Budget Law

Transition 5.0 plan towards simplification in manoeuvre

Self-certification on initial energy saving targets under consideration. More AI and cybersecurity among eligible assets. But there is the resource knot: possible gap of almost 1 billion

by Carmine Fotina

4' min read

Translated by AI
Versione italiana

4' min read

Translated by AI
Versione italiana

Simplified, but with the great unknown of resources. The new Transition 5.0 incentive plan included in the budget bill will almost certainly be tweaked during parliamentary consideration, with a reduction in the documentary burden on companies that will be able to self-certify the initial energy saving targets they intend to achieve with the investment project. Then the new list of capital goods that can be purchased benefiting from the hyper-amortisation is almost ready, with more focus on new technological fields such as artificial intelligence and cybersecurity. In addition, the tortuous implementation process will be largely dribbled out by avoiding the interministerial decree and inserting the application provisions directly into the amendment, with the probable exception of the need for a light directorial decree. But in the meantime, the Ministry of the Economy, the Ministry of Enterprise and Made in Italy, and the Ministry of EU Affairs, the NRP and Cohesion are grappling with the funding conundrum: how to simultaneously finance the 2025 projects that have remained on the waiting list due to the exhaustion of funds and the extension of the new plan beyond 2026?

The procedures

To simplify the picture, compared to what has been until now Transition 5.0 (a maze of fulfilments and communications), the starting point is a paragraph of the new article inserted in the budget bill: 'To access the benefit, the company transmits, electronically via a platform developed by the Energy Services Manager, on the basis of standardised models, special communications and certifications concerning the eligible investments. Compared to the old plan, technicians at the Ministry of Enterprise and the GSE are studying the elimination of the obligation to transmit an 'ex ante' certification, attesting to the reduction in energy consumption achievable through the planned investments. Up to now, this document had to be issued by an authorised certifier, while under the amendment being studied, a self-certification by the company would suffice. Instead, the obligation of an 'ex post' certification, proving the actual realisation of the investments in accordance with the self-certification, would remain in place.

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Annexes with capital goods

The work already underway for several months at the Ministry of Enterprise will lead to the updating of the list that with two separate annexes (A and B) was included in the 2017 budget law, which kicked off the original Industry 4.0 plan. On the extension of the perimeter of the assets, including technologies and applications that at the time were at a primordial stage or in any case had not yet been widely deployed, a number of majority amendments to the manoeuvre have been tabled, a basis on which the government reformulation could be inserted. By way of example, the parliamentary amendments aim to include in Annex A, which concerns tangible capital goods, measurement and inspection systems in line with advanced machine vision and artificial intelligence/edge systems for quality control; wearable equipment for assistance and training; systems for site energy management (Ems) and integration of renewable energy sources/accumulation. In contrast, Annex B, which covers intangibles such as software, could open up to advanced and generative artificial intelligence and cybersecurity platforms for information technology operations; privacy protection systems related to access and portability of data from connected products; multi-access edge computing systems.

The resource problem

The most difficult task for the ministries involved is actually solving the resource problem. After the abrupt halt to the Transition 5.0 plan announced on 7 November, once the EUR 2.5 billion wall agreed with the EU in the reshaping of the NRP had been breached, companies continued to submit projects and enter the waiting list. By the deadline of 27 November, bookings stood at EUR 4.8 billion, thus a surplus of EUR 2.3 billion. If we consider that in the meantime Transition 4.0 has exceeded the ceiling set at 2.2 billion by 100 million (and in theory the waiting list could still lengthen), we are left with a gap of 2.4 billion to cover.

In the meantime, Mimit imposed the mandatory option procedure for those who had booked both 4.0 and 5.0 tax credits. And a number of projects, although submitted by the deadline, could lapse for lack of requirements. But this is not enough to reassure the Treasury, which is called upon to find resources to cover the hole. Even assuming a prudential scenario, i.e., that almost two-thirds of the 5.0 projects submitted lapse, funds amounting to 800 million-1 billion would still have to be found.

A burden to be added to that of extending the new plan, which with an endowment of EUR 4 billion the draft budget law has at present limited to investments made between 1 January and 31 December 2026. The political objective of extending the hyper-amortisation also for 2027 and 2028 is shared by the various ministries. But realisability is not a foregone conclusion. One option is to stop at the two-year period, another is to simply insert a programmatic rule with partial allocations for 2027 and 2028, as has already been done for the tax credit for investments in the Special Economic Zone. The minimum hypothesis, on the other hand, is to lengthen the deadline for delivery of the goods, which is currently set for 20 June 2027 if at least a down payment of 20% has been made to the supplier of the goods by 2026.

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