Firm Guides · Cleaning businesses

Cleaning businesses in Italy: accounting, tax, payroll and sector rules

When a cleaning business does its job well, nobody notices. The work is done by people who start at dawn, in the evening or at night, often in several buildings in a single day and on part-time contracts: mostly women, many of whom came to Italy from other countries. Staff costs often exceed two thirds of revenue, and every mistake, whether on a payslip or an invoice, is repeated for every person and every month of the contract.

Problems arise where the rules intersect: the VAT credit that grows with the reverse charge (inversione contabile) and split payment (scissione dei pagamenti) and stays locked up just when it is needed to pay social security contributions; the change of contractor (cambio d’appalto) that a court treats as a transfer of a business; the cleaner who moves from one condominio (a building in multiple ownership, run by its owners’ association) to another without that time being paid; the tender won with a deep discount and fewer hours than the specification requires; the expired DURF (the certificate that a contractor meets the tax-compliance requirements of Article 17-bis of Legislative Decree 241/1997) that holds up payments from a major client.

This guide is written for owners and administrative staff of cleaning and multi-service businesses, whether artisan firms, companies or cooperatives, for those who want to set one up, and for clients, condominium administrators (amministratori di condominio) and fellow accountants who keep their books.

The text is up to date as at 16 October 2026. For regional rules the reference is Emilia-Romagna, with some mention of Lombardy. One caveat applies to the whole guide: from 1 January 2027 the new consolidated tax Acts (testi unici) apply, among them the consolidated VAT Act (Legislative Decree No. 10 of 19 January 2026), the consolidated income tax Act (Legislative Decree No. 117 of 19 June 2026), the consolidated Act on tax penalties (Legislative Decree No. 173 of 5 November 2024) and the consolidated Act on tax payments and collection (Legislative Decree No. 33 of 24 March 2025), into which Article 17-bis of Legislative Decree 241/1997 is also incorporated. These are consolidating Acts: as a rule they change the numbering of the articles, not the substance of the rules examined here (with some coordinating amendments, to be checked case by case). Until 31 December 2026 Presidential Decree 633/1972, the TUIR (the 1986 consolidated income tax Act, Presidential Decree 917/1986), Legislative Decrees 471 and 472 of 1997 and Legislative Decree 241/1997 remain in force, and these are the texts we refer to; contracts, tender specifications and invoice wording will need to be updated with the new references.

Setting up and running the business

The five activities and the technical requirements

Unlike many other activities, cleaning cannot be taken up freely. Law No. 82 of 25 January 1994 and its implementing regulation, Ministerial Decree No. 274 of 7 July 1997, make it subject to entry requirements, to a qualified entry with the Chamber of Commerce and to penalties that also reach those who commission the work. Article 1 of the decree distinguishes five activities: cleaning, which removes dust, dirt and unwanted material; disinfection, which destroys or inactivates pathogenic micro-organisms; pest control, aimed at small animals, arthropods in particular, and unwanted plant species; rodent control; and sanitisation, which makes premises healthy through cleaning, disinfection or pest control, or by controlling microclimate, lighting and noise.

The distinction determines which requirements apply. Since 2007 cleaning and disinfection have been subject only to a notice of start of business and cannot be made conditional on professional, educational or experience requirements; the good-character and financial-capacity requirements remain (Article 10(3) of Decree-Law No. 7 of 31 January 2007, converted into law by Law No. 40 of 2 April 2007). For pest control, rodent control and sanitisation the provision preserves the earlier rules, and for these three activities a technical manager is still required (CGARS, the Council of Administrative Justice for the Sicilian Region, 19 April 2021, No. 329, cited by ANAC, the National Anti-Corruption Authority, in resolution No. 567 of 6 December 2023). A business that began offering ‘sanitisation’ after the pandemic without a technical manager registered for that activity is carrying on an activity for which it is not authorised, with the risks described below; disinfection, on the other hand, does not require a technical manager, provided the registration covers it.

Good character, financial capacity and the technical manager

The good-character requirements (Article 2 of Law 82/1994) exclude, unless rehabilitated, anyone with final convictions for intentional offences carrying a sentence of more than two years or for offences against public trust or property, open insolvency proceedings, anti-mafia preventive measures, or convictions for unlawful competition involving threats or violence. They also exclude anyone found to have committed contraventions in the field of employment, social security and accident insurance that cannot be settled administratively: a neglected inspection report can affect the registration, as well as tenders. They apply to the owner, the general manager (institore), the partners of an snc (general partnership), the general partners of a limited partnership and the directors of companies and cooperatives.

