Observatory › Litigation and collection › Rottamazione-quinquies: with ContiTu you choose which demands to settle

Rottamazione-quinquies: with ContiTu you choose which demands to settle

The new settlement scheme for amounts referred for collection returns with a useful feature: choosing which demands to settle. A cost-benefit decision, to be approached methodically.

The settlement scheme (definizione agevolata) for amounts entrusted to the Agente della riscossione (collection agent) between 1 January 2000 and 31 December 2023 (Article 1, paragraphs 82 to 100, of Law No. 199 of 30 December 2025) allows the debt to be discharged by paying the principal and the reimbursement of the costs of enforcement procedures and of service, with no penalties, interest entered in the collection roll, default interest or collection fee (aggio). It covers amounts arising from the non-payment of taxes reported in returns, from automated and formal checks of returns and from INPS social security contributions; amounts arising from tax assessments are excluded. It is a means of regularisation, not an amnesty on the tax itself.

The “ContiTu” feature

The choice of which amounts to settle is made in the application to join the scheme (dichiarazione di adesione) under Article 1, paragraph 86, of Law No. 199/2025, which may cover only some of the eligible cartelle di pagamento (tax collection notices). ContiTu comes into play at a later stage: once the Comunicazione delle somme dovute (statement of amounts due) has been received, it allows the taxpayer to limit payment to only some of the cartelle or notices already included in the plan, with the amount and the payment forms recalculated over the number of instalments chosen in the application. For the amounts left out of the recalculation the settlement has no effect and the Agente della riscossione (collection agent) resumes recovery action. The service therefore makes it possible to concentrate resources on the amounts carrying the heaviest penalties and interest, calibrating the financial commitment.

What to weigh up

The ordinary window for joining the scheme closed on 30 April 2026. The plan provides for a single payment by 31 July 2026 or up to 54 two-monthly instalments (31 July, 30 September and 30 November 2026; from 2027, 31 January, 31 March, 31 May, 31 July, 30 September and 30 November; final instalment on 31 May 2035), with interest at 3% per year from 1 August 2026 and a minimum instalment of 100 euro. The benefit of the scheme is lost if two instalments, even non-consecutive ones, are not paid or are paid only in part, or if the single payment or the final instalment is not paid, is paid only in part or is paid more than five days late. For amounts entrusted for collection by regions and local authorities that have adopted the relevant measure (Article 10-quinquies of Decree-Law No. 38/2026, converted into law by Law No. 88/2026), the application to join the scheme (dichiarazione di adesione) must be filed between 16 October and 15 December 2026, with a single payment by 31 March 2027 or up to 54 two-monthly instalments starting on 31 March 2027. Before joining, it is advisable to check that the plan is sustainable, what effect it has on existing instalment plans (dilazioni) and on procedures under way (suspension, then revocation of the instalment plans at the first due date), and whether the scheme is worthwhile for each cartella di pagamento (tax collection notice).

• Article 1, paragraphs 82 to 100, of Law No. 199 of 30 December 2025 (2026 Budget Law).
• Article 10-quinquies of Decree-Law No. 38 of 27 March 2026, converted into law by Law No. 88 of 22 May 2026 (amounts entrusted for collection by regional and local authorities).
• Agenzia delle Entrate-Riscossione, Rottamazione-quinquies: the ContiTu service and the Comunicazione delle somme dovute (statement of amounts due).