From 2028 businesses with revenue or VAT turnover of at least EUR 100 million will be able to enter the adempimento collaborativo (cooperative compliance regime); in 2026 and 2027 the threshold remains EUR 500 million. Entry requires a tax risk control system certified by a lawyer or a chartered accountant (dottore commercialista) on the relevant list. Businesses admitted without certification on applications filed in 2024 or 2025 must produce it by 31 December 2026; failing that, the Italian Revenue Agency (Agenzia delle Entrate) may exclude them from the regime.
Article 7, paragraph 1-bis, of Legislative Decree No. 128 of 5 August 2015 reserves the regime for taxpayers with VAT turnover or revenue of at least EUR 750 million from 2024, EUR 500 million from 2026 and EUR 100 million from 2028. The test uses the higher of revenue in the financial statements and VAT turnover for the three financial or calendar years preceding the application (paragraph 1-ter).
Businesses belonging to a group under common legal or de facto control within the meaning of Article 2359, paragraph 1, points 1 and 2, and paragraph 2, of the Civil Code may also be admitted, provided that at least one of them meets the threshold and the group adopts a certified integrated system (paragraph 1-quater).
The system (tax control framework, TCF) must ensure clear roles and responsibilities, effective procedures for identifying and controlling tax risks, corrective action and a map of the tax risks arising in business processes, with a report to the management bodies at least once a year (Article 4, paragraphs 1 and 2). It is certified by independent professionals: Ministerial Decree No. 212 of 12 November 2024 reserves this activity for professionals who have been on their professional register for more than five years and are on the lists kept by the National Bar Council (Consiglio nazionale forense) or the National Council of Chartered Accountants (Consiglio nazionale dei dottori commercialisti e degli esperti contabili); the certification lasts three years.
Businesses that had already been admitted, or had applied, before 18 January 2024 do not need to have the system certified but must attest that it operates effectively (Legislative Decree No. 221 of 30 December 2023, Article 1, paragraph 3).
For risks disclosed promptly and fully before the return is filed or the deadline expires, provided the conduct matches what was disclosed, no administrative penalties apply (Article 6, paragraph 3) and there is no criminal liability for the offence of filing an inaccurate return (paragraph 4), save for sham or fraudulent conduct and, for the offence, non-existent deductible items. With a certified system the time limits for assessment are shortened by two years (paragraph 6-bis), subject to the exceptions in paragraph 6-quater.
Businesses below the threshold may opt for the regime under Article 7-bis: the election is notified to the Revenue Agency, lasts two tax periods, is irrevocable and is renewed automatically. It rules out administrative penalties and criminal liability for filing an inaccurate return in respect of risks submitted through an interpello (ruling request) and, from 12 August 2026, of risks relating to earlier periods that are disclosed within 120 days of the outcome of the check on the election (paragraphs 2-bis and 2-ter); it does not shorten the time limits.
No: the threshold remains EUR 500 million until the end of 2027. It may opt for the Article 7-bis regime; the full regime will be open to it from 2028.
An independent lawyer or chartered accountant who has been on the professional register for more than five years and is on the list kept by their national council (Ministerial Decree No. 212/2024). The certification lasts three years and must then be updated.
No: it requires a certified system and does not apply to violations committed using false documents, non-existent transactions, artifice or fraudulent conduct (Article 6, paragraph 6-quater).
Legislative Decree No. 128 of 5 August 2015, Articles 4, 6, 7 and 7-bis (text in force on 12 November 2026)
Civil Code, Article 2359
Legislative Decree No. 221 of 30 December 2023, Article 1, paragraph 3
Ministerial Decree No. 212 of 12 November 2024, Articles 1 and 7
Legislative Decree No. 192 of 18 December 2025, Article 14
Legislative Decree No. 148 of 7 August 2026, Articles 16 and 17
Legislative Decree No. 141 of 5 August 2026, consolidated Act on tax compliance and assessment, Articles 143 to 150 (from 1 January 2027)
Revenue Agency (Agenzia delle Entrate), Circular No. 6/E of 6 August 2026, § 2.6, referring to the Ministerial Decree of 21 November 2024 on how operating effectiveness is attested
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