Tax Observatory › Assessment, collection and litigation › Instalment plans for payment notices: 84 instalments for applications filed by 31 December, 96 in 2027

Instalment plans for payment notices: 84 instalments for applications filed by 31 December, 96 in 2027

For debts of up to EUR 120,000, the maximum number of instalments granted on simple request depends on the year in which the application is submitted. Taxpayers who intend to apply in the coming months must choose between the immediate protection that an application provides and the longer plan available to those who wait until January. The choice should take account of the effects on enforcement proceedings and on offsetting.

For applications submitted on or before 31 December 2026, the Agenzia delle entrate-Riscossione (the Italian collection agent) grants, on simple request, up to 84 monthly instalments for amounts entered on the collection roll (iscrizione a ruolo) of up to EUR 120,000; for applications submitted in 2027 and 2028, the maximum rises to 96 instalments. Above that threshold, or for a larger number of instalments, the taxpayer must document economic and financial difficulty, and the limit is 120 instalments. Taxpayers who intend to apply for an instalment plan (rateizzazione or dilazione) must therefore decide whether to submit the application now or in January.

The rules in force

The matter is governed by Article 19 of Presidential Decree No. 602 of 29 September 1973, as amended by Article 13(1) of Legislative Decree No. 110 of 29 July 2024, which replaced paragraph 1 and inserted paragraphs 1.1 to 1.3. The new rules apply to applications submitted on or after 1 January 2025 (Article 13(3) of Legislative Decree No. 110/2024).

For amounts of up to EUR 120,000, a taxpayer who declares a temporary situation of objective economic and financial difficulty is granted up to 84 instalments for applications submitted in 2025 and 2026, up to 96 for those submitted in 2027 and 2028, and up to 108 for those submitted on or after 1 January 2029 (Article 19(1)). The threshold refers to the amounts included in each application.

If the difficulty is documented, amounts of up to EUR 120,000 may be spread over 85 to 120 instalments (from 97 for applications submitted in 2027 and 2028, from 109 for those submitted in or after 2029); above the threshold, documentation is always required and the limit remains 120 instalments (paragraph 1.1). For individuals and sole proprietorships under the simplified accounting regime, the difficulty is assessed by reference to the ISEE (indicatore della situazione economica equivalente, the household means-test indicator) and to the amount of the debt, including debt already being paid in instalments; for other taxpayers, by reference to the liquidity ratio and to the ratio of debt to the value of production (paragraph 1.2). The implementing arrangements were laid down, as provided for in paragraph 1.3, by the Ministerial Decree of 27 December 2024 (Official Gazette No. 305 of 31 December 2024).

The debtor may request instalments that increase annually rather than remain constant (paragraph 1-ter). According to the collection agent, each instalment must be at least EUR 50.

Effects of the application

From the submission of the application until it is rejected or the plan is forfeited, limitation periods and preclusive time limits are suspended, no new fermo amministrativo (administrative detention order on registered movable property) or ipoteca (charge on real property) may be registered, and no new enforcement proceedings may be commenced (Article 19(1-quater) of Presidential Decree No. 602/1973). Payment of the first instalment extinguishes enforcement proceedings already under way, provided that no successful auction has yet been held and no application for assignment has been filed. In the case of a pignoramento presso terzi (attachment of receivables owed by third parties), extinction requires that the third party has not made a positive declaration (dichiarazione positiva, confirming that it owes sums to the debtor) and that the order assigning the attached receivables has not yet been issued (paragraph 1-quater.2).

Amounts subject to the check under Article 48-bis of Presidential Decree No. 602/1973 on payments by public administrations cannot be included in an instalment plan if the check was carried out before the application was granted (paragraph 1-quater.1). Tax credits may not be offset in form F24 where amounts entered on the roll or entrusted to the collection agent for central government taxes and related ancillary amounts (accessori), overdue and not suspended, exceed EUR 50,000 (Article 37(49-quinquies) of Decree-Law No. 223 of 4 July 2006). Amounts included in an instalment plan that has not been forfeited do not count towards that threshold. Credits for social security contributions and insurance premiums may still be offset. What counts is the plan, not the application: the amounts are excluded from the calculation only once the application is granted. On the limits to offsetting, see our commentary on F24 offsetting and debts on the roll.

Forfeiture and new applications

Failure to pay eight instalments, even if not consecutive, results in automatic forfeiture of the plan, makes the remaining balance immediately recoverable and rules out a new instalment plan for the same debt (Article 19(3) of Presidential Decree No. 602/1973). Forfeiture does not prevent instalment plans for other debts (paragraph 3-ter). Where collection is suspended, the instalments relating to the suspended amounts need not be paid; when the suspension ends, the debtor may apply to pay the balance, including the interest provided for by law for that period, in the same number of instalments or in a different number, within the maximum limits in paragraphs 1 and 1.1 (paragraph 3-bis).

