The 2025 Budget Law (L. 207/2024, art. 1 co. 860) introduced the obligation for company directors to obtain a certified email address (PEC). Legislative Decree 31.10.2025 no. 159 further amended the regulation, specifying the obligated parties and introducing the December 31, 2025 deadline for existing companies.
Unioncamere, with a document dated 10.11.2025, provided official clarifications regarding the obligation.
Directors and companies concerned
The obligation applies to:
- Sole director
- Managing director
- Chairman of the Board of Directors (in the absence of a managing director)
Unioncamere specifies that the obligation concerns exclusively limited liability companies, as well as consortium companies and cooperatives having this legal form. Directors of partnerships and board members without delegated powers are excluded.
In the case of limited liability companies (SRL) with management entrusted to multiple parties jointly or severally (art. 2475 co. 3 c.c.), the obligation does not apply.
Liquidators
The specific reference to the positions of sole director, managing director or chairman of the board appears to exclude liquidators from the obligation, contrary to previous interpretations by the Ministry of Enterprise.
PEC must be different from the company’s
DL 159/2025 expressly establishes that the directors’ digital domicile cannot coincide with the company’s digital domicile.
However, a director holding positions in multiple companies may use the same PEC for all companies. It is also possible to communicate a PEC already available (for example, the mandatory PEC for professionals).
Deadlines
DL 159/2025 clarified the compliance deadlines:
- Directors in office as of 31.10.2025 who have not yet communicated their PEC must do so by December 31, 2025
- From 31.10.2025, PEC communication must be made simultaneously with the appointment or renewal of the position
Penalties
For newly established companies and new appointments, failure to indicate the PEC causes suspension of the registration application with the Business Register until regularization.
For existing companies, failure to meet the December 31, 2025 deadline results in the application of the penalty provided by art. 2630 c.c. in doubled amount, from 206 to 2,064 euros, and probably the official assignment of a PEC to the director.
Registry fees and stamp duty
Communication and subsequent changes of the director’s PEC are exempt from stamp duty and registry fees if submitted as a standalone practice (“Simple practice”).
If the communication is submitted together with a registration or document filing application (for example, appointment or renewal), it remains subject to the ordinary rules concerning registry fees and stamp duty.
RCG Studio remains available to assist in fulfilling the obligation by the December 31, 2025 deadline.