Transition 4.0 and 5.0, innovation bonus and Zes: how the map of business incentives is changing

Funds from Transition 4.o and the old 5.0 plan exhausted. Towards stop for innovation tax credits. Goodbye tax credit for training. The industrial policy instruments have ended up in this real bottleneck and the prospect of recovery is entrusted to the new maxi-amortisation programme that will start in 2026.

For the business associations, some of the government's choices have been unclear and disrespectful to those who have already started or planned investments, only to find the rules changed in the process. A chaos generated, in the first instance, by the depletion of the EUR 2.5 billion ceiling for Transition 5.0 that had been agreed with the EU Commission as part of the reshaping of the NRP.

As of 7 November, companies can still continue to book tax credits on the GSE (Gestore dei Servizi Energetici) portal, but they will receive a notice of unavailability of resources and will end up on a 'waiting list', i.e. they will only access the tax benefit if there are any waivers or a reduction in planned investments by those who have already accrued the right. Let us take a step back. The NRP had foreseen for investments made in 2024 and 2025 according to the rules of the Transition 5.0 plan a ceiling of EUR 6.3 billion (of which EUR 6.23 billion for the benefits and the rest for the management of the measure) but, especially in the initial phase, the draw was lower than expected and the government therefore decided to revise the commitment in order to allocate the residuals to other interventions. In recent months, it was therefore agreed to stop access to the incentives at EUR 2.5 billion, diverting the remaining EUR 3.8 billion to cover other interventions. A sudden stop, two months before the plan's natural expiry date, which triggered chaos among many companies that, even in the face of some simplifications gradually adopted to streamline the plan, had started investments, reserving the right to register. Since 7 November, in fact, a flood of projects has arrived, which evidently many companies, also on the advice of consultants, were planning to submit towards the end of the year. We are already over 3.5 billion in total, so over 1 billion above the limit set with the EU. This means that the government will have to recover additional resources, essentially backtracking from the initial decision to defund the measure in order not to risk exceeding the NRP targets. This will be discussed on Tuesday, 18 November, at a meeting convened with business associations by the Ministry of Enterprise and Made in Italy.

The news of the exhaustion of Transition 5.0 resources prompted many companies to quickly run for cover by moving projects to the old (and less generous in terms of rates) programme Transition 4.0. With the result that even these funds - which had 2.2 billion for 2025 - quickly ran out.

The Transizione 4.0 plan is based on tax credits for investments in the purchase or leasing of capital goods functional to digital innovation processes and differs from the later Transizione 5.0, which is instead fuelled by European resources from the NRP and also envisages energy-saving objectives to be achieved with innovation projects. Even for Transition 4.0, Mimit emphasises that it is still possible to continue to send in bookings until the end of the year: in the event of new availability, for possible cancellations or cancelled projects. It should be borne in mind that, in the back-and-forth between NRP European funds and national funds, Mimit has shifted precisely to Transition 4.0 the 3.8 billion that were defunded to Transition 5.0. This endowment will be used to cover 'old' investments from the 2023, 2024 and, indeed, 2025 tax periods. In the Senate Budget Committee, amendments by Fratelli d'Italia and Forza Italia have arrived that aim to use the residuals also for new investments facilitated with 4.0, made between 1 January and 31 December 2026, but there is currently no endorsement of the ministries on this option.