From 1 March 2026, Law 27 February 2026 no. 26 – converting Decree-Law 27 December 2025, no. 202 (so-called Milleproroghe 2026) – published in the Official Gazette on 28 February 2026, has officially come into force. Among the numerous provisions for deferral and updating contained in the measure, there is a significant new development for healthcare professionals: the extension to 31 December 2028 of the deadline for obtaining ECM credits relating to the 2023-2025 training triennium.
This extension forms part of a regulatory framework already established by Article 38 bis of Decree-Law No. 152 of 6 November 2021, converted into Law No. 233 of 29 December 2021, No. 233, which had introduced an important – and perhaps little-known – regulatory link between healthcare professionals’ fulfilment of their CME training obligations and the validity of the insurance cover provided for professional civil liability. Under this provision, the validity of professional civil liability insurance policies taken out pursuant to Law No. 24 of 8 March 2017, No. 24 is conditional upon the fulfilment of at least 70% of the individual training requirement relating to the most recent three-year period relevant for the purposes of insurance cover – in this case, the period 2023–2025.
In practical terms, this means that insurance companies are entitled to verify compliance with this minimum threshold and, in the event of non-compliance, to refuse indemnity and contest the validity of the cover if the healthcare professional has not accrued at least 70% of the required CME credits. The 70% threshold is therefore highly significant for insurance purposes, without, however, reducing or replacing the full training obligation laid down by the professional body’s regulations.
The intervention of the Milleproroghe 2026 does not alter the fundamental principles of this regulation but postpones its operational effects: with its conversion into Law no. 26/2026, the legislator has established that credits relating to the three-year period 2023-2025 may be acquired by 31 December 2028. This time extension offers healthcare professionals a broader timeframe to rectify any training deficiencies, thus immediately avoiding potential issues concerning professional liability and insurance coverage.
It should be noted that the new three-year training period 2026-2028 will commence as scheduled on 1 January 2026, with the possibility for professionals to earn, during the transitional period, credits that are valid for both the previous and the current three-year period, according to the current rules of the ECM system.
The extension introduced by the ‘Milleproroghe’ decree – now enacted as law – is a measure designed to facilitate a gradual adjustment to training requirements, thereby preventing the immediate application of the mechanism set out in Article 38 bis from having potentially detrimental effects on the validity of insurance cover. The deferral until 31 December 2028 allows healthcare professionals to fully understand the legal significance of CME compliance and to plan how to meet the minimum threshold required for insurance purposes. It remains, however, that once the new deadline has passed, failure to achieve the 70% credits for the three-year period 2023–2025 may once again become relevant for the purposes of the policy’s validity, with possible implications for the handling of claims and indemnity.
Within this regulatory framework, professional development can no longer be considered a purely formal requirement. It is now firmly integrated into the healthcare risk management system and the structure of medical professional liability insurance guarantees. For this reason, it is appropriate for every professional to carefully monitor their ECM (Continuing Medical Education) status and fully understand its importance, not only to fulfil professional and ethical obligations but also – and one might even say primarily – to ensure the full effectiveness of their asset protection.
Here is the link:
https://www.gazzettaufficiale.it/eli/id/2026/02/28/26G00044/SG
