The implementing decree has arrived. Rates, thresholds, eligible assets and the GSE procedure: an operational guide for planning the next three years of investment.
The 2026 Italian Budget Law has brought back to centre stage a mechanism already familiar from previous rounds of Industry 4.0: enhanced depreciation (iperammortamento). With the implementing decree published in May, we now have operational rules in place, although the application forms and the opening of the GSE platform will require a further administrative decree.
It is worth taking stock now, because the timing window is generous — the relief applies to investments made between 1 January 2026 and 30 September 2028 — and the rates remain highly attractive. For businesses with investment plans already under way, it is the time to make informed choices.
Let me be plain, because it is often confused: enhanced depreciation is not a grant and is not a tax credit. It is a fiscal uplift to the cost of acquisition of a new capital asset. In practical terms: a business buys a piece of equipment for €100,000, but for the purposes of calculating tax depreciation — or finance lease instalments — it can behave as if it had paid €280,000. The benefit comes through higher depreciation charges spread across the years, reducing the taxable base for corporate or personal income tax. It has no effect on IRAP (regional business tax).
The decree provides relief for two categories of investment:
On renewables, the decree introduces precise constraints. The first is dimensional: the maximum producibility of the plant cannot exceed 105% of the business’s energy requirement, calculated on average annual consumption from the previous financial year. An oversized photovoltaic plant designed for energy resale is therefore excluded. The second concerns photovoltaics specifically: modules must be listed in the ENEA register in the prescribed categories — the “Made in Europe” requirement persists here.
There are also unit cost ceilings: €1,420/kW for plants up to 20 kWp, €840/kW for plants exceeding 1,000 kWp. Costs in excess of these thresholds do not enter the calculation base.
Enhanced depreciation operates on a progressive threshold basis applied to the eligible annual investment. Up to €2.5 million, the uplift is 180%, meaning the fiscally depreciable value rises to 280% of the asset cost. Between €2.5 and €10 million the uplift drops to 100%, for a value of 200%. Between €10 and €20 million a 50% uplift applies, for a value of 150%.
An example clarifies the mechanism. A €4 million investment: the first €2.5 million is valued at 280% (= €7 million of fiscal value), the remaining €1.5 million at 200% (= €3 million). Total fiscally depreciable value: €10 million against €4 million of actual expenditure. The fiscal leverage effect is significant.
The uplift begins to apply from the tax period in which the business notifies GSE of the completion of the investment, provided that the asset has entered into operation in the same period and that — for assets covered by annexes IV and V — interconnection to the corporate production management system has been completed.
Enhanced depreciation requires going through a structured procedure on the GSE platform, accessed via SPID or CIE, set out in three notifications:
GSE verifies the upload within 10 days and notifies the outcome or requests integrations (which extend the deadline by 20 days).
All investments require a technical sworn appraisal supported by technical analysis, issued by an engineer or industrial expert registered with the relevant professional body, or by an accredited certification body. And an accounting certification from a statutory auditor (including for businesses not legally required to be audited: in such cases, an independent auditor is engaged).
In addition, invoices and shipping documents must be retained, along with technical documentation on interconnection.
Here is an element often underestimated. Once the relief has been obtained, it does not end there. Beneficiary businesses must transmit annually:
It may seem a formality, but failure to comply can result in the loss of the benefit on subsequent instalments. It is worth setting up monitoring correctly from the outset.
The attractive rates tell only half the story. The other half is the procedure: those who begin internal planning now have six months to be ready for the first preliminary notification without giving up months of useful time.
If you are evaluating an investment and want to understand whether it falls within eligible assets or which rate applies to your case, write to us or book a call directly.