Financial capacity (Article 2(1) of Ministerial Decree 274/1997) is shown by the registration with INPS (National Social Security Institute) and INAIL (National Institute for Insurance against Accidents at Work) of all those working in the business, including the owner, family members and working shareholders where the conditions are met, by the absence of protested bills in the last five years and by bank statements on credit lines. For the three activities that require one, the technical manager must have completed compulsory schooling and have three years of qualified experience, or hold a relevant vocational certificate, diploma or degree. Nor can he or she be an outside consultant or professional (Article 2(2)): the ‘hired technical manager’, who signs for several businesses without working in any of them, exposes the business to loss of the requirement and to removal from the register.

SCIA, changes and classification bands

The business starts with a SCIA (segnalazione certificata di inizio attività, the certified notice of start of business) accompanied by statements on the requirements (Annex A to the decree), filed through the Comunicazione Unica (the single online filing) with the Business Register or the register of artisan businesses (albo artigiani), at the Chamber of Commerce of the province where the registered office is located; local branches are notified where they are located. Changes in the requirements, including a change of technical manager or of directors, must be notified within thirty days (Article 4 of Ministerial Decree 274/1997). Failure to do so carries an administrative penalty still expressed in lire, about €207 to €620 (Article 6(1) of Law 82/1994); the more serious problem is that a business that has lost a requirement without notifying it makes a false statement in every tender.

Article 3 of the decree allows a business to apply for entry in one of ten classification bands (fasce di classificazione, based on turnover net of VAT). The text is in lire; the amounts in euro are the conversions used in the Chamber of Commerce forms.

The band is calculated on average turnover over the last three years, or over at least two years of activity, and for the first band the average must reach 60 million lire, about €30,987. The business must also have performed services in the period worth at least 40% of the amount of the band below (or two services for 50%, or three for 60%), certified by the clients, and its employee costs must amount in each year to at least 40% of total costs, or 60% for businesses that carry on cleaning and disinfection only; a cooperative with many worker-members may produce a certificate of contribution compliance instead. This last requirement separates genuine businesses from labour intermediaries: a business that declares a large turnover with few employees, because the work is done by others, will struggle to justify its band and is at risk at the first check, which the Chamber can carry out at any time, including on a report from a competitor (Article 4(3)).

Suspension, removal and criminal offence

Registration for cleaning can be suspended for conduct that seriously disrupts relations with the contracting authority, for gross negligence endangering public health or safety at work, and for significant, unremedied breaches of social security and insurance rules and of the sector’s collective agreements (Article 5 of Ministerial Decree 274/1997). This little-known, sector-specific penalty makes compliant payroll a condition of being allowed to work at all. Suspension lasts ninety days, renewable once; a business that loses a requirement can avoid immediate removal by applying for it itself within ten days of the notice that proceedings have begun, a time limit that a business receiving a PEC (certified email) from the Chamber must not miss.

Anti-mafia rules: white list and documentation

Cleaning is not among the activities exposed to the risk of infiltration that require entry in the Prefettura’s white list (the list of businesses cleared against mafia infiltration) (Article 1(53) of Law No. 190 of 6 November 2012). The problem arises in multi-service contracts: if the contract includes waste collection and transport, catering or guarding of building sites, activities that the list does cover, ANAC and the administrative courts consider registration necessary even when that part is ancillary or of modest value. Every change in ownership or in the corporate bodies must be notified to the Prefettura within thirty days, failing which the business is removed (paragraph 55). Outside these activities the ordinary regime applies: anti-mafia documentation is not required for contracts up to €150,000 or for an individual artisan business (points (d) and (e) of Article 83(3) of Legislative Decree 159/2011), and an anti-mafia exclusion order (interdittiva) affects all the business’s public contracts and allows the tender guarantee to be enforced (Article 106(6) of Legislative Decree 36/2023). Transfers of shares and appointments of directors must be prepared with care.

Chemicals, biocides and waste

As a professional user of chemical substances and mixtures, the business must keep safety data sheets available to workers (Article 31 of Regulation (EC) 1907/2006, REACH), comply with labelling under Regulation (EC) 1272/2008 and assess chemical risk (Title IX of Legislative Decree 81/2008). The typical mistakes are decanting into unlabelled bottles and mixing incompatible products, such as chlorine and acids. A product may be presented as a disinfectant only if it is authorised as a biocide (Regulation (EU) 528/2012) or registered as a medical-surgical product (presidio medico-chirurgico) (Presidential Decree No. 392 of 6 October 1998): an ordinary detergent is not, and claiming otherwise in a bid is a contractual and health risk.

