Corporate Welfare and Fintech Solutions: Key Requirements Clarified by the Italian Corporate Welfare Association’s Circular No. 1/2026 1/2026
Knowing good advice Driven in part by developments in collective bargaining—most notably the recent renewal of the National Collective Labour Agreement (CCNL) for the Metalworking Industry and Plant Installation Sector—the corporate welfare market continues to evolve towards increasingly digital and flexible solutions. Against this backdrop, Technical Circular No. 1/2026 issued by the Italian Corporate Welfare Association (AIWA) revisits an issue that frequently gives rise to uncertainty when welfare benefits are managed through payment cards or digital wallets. The Circular clarifies that the mere fact that a merchant is equipped with a POS terminal is not sufficient to ensure compliance with the applicable tax legislation, particularly Article 51(3) of the Italian Income Tax Code (TUIR). The Circular replaces the previous AIWA Circular No. 4/2024, incorporating the guidance provided by the Italian Revenue Agency in Advance Tax Ruling (Interpello) No. 5/2025, and reflects the conclusions reached during a series of technical working groups held throughout 2025. What Are “Fintech Solutions” in Corporate Welfare? Within the corporate welfare framework, fintech solutions refer to technology-based financial applications that enable employees to access and spend their welfare credits through modern, fully traceable payment instruments, such as: digital wallets, debit or prepaid cards and payment applications operating on widely accepted payment networks. The Circular confirms that these solutions may qualify for the favourable tax treatment provided under Italian law, provided they comply with a number of specific structural requirements.It also warns that treating welfare benefits merely as an alternative payment method risks undermining their social purpose, transforming them into instruments designed primarily to achieve tax savings rather than to promote employees’ well-being. Mandatory Technical Requirements for Fringe Benefits Compliance with the applicable tax regime requires that all of the following conditions be satisfied simultaneously: Restricted payment network and prior merchant agreement: welfare credits must be spendable exclusively at merchants that have entered into a prior commercial agreement with the welfare provider. The presence of a POS terminal alone is insufficient. Merchants must be formally included in the provider’s authorised network, and employees must have access to the list of participating merchants, whether through printed materials, electronic platforms or mobile applications with geolocation features.No services may be provided outside this authorised network. No combination with personal funds: employees must not be permitted to combine welfare credits with their own money within the same transaction when using the same payment instrument, whether a card or a digital application. Absolute prohibition on cash transactions: the payment instrument must not allow cash withdrawals, cash deposits, transfers to third parties or cash reimbursements under any circumstances. Personal and non-transferable nature: the welfare instrument must be issued to a specific employee, may not be transferred to another person and cannot be sold or otherwise commercialised. Issuance prior to use: the entitlement document or voucher must be issued before the benefit is redeemed or used. Retrospective generation of vouchers after the transaction has taken place is not permitted. Accounting and Administrative Requirements: the Circular further clarifies that merchants must be able to identify each transaction as being made through a welfare voucher issued pursuant to Article 51(3) of the TUIR, clearly distinguishing it from an ordinary monetary payment.In addition, welfare providers are required to implement dedicated accounting procedures enabling client companies to correctly record these transactions in their financial statements. Practical Considerations Companies that currently provide, or are considering introducing, voucher cards, prepaid welfare cards or fintech-based digital wallets as part of their employee welfare programmes should carefully verify with their chosen provider that the proposed solution fully complies with all of the requirements outlined above.Given the complexity of the applicable tax, corporate and employment law rules, businesses should also seek appropriate professional advice to assess the administrative and legal implications of their welfare programmes and to ensure that they are structured in a manner that is both fully compliant and capable of delivering sustainable long-term benefits for employees. Date of publication Author Areas of activity Assistenza Fiscale (11) Assistenza Legale (2) Assistenza Societaria (1) Consulenza del lavoro (5) Kreston-TDL (1)