Italy-Switzerland border workers: teleworking up to 25%

Law no. 217 of 29 December 2025 introduced a new rule for border workers working in Switzerland and residing in Italy.
Context
Key facts
- Law no. 217 of 29 December 2025, published in the Official Gazette on 19 January 2026, ratifies the Protocol amending the 2020 Agreement on the taxation of frontier workers. The Protocol has been in force since 9 February 2026 and applies from 1 January 2024.
- The new rule applies to all frontier workers covered by the 2020 Agreement, including those under the transitional regime.
- The legislation provides for frontier workers to be able to telework from their home in Italy for up to 25% of their working time in a calendar year, without any request to the tax administration.
Concrete examples
- A frontier worker who lives in Como and works in Lugano, with 220 working days a year, can telework for up to about 55 days (25%): one day a week, about 20% of working time, stays below the threshold.
- Another frontier worker who lives in Varese and works in Bellinzona exceeds the threshold by working from home two days a week (about 40% of working time): the frontier-worker status under the Agreement changes and taxation must be checked case by case.
Regulation
The Protocol, ratified by Law no. 217 of 29 December 2025, establishes that frontier workers may telework from their home in their State of residence for up to 25% of their employment activity in a calendar year without any change to their frontier-worker status. Within this share, the salary for telework is treated for tax purposes as work carried out in Switzerland at the employer. The Protocol sets no other requirements: the employment contract, equipment, internet connection and data protection are matters to agree with the employer, not legal conditions.
Operational Checklists
To perform teleworking effectively and safely, frontier workers must:
- Check that their employment contract provides for the possibility of teleworking;
- Install and configure the equipment needed for teleworking;
- Connect to the company network or use a cloud computing service;
- Comply with the rules on data protection and security of IT systems;
- Keep in touch with their supervisor and colleagues;
- Keep a record of telework days, because the 25% is calculated over the calendar year;
- Between 25% and 49.9% telework, check that the employer has requested the A1 certificate so that they remain insured in Switzerland.
Operational details
The new rule allows frontier workers to carry out up to 25% of their work by teleworking from their home in the State of residence. This means they can work from home for up to 25% of their working time in a calendar year.
The rule was agreed by Switzerland and Italy in the Protocol amending the 2020 Agreement on frontier workers: in force since 9 February 2026, it applies from 1 January 2024. According to the Federal Council press release of 13 February 2026, the Protocol settles the taxation of frontier workers' telework on a lasting basis.
But what exactly does this new rule mean for frontier workers? Here are some concrete examples to clarify this.
Let's imagine a frontier worker who lives in Luino and works in Lugano five days a week. The 25% is not calculated per day but over the calendar year: out of 220 working days, he can work from home for about 55 days, roughly one day a week, without changing his frontier-worker status.
Here is another example: a frontier worker who lives in Como, works in Mendrisio and works from home two days a week (about 40% of working time) exceeds the threshold: the frontier-worker status under the Agreement changes and taxation must be checked case by case.
The new rule applies to all frontier workers as defined by the 2020 Agreement, regardless of their nationality, including those under the transitional regime.
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Key points
The 25% rule was not introduced by the Ticino tax administration: it is the result of the Protocol agreed between Switzerland and Italy, in force since 9 February 2026 and applicable from 1 January 2024. It allows frontier workers to do up to 25% of their work from home in a calendar year without changing their status: the salary for telework continues to be taxed under the rules of the Agreement, as work carried out in Switzerland. It is not a tax exemption.
No request is needed to benefit from this rule: neither the Protocol nor the 2020 Agreement provides for an application to the tax administration or a report of telework days. The automatic exchange of information under Art. 7 of the Agreement goes from the Canton to the Italian Revenue Agency and covers personal data, Italian tax code, gross salary, social contributions, withholding tax and employer details, not telework days.
The Protocol sets no income threshold: the rule applies to all frontier workers as defined by the 2020 Agreement, including those under the transitional regime, who work for an employer in Switzerland.
Here are some concrete examples of how the rule works:
- A frontier worker who lives in Como and works as an engineer in Lugano can do up to 25% of his work from home, about 55 days out of 220: his salary is still taxed under the rules of the Agreement, as if he had worked in Switzerland.
- Another frontier worker who lives in Varese and works as an accountant in Bellinzona works from home two days a week, about 40% of working time: he exceeds the threshold, the frontier-worker status under the Agreement changes and taxation must be checked case by case.
There are two documented obligations. Between 25% and 49.9% telework, the Swiss employer requests the A1 certificate (via ALPS) so that the worker remains insured in Switzerland. In Ticino, if the employment ends during the year and the worker asks for it, the employer certifies the telework days already worked that year (Art. 5a of the Ticino withholding tax regulation).
Operational checklist:
- No request to the tax administration: the 25% limit applies directly
- Keep a record of telework days in the calendar year
- Between 25% and 49.9% telework, check that the employer has requested the A1 certificate
- In Ticino, if the employment ends during the year, ask the employer for the certificate of telework days worked
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Source: missionline.it
Official sources: Swiss Federal Council, press release of 13 February 2026 on the entry into force of the protocol (https://www.admin.ch/en/newnsb/KIyFJwwqspqaOcHDaT7u0); text of the amending protocol (https://www.newsd.admin.ch/newsd/message/attachments/88035.pdf); Fisco Oggi (Agenzia delle Entrate), ratification by Law No. 217 of 29 December 2025 (https://www.fiscooggi.it/portale/-/accordo-frontalieri-italia-svizzera-ratificato-l-aggiornamento-sul-telelavoro); Italian Ministry of Economy and Finance, release of 28 November 2023 on the 25% rule and the 2023 transitional arrangement (https://www.mef.gov.it/inevidenza/Frontalieri-accordo-Italia-Svizzera-telelavoro-fino-al-25-dal-1-gennaio-2024/); FSIO, Telework (https://www.bsv.admin.ch/de/telearbeit); Canton Ticino, DFE, press release of 13 January 2025 on the certificate of telework days (https://www4.ti.ch/tich/area-media/comunicati/dettaglio-comunicato?NEWS_ID=247871); Ticino tax administration, automatic exchange of information (https://www4.ti.ch/fileadmin/DFE/DC/DOC-IF/nuovo_accordo/Scambio_automatico_di_informazioni_CH-I.pdf).
Frequently Asked Questions
- How can I benefit from the new rule?
- No request to the tax administration is needed: the limit of 25% of working time in the calendar year applies directly. Between 25% and 49.9% telework, your employer must request the A1 certificate so that you remain insured in Switzerland.
- What are the conditions to benefit from the new rule?
- The new rule applies to all frontier workers covered by the 2020 Agreement, including those under the transitional regime: telework from home in Italy must not exceed 25% of working time in the calendar year.
- When does the new rule go into effect?
- The Protocol has been in force since 9 February 2026 and applies from 1 January 2024. The Italian ratification law no. 217 of 29 December 2025 was published in the Official Gazette on 19 January 2026.
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