Weed control with plant protection products requires a certificate of competence (Legislative Decree No. 150 of 14 August 2012). Waste from the activity, such as containers of hazardous products and contaminated materials, belongs to the business, not the client: it must be sent for recovery or disposal through authorised carriers and, if hazardous, tracked in the RENTRI electronic register. Leaving empty drums in the client’s bins still happens, and it is wrong.

Keys, alarms and confidentiality

Cleaning staff enter closed offices, medical practices and archives, often alone and outside working hours. Handing over keys, badges and alarm codes is an act of trust and should be governed in writing, also to protect staff when something goes missing from a room: who receives them, where they are kept, how access is recorded, what happens when a member of staff leaves the business. As a rule the business does not process data on the client’s behalf and need not be appointed as data processor (Article 28 of Regulation (EU) 2016/679), but a contractual confidentiality undertaking is needed: no reading of documents or screens, no photographs, no throwing away papers without instructions. If the service includes document destruction, the appointment becomes necessary.

Staff

Which collective agreement

The reference agreement is the CCNL (national collective labour agreement) for staff of businesses providing cleaning and integrated/multi-service services. The renewal of 13 June 2025, signed by the cooperative federations, by Unionservizi Confapi and by Filcams-CGIL, Fisascat-CISL and Uiltrasporti-UIL, runs until 31 December 2028, with pay tables set by the agreement of 6 August 2025. ANIP-Confindustria, a long-standing signatory, did not sign this time: its members need to clarify with their association which terms they apply, because the most careful clients already ask at the bidding stage.

For the minimum rates at level 2, the entry level for cleaning operatives, the renewal provides for an increase of €215 when fully phased in, in several instalments up to 2029; in 2026 the instalments took effect on 1 May and 1 October. On the regulatory side, for hires after 13 June 2025 part-time work cannot fall below 15 hours a week, and the renewal addresses the consolidation of additional hours worked on a continuous basis and notice before the protected sick-leave period (comporto) runs out. Minimum rates must be taken from the official tables, not from summary websites: payroll software that has not loaded the October 2026 instalment is already producing incorrect payslips.

Artisan businesses usually apply the CCNL for artisan businesses in cleaning, disinfection, pest control, rodent control and sanitisation. The draft agreement of 17 December 2025 covers 2025-2028, with €215 at level 5 when fully phased in, starting from the January and July 2026 instalments, a one-off payment in two parts in 2026, a 40-day probationary period for operatives hired on or after 1 February 2026 and a 25% supplement for additional hours.

There are also ‘multi-service’ agreements signed by less representative organisations, with lower minimum rates or supplements. Choosing them today creates exposure on several fronts. In contracts for services, staff are entitled to overall terms no less favourable than those of the comparatively most representative agreement for the sector and the area (Article 29(1-bis) of Legislative Decree 276/2003, introduced by Decree-Law No. 19 of 2 March 2024), and the client is jointly liable.

Decree-Law No. 62 of 30 April 2026, converted into law by Law No. 112 of 25 June 2026, adopted the same benchmark as a condition for incentives and required the alphanumeric code of the agreement to be shown on the payslip, which becomes the key to cross-checks between INPS, the Ispettorato (National Labour Inspectorate) and CNEL (National Council for Economics and Labour). The courts may disregard the minimum rates of any agreement if pay is not proportionate and sufficient (Article 36 of the Constitution; Cass., Labour Section, 2 October 2023, No. 27711), and the shortfalls are recovered retrospectively. Finally, unremedied breaches of the sector’s agreements can lead to suspension of the Chamber of Commerce registration. The agreement code must be taken from the CNEL archive, checked against the INPS table and shown consistently on the UNILAV notification, the UniEmens return and the payslip.

Part-time, split shifts, night work

Part-time work is the norm in the sector. The contract must state precisely the duration and scheduling of the work (Article 5(2) of Legislative Decree 81/2015), and shifts are allowed only within pre-set time slots: the wording ‘hours according to site requirements’ does not stand up, with the consequences described in the chapter on employment law. Additional hours must be paid with the contractual supplement and cannot become the actual, stable schedule: a cleaner hired for 15 hours who regularly works 25 in fact has a different schedule, and in a dispute the court reconstructs the relationship on the basis of actual attendance.

Split shifts (two hours at dawn in an office, three in the evening in a supermarket) are lawful if they are set out precisely. With more than one employer, a very common situation, each is responsible for its own employment relationship, but the eleven consecutive hours of rest and the 48-hour average weekly limit apply to the person (Legislative Decree 66/2003): it is advisable to obtain on hiring, and keep up to date, a statement on other employment and its hours. Unless the collective agreement provides otherwise, a night worker is anyone who works at least three hours during the night period, which includes the interval between midnight and 5 a.m., for at least eighty days a year; for such workers the eight-hour average limit applies, together with a health assessment before assignment and at regular intervals.

