Residence Permit for Seasonal Work: When a Conversion Is Denied Because the Authorities Ignore the Worker’s Observations Good morning, and welcome to a new episode of the Immigration Law podcast. Today we examine a recurring and often problematic issue: the conversion of a residence permit for seasonal work into a residence permit for subordinate employment. This step is crucial for many foreign workers, because the stability of their stay and the continuity of their employment path depend on the correct handling of the conversion procedure. The case we take as our starting point was decided by the Regional Administrative Court of Calabria, Reggio Calabria division, in a judgment published on 24 November 2025, concerning proceedings registered under number 3 of 2025. The court annulled a refusal of conversion because the Prefecture had ignored the observations submitted by the worker in response to the notice of intended rejection, despite the fact that those observations had been duly received and filed in the administrative record . The facts are straightforward. The worker had entered Italy for the agricultural season, had obtained a regular seasonal work permit, and, before its expiry, had applied for conversion. The Prefecture issued a notice indicating possible grounds for rejection linked to alleged irregularities involving the employer. The worker replied in full, providing explanations and supporting documents. Nevertheless, the Prefecture concluded the procedure by stating that no observations had ever been submitted. This is the critical error that led to the annulment. In a conversion procedure, participatory rights are not a mere formality: they are a legal guarantee. Article 10-bis of Law 241 of 1990 requires the Administration to examine the interested party’s observations and to base the final decision, including its reasoning, on that input. If the office denies the existence of documents that were in fact properly submitted, the reasoning rests on a false premise, and the entire decision becomes unlawful. The Administrative Court made this point very clear: the failure to consider the worker’s observations amounts to a procedural flaw serious enough to invalidate the refusal. This ruling highlights an essential point: procedural correctness directly affects the life and future of the foreign worker. If observations are ignored, the individual is deprived of the opportunity to present decisive elements, and the conversion may be unjustly denied. Judicial review intervenes precisely to restore balance and reaffirm that the administrative procedure cannot be emptied of its substance. This concludes today’s episode. Thank you for listening. See you next time.