The 2026 Budget Law (Law no. 199 of 30 December 2025, arts. 427–436) introduces a new hyper-depreciation regime, replacing the previous Transition 4.0 and 5.0 tax credits. The incentive consists of an enhanced cost basis for eligible assets — relevant exclusively for extra-book tax deduction purposes — and applies to businesses investing between 1 January 2026 and 30 September 2028 in technologically advanced capital goods or in plants for renewable energy self-production for own consumption. The implementing decrees DM 7 May 2026 and DM 10 June 2026 have defined the operational rules and the opening schedule for the GSE platform.
Eligible assets
The incentive covers two categories of investment. The first includes new tangible and intangible capital goods supporting technological and digital transformation, listed in Annexes IV and V to Law 199/2025 (updating the former Annexes A and B to Law 232/2016), provided they are interconnected with the company’s production management system or supply network. The second category covers new tangible assets for renewable energy self-production and self-consumption, including storage systems. For this latter category, plant capacity may not exceed 105% of the production facility’s energy requirement, calculated on the average consumption of the prior financial year. All assets must be allocated to production facilities located in Italy.
Enhancement rates
The benefit applies to eligible expenditure on investments completed in each calendar year and is structured in three bands: 180% for investments up to €2.5 million; 100% for the tranche between €2.5 million and €10 million; 50% for the tranche between €10 million and €20 million. The thresholds are calculated per individual year. The relief takes the form of a downward adjustment in the REDDITI income tax return and applies from the tax period in which the company submits the completion notice to the GSE, provided the asset has entered into operation within the same period.
Access procedure: three communications to the GSE
Accessing the incentive requires three successive communications, submitted exclusively through the GSE online platform (www.gse.it), “Area Clienti” section, accessible via SPID. The preliminary communication — already available from 12 June 2026 at 12:00 — must state the company’s details, the type and amount of planned investments and the expected interconnection or operational start date. The confirmation communication, due within 60 days of the GSE’s positive outcome notice, confirms that a deposit equal to at least 20% of the acquisition cost of each asset has been paid. The completion communication must be submitted by 15 November 2028, once the investment is finalised, and must be accompanied by the sworn technical report and the accounting certification. Failure to submit these communications within the prescribed deadlines precludes entitlement to the benefit.
Periodic monitoring communications
Throughout the incentive period, each beneficiary must submit two annual monitoring communications: by 20 January each year, reporting on investments made and the projected use of the benefit; by the following 30 June, a supplementary communication including the depreciation schedule and the incentive instalments allocated per financial year.
Required documentation
The substance of the investments must be evidenced by a sworn technical report, issued by a registered engineer or industrial expert (or, in the agricultural sector, by a qualified agronomist or agricultural surveyor), and by an accounting certification issued by a statutory auditor or audit firm. Both professionals must hold appropriate professional indemnity insurance. All documentation must be retained for GSE inspection; in the event of improper use of the benefit, the GSE notifies the Italian Tax Authority (Agenzia delle Entrate) for recovery of the amount, plus interest and penalties.
Main grounds for forfeiture
The benefit is forfeited, in whole or in part, if during the incentive period the eligible asset is sold or transferred to a foreign production facility without replacement by a technologically equivalent or superior asset in the same tax period. Forfeiture also applies where documentation is irregular and cannot be remedied, false declarations have been made, supporting records have not been retained, or audits cannot be carried out due to reasons attributable to the company.
To assess the applicability of hyper-depreciation to your investments and receive support in managing GSE communications, contact Studio RCG.