The change of contractor from the payroll side

For a cleaning business a change of contractor is an everyday event, and it is where most disputes arise. Article 4 of the CCNL Multiservizi distinguishes two cases. If the contract continues on the same terms, methods and services, the incoming contractor hires, without a probationary period, the staff shown by documentary evidence to have been assigned to the contract for at least the four months before it ended. If terms, methods or services change, a joint review is held at the local employers’ association or the Ispettorato, with the RSA (workplace union representatives) and the unions, to reconcile the new requirements with employment levels, including through moves between sites, part-time or reduced hours: that is where a reduction in hours is negotiated when the new specification provides for fewer. The risks of a transfer of a business and the tender rules are dealt with below; on the payroll side the points to watch are these.

• The list of staff with levels, hours, length of service and sites must be provided in good time; its absence does not extinguish the right to be hired (Cass., order of 6 November 2018, No. 28246), but it exposes both businesses.
• The outgoing contractor pays out TFR, accrued instalments of additional monthly pay, holiday and paid time off (permessi); the incoming contractor does not inherit the TFR, unless expressly agreed, but such agreements change the nature of the transaction (see the chapter on taxes).
• The dismissal levy for NASpI (the unemployment benefit) is not due for dismissals followed by hiring by the new contractor in implementation of social clauses (clausole sociali, the obligation to re-employ the outgoing contractor’s staff) (point (a) of Article 2(34) of Law 92/2012; INPS circular No. 40 of 19 March 2020). The condition is documented with the incoming contractor’s letter of appointment; if re-employment is partial or does not derive from the clause, INPS claims the levy.
• An incoming cooperative cannot make hiring conditional on joining as a member: in a case decided on an interim basis, the Court of Monza (order of 22 April 2024) ordered the immediate admission to work of the staff excluded for refusing, with pay from the date of the takeover.
• Hires made in implementation of the social clause do not qualify for contribution incentives, because they fulfil a pre-existing obligation under collective bargaining (point (a) of Article 31(1) of Legislative Decree 150/2015). It is one of the most costly mistakes in INPS audits.

Travel between sites: working time, reimbursements, place of work

This is one of the least discussed and most costly issues. A cleaner who finishes at 8 a.m. in a bank and starts again at 8.30 in a medical practice three kilometres away spends that time meeting an organisational need of the business. Working time is any period during which the worker is at the employer’s disposal and carrying out his or her activity (point (a) of Article 1(2) of Legislative Decree 66/2003), and travel between sites during a shift falls within it, even if the payslip pays only ‘site hours’.

For workers without a fixed or habitual place of work, travel between home and the first or last client of the day is also working time (CJEU, 10 September 2015, C-266/14, Tyco), and the Court of Cassation has declared void clauses that required the worker to absorb a set amount of unpaid travel time (Cass., order of 17 June 2024, No. 16674). If attendance records show only the hours on site, the business builds up pay and contribution shortfalls every day which, with a large workforce and a five-year limitation period, become significant. The correct approach is to organise rounds with short journeys and pay for them, also taking them into account for the working-time limits.

Reimbursements depend on this. Journeys between sites in the worker’s own vehicle outside the municipality of the place of work follow the rules on business travel (Article 51(5) TUIR), with mileage reimbursed on the ACI tables and documented routes; within the municipality of the place of work they are taxable, except for transport costs documented by the carrier. From 2025 reimbursements of meals, accommodation, travel and non-scheduled transport are excluded from income and deductible only if paid by traceable means (Articles 51(5) and 95(3-bis) TUIR, as amended by Article 1(81) of Law 207/2024). For those who work in constant mobility, without a fixed place and with a fixed allowance, the regime for itinerant workers (trasfertisti) applies (Article 51(6) TUIR; Article 7-quinquies of Decree-Law 193/2016). If the contract gives the place of work as ‘the business’s sites’, reimbursements paid for years risk being recharacterised as pay. A precise place of work and a log of journeys resolve the working-time, tax and contribution problems at the same time.

Contributions, the Treasury Fund and supplementary pensions

Contributions follow the business’s classification and the ordinary rates, with no reductions specific to the sector; type B social cooperatives (which employ disadvantaged people) pay no contributions for the disadvantaged persons they take on (Article 4 of Law 381/1991). Fixed-term contracts bear the additional NASpI contribution of 1.4%, increased by 0.5 points at each renewal, and for part-timers with few hours the minimum hourly contribution base applies.

