La tutela giuridica del caregiver familiare nei sistemi di welfare state familistico. Quali spunti dalla comparazione per il legislatore italiano?

This article examines the legal protection of informal caregivers in familistic welfare regimes, with a particular focus on the regulatory frameworks adopted in Greece, Portugal and Spain and their potential relevance for Italian lawmakers. The article first distinguishes between formal and informal caregivers and sets out the problems arising from the lack of a coherent national framework on informal caregiving in Italy. It then analyses the main measures of support, work-care reconciliation, and financial recognition introduced in the four selected countries. The comparative analysis shows, on the one hand, that the Italian definition of informal caregiver is significantly narrower than those used elsewhere and, on the other, that the Italian rules protecting this figure are highly fragmented and unsystematic. Against this backdrop, the article argues for the adoption of a national framework law that would explicitly recognise informal caregivers as part of the care infrastructure; broaden the statutory definition of informal caregiver; establish a common core of rights, services and social and health-care benefits; and underpin these entitlements with credible guarantees of implementation.