Complementary Protection Recognised on the Basis of Work Integration_ the Florence Court Decision of 24 December 2025

Complementary Protection Recognised on the Basis of Work Integration: the Florence Court Decision of 24 December 2025 Good morning, my name is Avvocato Fabio Loscerbo, and this is a new episode of the podcast Immigration Law. In today’s episode, we look at a very important decision issued by the Ordinary Court of Florence on 24 December 2025, at the end of proceedings registered under general docket number 6262 of 2024. This ruling clearly addresses the scope of complementary protection based on work integration after the legislative changes introduced by Decree-Law No. 20 of 2023. The case concerned a foreign national whose application for refugee status and other forms of international protection had been rejected by the Territorial Commission. Before the Court, the claim was limited to complementary protection, relying in particular on the right to respect for private life developed in Italy through a stable path of integration, especially from a professional point of view. The Florence Court upheld the appeal and recognised the right to a residence permit for special protection, ordering the competent Questore to issue the permit. This decision is significant because it clarifies that the 2023 reform did not abolish the protection of private and family life, nor did it empty complementary protection of its substance. According to the Court, the partial repeal of Article 19 of the Consolidated Immigration Act affected the legislative typification of the criteria, but not the essence of the protection itself, which continues to be grounded in constitutional principles and international obligations, in particular Article 8 of the European Convention on Human Rights. In assessing the individual case, the Court placed central importance on the applicant’s work integration. It gave weight to the existence of stable and lawful employment, economic self-sufficiency, lawful housing, and a network of social relationships consistent with a lawful and rule-abiding presence in Italy. In such circumstances, removal from the national territory would have been disproportionate and detrimental to the right to respect for private life. A particularly important aspect of the decision concerns the time factor. The Court expressly stated that integration achieved during the period required to examine protection applications cannot be regarded as artificial or irrelevant. Time spent waiting is real life time, during which social and professional ties are formed and consolidated, and these ties must be taken into account by the legal system. The message emerging from this decision is clear: integration, and in particular work integration, remains the key legal criterion for complementary protection. This is not an amnesty, but a balancing instrument between the protection of fundamental rights and the governance of migration. The Florence Court’s decision of 24 December 2025 therefore represents an important reference point for understanding how case law is developing on complementary protection after 2023 and provides concrete guidance for practitioners in the field of immigration law. Thank you for listening, and see you in the next episode of Immigration Law.