Businesses with at least 50 employees pay the TFR not allocated to pension funds into the INPS Treasury Fund (Fondo di tesoreria) (Article 1(755) of Law 296/2006). From 2026 the obligation also applies to those that reach the threshold in the years after starting business, on the basis of the previous year’s average: 60 employees in 2026-2027, 50 from 2028, 40 from 2032 (Article 1(203) of Law No. 199 of 30 December 2025; INPS circular No. 12 of 5 February 2026). With workforces that grow when contracts are won, the annual average must be monitored. From 1 July 2026 new hires are also automatically enrolled in supplementary pension provision unless they opt out within sixty days (Article 8 of Legislative Decree 252/2005, as amended by Law 199/2025).

INAIL, safety and training

For INAIL purposes cleaning and sanitisation are classified under tariff item 0411 in the Industry and Artisan schemes, 0421 in the Services scheme and 0410 in Other activities (2019 tariffs); portering, grounds maintenance and work at height go under their own items. The risk assessment document must describe the risks of the trade: chemical, with safety data sheets available on site; slipping on wet floors, among the leading causes of accidents; handling of trolleys, buckets and sacks and overloading of the upper limbs; ladders; lone working. It must also consider risks related to gender, age and having come from another country (Article 28 of Legislative Decree 81/2008). Training follows the State-Regions Agreement of 17 April 2025, with a final test of learning, and the transitional period ended on 24 May 2026; where Italian is not the worker’s first language, understanding of the language must be checked (Article 37(13)).

The points-based licence (patente a crediti) (Article 27 of Legislative Decree 81/2008) applies to those who work physically on temporary or mobile construction sites: according to the National Labour Inspectorate’s FAQs, a cleaning business working inside a construction site is required to hold one, but not a business cleaning offices or factories. End-of-works cleaning in a building that is still a construction site falls into the first case. The check on the adequacy of construction labour (congruità, Ministerial Decree No. 143 of 25 June 2021) does not apply to cleaning services as such, but a business subcontracted on a construction site should clarify with the main contractor and the Cassa edile (construction workers’ fund) how its labour is treated.

2026 tax relief and meal vouchers

For people working in cleaning, with modest pay and a great deal of night and public holiday work, 2026 brings some real advantages. Law 199/2025 provides for a 15% substitute tax on pay supplements and allowances for night work, public holiday work, work on rest days and shift work, up to €1,500 a year, for those whose employment income in 2025 did not exceed €40,000 (Article 1(10) and (11)); a 5% substitute tax on pay increases paid in 2026 under renewals signed from 2024 to 2026, for income up to €33,000 (paragraph 7), which covers both the Multiservizi and the artisan renewals; and 1% on performance bonuses paid in 2026 and 2027 up to €5,000 (paragraph 9), with a filed company or local agreement and measurable indicators, such as a reduction in non-conformities recorded by the client.

The practical issue is the worker with more than one employer: the €1,500 limit is a single limit for the person, and anyone who does not have the withholding agent’s Certificazione Unica (the annual certificate of income and tax withheld) must state the previous year’s income in writing. It is advisable to collect these statements on a standard form on hiring and at the start of each year.

From 2026 electronic meal vouchers are excluded from income up to €10 a day (point (c) of Article 51(2) TUIR, as amended by Article 1(14) of Law 199/2025). For short and split shifts they are one of the least costly welfare tools, provided the company rules link them to days actually worked.

Hiring incentives in 2026

Decree-Law 62/2026 provided for 100% contribution relief, excluding INAIL premiums, for permanent hires in 2026 of women without paid employment for at least 24 months (or less if disadvantaged), of disadvantaged young people under 35 and of the long-term unemployed in the single Special Economic Zone (ZES), as well as relief for converting young people’s fixed-term contracts into permanent ones; the instructions are in INPS circulars Nos. 55, 56 and 57 of 14 May 2026, and the monthly ceilings, which differ by measure and by area, should be read there.

For a cleaning business it is above all the conditions that matter: a net increase in employment compared with the average of the previous twelve months, with part-timers counted in proportion to their hours, to be calculated month by month with workforces that change as contracts are won and lost; no economic or collective dismissals in the previous six months in the same unit; compliance with the terms of the comparatively most representative agreement; and a hire that is not the fulfilment of a social clause. The windows close on 31 December 2026, and the 2027 budget law, still under discussion, should be checked before planning hires for contracts starting in January.

