benefits, employers will display the newly created code “G808 “, having the meaning of” CIGD adjustment for multi-location companies – Law Decree 19 May 2020, n. 34 paragraph 4 art. 22 “, in the element / / / / / /, and the amount set as an adjustment in the element, present at the same path.
“Covid-19 Emergency” redundancy fund, authorized by the Institute; extension of the further 5 and any subsequent 4 weeks
For the adjustment of the anticipated benefits, the employers will display the newly established code “G809”, with the meaning of “CIGD adjustment for multi-location companies – Law Decree 19 May 2020, n. 34 art. 22 quater, paragraph 1 – extension “, in the element / / / / / /, and the amount adjusted for the element, present at the same path.5.2 Direct payment in advance of 40% of the authorized hours
Please note that, in the case of a request for direct payment in advance, the INPS authorizes the applications and arranges the advance payment of the treatment, to the extent of 40% of the authorized hours in the the entire period, within 15 days of receipt of the applications. For the relative specifications, as well as for the terms of payment of the advance or for the balance of the payment of the salary supplement, please refer to the information provided in paragraph 4 of the aforementioned message no. 2489/2020, as well as circular letter no. 78/2020.6. Monitoring of expenditure
The Institute monitors expenditure and, in line with the provision referred to in article 3, paragraph 5, of the aforementioned inter-ministerial decree no. 9/2020, provides weekly, to the Ministry of Labor and Social Policies and the Ministry of Economy and Finance, the results of the activity carried out by means of reports that are made available in the “Information System of Receivers” (SIP ). In particular, with reference to COVID-19 performance, the reports are distinct as indicated in point f.1) of circular no. 47/2020.
The monitoring forms will report the estimate of the CIGD commitment made on the CIG requests in derogation granted for the applications for which the INPS has carried out the investigation and issued the relative authorization. The estimate of the commitment will be calculated by multiplying the authorized hours by the average cost of an hour of CIG. For the year 2020, the average hourly amount of the wage integration service in derogation for multi-location companies corresponds to € 8.90, including notional contribution and ANF.
If the total estimate of the CIGD measures adopted by INPS reaches the amount allocated by the interministerial decree no. 9/2020 of allocation of resources, it will no longer be possible to issue further concession measures, except in the case – illustrated in the previous period – in which it is possible to replace the estimate with the actual expenditure.7. Accounting instructions
Article 70, paragraph 1, letter g), of decree-law no. 34/2020 introduced, in article 22 of the decree-law n. 18/2020, converted, with amendments, by law no. 27/2020, paragraph 6-bis which establishes, exclusively for multi-location companies, that the redundancy fund payments in derogation can also be granted with the modality of the adjustment.
To this end, as part of the Management for welfare interventions and support for pension management separate accounting – Management of charges for wage maintenance (GAU), the following account is set up:
GAU30304 – to detect the burden relating to wage integration treatments in derogation and ANF related, paid to employees by companies with more “multi-location” production units operating throughout the national territory affected by the COVID-19 emergency, admitted to balance with the reporting system referred to in Ministerial Decree 5/2/69 art. 22, paragraph 1 and 6 bis of Legislative Decree 18/2020 converted with amendments into Law 27/2020 art. 70 and 71 of the Decree Law 19 May 2020, n. 34 converted, with amendments, into law 17 July 2020, n. 77,
to be combined with the element code “G808”, having the meaning of “CIGD adjustment for multi-location companies – Decree Law 19 May 2020, n. 34 paragraph 4 art. 22”.
For accounting instructions relating to the payment of benefits paid directly to beneficiary workers, please refer to message no. 1775/2020, whose accounts will be appropriately renamed.
Furthermore, with regard to the request for direct advance payment in the amount of 40% of the hours authorized in the entire period, please refer to the accounting instructions provided with circular no. 78/2020.
For the purposes of accounting evidence of the services relating to the redundancy fund treatments in derogation and also for companies with production units located in five or more Regions and autonomous Provinces, as indicated in Article 1, paragraph 1, letter c), and paragraph 2, of the decree n. 9/2020, of the Minister of Labor and Social Policies in agreement with the Minister of Economy and Finance, the new accounts are established:
Uniemens equalization benefits
GAU30314 – to detect the burden relating to wage integration treatments in derogation and ANF related, paid to employees by employers with more production units operating throughout the national territory affected by the COVID-19 emergency admitted to balance with the system of denunciation referred to in Ministerial Decree 5/2/69 art. 22, paragraph 1 of the Law Decree of 17 March 2020, n. 18, converted with modification by Law no. 27/2020 art. 70 and 71 of the Decree Law 19 May 2020, n. 34 converted with amendments by Law 17 July 2020, n. 77 art.1, paragraph 1 letter c) and paragraph 2 of the Interministerial Decree of 20 June 2020, n. 9,
to be combined with the element code “G809”, having the meaning “CIGD adjustment for multi-location companies – Decree Law 19 May 2020, n. 34 art. 22 quater, paragraph 1 extension”.
Direct payment services
GAU30328 – to detect the charge relating to wage supplementation in derogation and ANF related, paid directly to employees by employers operating throughout the national territory affected by the COVID-19 emergency art. 22, paragraph 1 of the Law Decree of 17 March 2020, n. 18, converted with modification by Law no. 27/2020 art. 70 and 71 of the Decree Law 19 May 2020, n. 34 converted with amendments by Law 17 July 2020, n. 77 art.1, paragraph 1 letter c) and paragraph 2 of the Interministerial Decree of 20 June 2020, n. 9;
GAU30326 – to detect the burden relating to wage integration treatments in derogation and connected ANF, paid directly to employees by employers with more production units operating throughout the national territory affected by the COVID-19 emergency art. 22, paragraph 1 of the Law Decree of 17 March 2020, n. 18, converted with modification by Law no. 27/2020 art. 70 and 71 of the Decree Law 19 May 2020, n. 34 converted with amendments by Law 17 July 2020, n. 77 art.1, paragraph 1 letter c) and paragraph 2 of the Interministerial Decree of 20 June 2020, n. 9.
The payables for the services provided with the centralized payment accounting procedure must be charged to the debit account in use GAU10160.
Any re-credit of sums for unsuccessful payments will be recorded in the account in use GPA10031, assisted by an accounting register, with the indication of the budget code “03217”.
For the accounting recognition of any recoveries of unduly paid or reintroduced services, the new account is created:
GAU24328 – to detect the recoveries and / or income from wage integration treatments in derogation and ANF related, to workers employed by employers even with more production units operating throughout the national territory affected by the COVID-19 emergency art. 22, paragraph 1 of the Law Decree of 17 March 2020, n. 18 art. 70 and 71 of the Decree Law 19 May 2020, n. 34 converted with amendments by Law 17 July 2020, n. 77 art.1, paragraph 1 letter c) and paragraph 2 of the Interministerial Decree of 20 June 2020, n. 9.
The budget code in use “1171” is associated with the aforementioned account, as part of the “Recovery for undue benefits” procedure.
Financial relations with the State will be defined by the Directorate General.
The change in the chart of accounts is shown in the attachment (Attachment no. 1).
Vicar General Manager
Vincenzo Caridi

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