Applying now or in January

The maximum number of instalments depends on the year in which the application is submitted. For an srl (limited liability company) with debts of EUR 96,000, the monthly principal is EUR 1,142.86 over 84 instalments and EUR 1,000 over 96, excluding interest; the longer plan, however, results in higher total interest for deferred payment. In addition, the choice can be made only once: according to the collection agent’s practice, a debt already included in a plan granted over 84 instalments cannot be the subject of a new application for 96 instalments in 2027. To lengthen the plan, the only remaining option is an extension, granted once only where the taxpayer’s situation has demonstrably worsened (Article 19(1-bis) of Presidential Decree No. 602/1973).

Waiting until January, however, means remaining for several weeks without the protection of paragraph 1-quater, exposed to detention orders, charges on real property and pignoramenti (attachments). If overdue central government tax debts exceed EUR 50,000, tax credits cannot be offset in form F24 in the meantime. Lastly, if a public administration starts the Article 48-bis check on a payment owed to the taxpayer, the amounts checked can no longer be included in an instalment plan. Where an attachment has already been served, or where VAT credits are to be offset shortly, we consider it advisable to submit the application immediately; in other cases, deferral reduces the principal portion of each instalment by 12.5 per cent.

For businesses in crisis, the instalment plan should be coordinated with the composizione negoziata, the negotiated crisis settlement procedure; before applying for an instalment plan, it should also be checked that the payment notices (cartelle di pagamento) were validly served.

The rules from 2027

Article 19 remains in force until 31 December 2026. With effect from 1 January 2027, Presidential Decree No. 602/1973 will be repealed (point (c) of Article 241(1) of Legislative Decree No. 33 of 24 March 2025) and the Consolidated Act on tax payments and collection (testo unico versamenti e riscossione) will apply. Its date of application, set by Article 243(1), was deferred by Article 4(4) of Decree-Law No. 200 of 31 December 2025, converted into law by Law No. 26 of 27 February 2026. Instalment plans will be governed by Article 105 of the Consolidated Act, which carries over Article 19 with the same thresholds, the same effects of the application (Article 105(7)) and forfeiture after eight unpaid instalments (paragraph 10); the reference to Article 48-bis will be replaced by a reference to Article 144 (paragraph 8). For the bar on offsetting, the reference will become Article 5(7) of Legislative Decree No. 33/2025, with the same EUR 50,000 threshold and the same exclusion of amounts included in plans that have not been forfeited.

In practice

• The taxpayer, or the authorised intermediary, reconstructs the overdue debts from the statement of the collection roll (estratto di ruolo), distinguishing those that are suspended.
• No later than 31 December 2026, the taxpayer decides whether to apply for 84 instalments or to wait until 2027, taking into account any proceedings under way and any offsetting planned.
• For amounts of up to EUR 120,000 per application, the taxpayer uses the “Rateizza adesso” service in the collection agent’s secure personal area or form RS sent by certified email (PEC); above the threshold, or for more than 84 instalments (96 in 2027 and 2028), the taxpayer files a documented application with the attachments required by the Ministerial Decree of 27 December 2024.
• The taxpayer keeps the receipt for the application, the decision granting it and the payment receipts, and maintains a schedule of instalment due dates: once an eighth instalment goes unpaid, the plan is forfeited automatically, with no prior warning.

Frequently asked questions

Can I submit several applications to stay below EUR 120,000?

The threshold refers to each application, and the legislation allows more than one plan for different debts. Splitting debts solely to avoid the documentation requirement is not addressed by the legislation and should be approached with caution.

If I submit the application in December and it is granted in January, do I obtain 96 instalments?

No. Article 19(1) of Presidential Decree No. 602/1973 links the maximum number of instalments to the year in which the application is submitted: for applications submitted in 2026 the limit remains 84 instalments.

Sources

Article 19 of Presidential Decree No. 602 of 29 September 1973 (in force until 31 December 2026).

Article 13 of Legislative Decree No. 110 of 29 July 2024 (Official Gazette No. 184 of 7 August 2024).

Decree of the Ministry of Economy and Finance of 27 December 2024 (Official Gazette No. 305 of 31 December 2024).

Article 37(49-quinquies) of Decree-Law No. 223 of 4 July 2006.

Legislative Decree No. 141 of 5 August 2026 (Official Gazette No. 181 of 6 August 2026, Ordinary Supplement No. 28), for the wording of Article 5(7) of Legislative Decree No. 33/2025 in force as from 7 August 2026, applicable with effect from 1 January 2027.

Article 5(7) and Articles 105, 144, 241 and 243 of Legislative Decree No. 33 of 24 March 2025; Article 4(4) of Decree-Law No. 200 of 31 December 2025, converted into law by Law No. 26 of 27 February 2026.

Agenzia delle entrate-Riscossione, web pages “La rateizzazione dal 1° gennaio 2025”, “Istanze a semplice richiesta” and “Istanze documentate”.