Cooperatives and worker-members

A worker-member, who has both a membership relationship and an employment relationship with the cooperative, often as an employee, is entitled to overall terms no lower than the minimum rates of agreements signed by the comparatively most representative organisations (Article 3 of Law 142/2001; Article 7(4) of Decree-Law 248/2007, upheld by Constitutional Court judgment No. 51/2015). The internal regulations must be filed with the Ispettorato within thirty days of approval and may provide for temporary reductions in pay only in a crisis and following the statutory procedures. Ristorni (cooperative refunds to members in proportion to the work they have done) are resolved upon with the financial statements, up to 30% of total pay (point (b) of Article 3(2)); their tax treatment is in the chapter on taxes, and the exclusion of a member in the chapter on employment law.

Issues the textbooks barely cover

Residence permits. Anyone who has applied to renew a residence permit before it expires, or within sixty days, may continue to work until any refusal (Article 5(9-bis) of Legislative Decree 286/1998): the receipt must be kept and a schedule of permit expiry dates maintained, reminding the person concerned of the expiry in good time, because employing workers without a valid permit is a criminal offence (Article 22(12)).

Unpaid hours on site. When the specification provides for an insufficient number of hours and the team leader asks staff to ‘finish anyway’, the extra hours go unrecorded: this is unpaid work for those who did it, a risk of pay claims and, in an inspection, an indicator of labour exploitation. Attendance must be recorded on every site, and the hours brought into line with the specification before the contract is accepted.

Employment law: the sticking points

Genuine contract or mere supply of workers

In cleaning the real capital is people, and machines and products are often supplied by the client: this is why the line between a service contract (appalto) and the supply of labour (somministrazione) is a fine one. Article 29(1) of Legislative Decree 276/2003 identifies a genuine contract by the organisation of the means, which in contracts consisting almost entirely of labour may be shown by the exercise of organisational and managerial authority over the workers, and by the assumption of business risk. According to the Court of Cassation, in labour intensive contracts the contractor must be given an autonomous result to achieve and must exercise real managerial authority over its own employees; if that authority remains with the client there is unlawful labour intermediation (interposizione illecita), even if the client did not choose the individual workers (Cass. 27 April 2022, No. 13182). The client may set priorities and check the result; it may not assign shifts, move cleaners from one department to another, grant holidays or discipline them. The risk arises in the daily life of the site, when the business’s team leader is never there and instructions come from the plant manager or the condominium administrator.

For the same reason, a client that complains about inadequate cleaning is alleging a breach of contract by the business, not by the individual cleaner. If the business wishes to take disciplinary action, it does so under the procedure in Article 7 of Law 300/1970 (the Workers’ Statute), on the basis of its own findings: the client’s report alone is not enough, and a complaint about quality often reflects contracted hours too few for the work to be done better.

Joint and several liability and minimum terms

A client that is a business or an employer is jointly and severally liable with the contractor and with every subcontractor, for two years after the contract ends, for pay, TFR, contributions and insurance premiums, excluding civil penalties (sanzioni civili) (Article 29(2) of Legislative Decree 276/2003); following Constitutional Court judgment No. 254/2017 the protection extends to subcontracting of supplies (subfornitura). A client who is an individual not carrying on a business or profession is excluded (paragraph 3-ter); for the condominio the question is open. The contractor’s employees also retain a direct action against the client, up to the amount the client still owes (Article 1676 of the Civil Code). Paragraph 1-bis, mentioned above, also makes the client liable for shortfalls arising from a ‘minor’ collective agreement.

Two clarifications avoid unfounded alarm. The contractor’s joint tax liability for the subcontractor’s withholding tax has been repealed (Article 28 of Legislative Decree 175/2014), and the VAT liability in Article 60-bis of Presidential Decree 633/1972 concerns only supplies of goods identified by decree, not services. The obligations in Article 17-bis of Legislative Decree 241/1997, discussed below, remain. A prudent client checks that the price is compatible with the Ministry’s labour cost tables, verifies that management and organisation really lie with the contractor and keeps the evidence: DURC (certificate of social security compliance), specification, contact persons, attendance records kept by the contractor.

Change of contractor and transfer of a business

Article 29(3) of Legislative Decree 276/2003, rewritten by Law No. 122 of 7 July 2016, provides that taking on the staff already employed on the contract, under the law, a collective agreement or a clause of the service contract, is not a transfer of a business, but only if the incoming contractor has its own organisational and operational structure and there are ‘elements of discontinuity that determine a specific business identity’.

EU law is less clear-cut, and it originated precisely in a cleaning contract. In Süzen (CJEU, 11 March 1997, C-13/95), concerning a school cleaner dismissed when her employer lost the contract, the Court held that the loss of a contract is not enough, but that in an activity based essentially on manpower there is a transfer if the new contractor takes over an essential part of the staff. In Somoza Hermo (CJEU, 11 July 2018, C-60/17) the Court specified that a transfer may also arise when re-employment is required by a collective agreement. In Italy the Court of Cassation upheld the classification as a transfer of part of a business of a takeover in which the new contractor had changed only the uniforms and identity badges (Cass. 25 October 2024, No. 27707).

Where the incoming contractor almost always takes over the same people on the same site, discontinuity must be built and documented: its own contract managers, different shifts and methods, its own equipment, independent quality control. Without it Article 2112 of the Civil Code applies: employment relationships continue with length of service, and transferor and transferee are jointly liable for accrued claims, that is arrears, length-of-service increments and TFR, which the incoming contractor inherits without having priced them in. The risk increases if the incoming contractor also takes over its predecessor’s equipment, premises or organisation; the tax consequences are in the chapter on taxes.

Those left out: dismissal for loss of the contract

The social clause in public contracts (Article 57 of Legislative Decree 36/2023) is consistently read by the Council of State as an obligation to be reconciled with freedom to conduct a business: it does not require all the staff to be taken on again, nor their organisation to be replicated, nor previous length of service to be recognised. Those not re-employed remain employees of the outgoing contractor, which must redeploy or dismiss them. The collective redundancy procedure is excluded only for workers re-employed by the incoming contractor on the same terms (Article 7(4-bis) of Decree-Law 248/2007): for the others, in a business with more than fifteen employees, five dismissals within one hundred and twenty days require the procedure under Law 223/1991, which the joint review under the collective agreement does not replace.

In an individual dismissal, loss of the contract justifies the abolition of the post, but does not relieve the employer of the repêchage duty: the employer must prove that it cannot redeploy the worker to other sites or compatible duties (Cass. 28 August 2025, No. 24051). For those hired after 7 March 2015 there is reinstatement if the material fact does not exist (Constitutional Court judgment No. 128/2024), whereas if only the repêchage is missing the remedy is compensation; for businesses with up to fifteen employees the Constitutional Court has removed the six-month cap (judgment No. 118/2025). In cleaning a little-known rule also matters: for the purposes of compensation, the length of service of a worker who passed to the incoming contractor includes the whole period worked on the contract, including with previous employers (Article 7 of Legislative Decree 23/2015).

Part-time: the form that decides cases

If a part-time contract does not state the duration, the court may declare the relationship full-time; if it does not state the scheduling of hours, the court sets it, taking account of the person’s family responsibilities and other work, and awards damages for the past (Article 10(2) of Legislative Decree 81/2015). The Court of Cassation has confirmed that stating the shifts does not dispense with stating the hours (order of 29 April 2024, No. 11333). Changes are handled through written flexibility clauses (clausole elastiche), with two working days’ notice and the compensation set by the collective agreement; if the agreement does not regulate them, they are agreed before a certification board, with a maximum increase of 25% of annual hours and a 15% supplement (Article 6). Consent can be withdrawn in the cases provided by law, refusal is not a justified reason for dismissal, and work outside the rules gives entitlement to damages in addition to pay (Article 10(3)).

Cooperatives: the excluded member

A member’s employment relationship ends with withdrawal or exclusion resolved in accordance with the articles of association (Article 5(2) of Law 142/2001). An excluded and dismissed member may challenge the dismissal without challenging the resolution, but if the exclusion stands he or she obtains only damages, because without the membership bond the relationship cannot be revived (Cass., Joint Divisions, 20 November 2017, No. 27436). The quality of the resolution matters: it must state a fact provided for in the articles and follow the procedure. When the cooperative is ‘spurious’, with no real membership life, the cooperative form does not protect the client: the case reverts to labour intermediation and joint liability.

Badges, clocking apps and geolocation

Tools for recording attendance do not require a union agreement or authorisation (Article 4(2) of Law 300/1970); tools that also allow remote monitoring do (paragraph 1), and the data may be used only with adequate information and in compliance with data protection rules (paragraph 3). For the Ispettorato, GPS systems as a rule fall under paragraph 1 (INL circular No. 2/2016).

On apps that clock in using the smartphone’s location the picture is not settled: the Garante (Italian Data Protection Authority) penalised a public body for shortcomings in information, impact assessment and proportionality (measure No. 135 of 13 March 2025), and a 2026 first-instance judgment set aside the penalty, treating location recorded only at the moment of clocking in as an attendance tool (Court of Cosenza, 1 July 2026, No. 972). The prudent line is to record location only at clocking in, never continuously and without reconstructing routes, with specific information, an impact assessment, short retention and an agreement or authorisation as soon as the app does anything more. The worker has the right to access his or her own geolocation data (Garante, measure of 14 September 2023).

Lone working, harassment and maternity

Empty offices, closed shopping centres, dark car parks: cleaners often work alone. Article 2087 of the Civil Code requires the measures needed to protect physical integrity and personal dignity, and lone working must be treated as a specific risk, with call and alarm systems, regular check-ins and arrangements with the client on lighting and access, within the coordination required by Article 26 of Legislative Decree 81/2008. Harassment, including sexual harassment, is discrimination (Article 26 of Legislative Decree 198/2006; ILO Convention No. 190, ratified by Law 4/2021), and harassment by third parties present on site also counts: the business must take action vis-à-vis the client as well, and anyone who suffers or reports harassment must know whom to turn to within the business.

For pregnant workers, work between midnight and 6 a.m. is prohibited until the child is one year old (Article 53 of Legislative Decree 151/2001), as are strenuous or unhealthy work and exposure to hazardous chemical agents (Article 7): in a trade made up of detergents, buckets and ladders, this means changing duties immediately or, if that is not possible, applying to the Ispettorato for early maternity leave (Article 17). Dismissal during the protected period is void (Article 54).

Absence from site and resignation by conduct

If an unjustified absence exceeds the period set by the collective agreement or, failing that, fifteen days, the employer may notify the Ispettorato and the relationship is deemed terminated at the worker’s will, unless the worker proves that it was impossible to communicate the reasons (Article 26(7-bis) of Legislative Decree 151/2015, introduced by Law No. 203 of 13 December 2024). The procedure is optional, takes effect on notification, excludes NASpI and the dismissal levy, and collective agreements cannot set periods shorter than fifteen days (INL note No. 579/2025; Ministry of Labour circular No. 6/2025).

The typical case is the cleaner who stops turning up after a move to another site or a change in hours: before using the procedure, the business must ask itself whether the absence is really unjustified, because a transfer without reasons (Article 2103 of the Civil Code) or hours changed without a flexibility clause may make the refusal lawful, and the ‘resignation’ turns into an oral dismissal. It is advisable first to contact the person and find out what happened, then to send a written disciplinary notice beforehand, with proof of receipt.

VAT

The activity code after ATECO 2025

The ATECO 2025 classification has been in force since 1 January 2025 and has been used in the documents of the Agenzia delle Entrate (Italian Revenue Agency) since 1 April 2025. Group 81.2 has been redesigned, and businesses that have not checked the automatic conversion at the Chamber of Commerce and in the tax register (Anagrafe tributaria) risk having a code that no longer describes what they do.

Related activities have their own codes: 81.10.00 for combined facilities support services, 81.30.00 for landscape services, 52.24.40 for cargo handling at industrial sites, that is the portering done by multi-service businesses. The code must be notified for each activity carried on: it determines the applicable synthetic reliability index and is the first clue an auditor uses to challenge the VAT treatment of an invoice.

The reverse charge on building cleaning

Since 1 January 2015, cleaning services relating to buildings supplied to taxable persons have been invoiced without VAT, which the client accounts for under the reverse charge (Article 17(6)(a-ter) of Presidential Decree 633/1972). The rule does not depend on the supplier’s sector or on the type of contract: it applies to a business cleaning a professional practice as much as to the subcontractor of a construction firm (circular No. 14/E of 27 March 2015). On the electronic invoice the service is shown with nature code N6.7 and the client completes it with a TD16 document.

The scope is narrower than many believe. The Agenzia identified the services by ATECO 2007 codes 81.21.00 and 81.22.02, the latter only as regards buildings, excluding the cleaning of industrial plant and machinery, and adopted the definition of building in Article 2 of Legislative Decree 192/2005: residential and business buildings, including those under construction, and parts of them, even a single room (circular 14/E/2015, paragraphs 1.2 and 1.3). The result is a map worth keeping to hand.

• Offices, warehouses, homes, single rooms, buildings under construction, façades and external glazing: reverse charge towards clients that are taxable persons.
• Yards, open-air car parks, gardens, swimming pools, land: ordinary VAT, unless they form an integral part of the building; underground car parks and rooftop car parks, on the other hand, are subject to the reverse charge (circular No. 37/E of 22 December 2015, paragraph 4).
• Rodent control and pest control, emptying of septic tanks and drains, snow removal: ordinary VAT (circular 37/E/2015, paragraph 5).
• Cleaning of trains, buses, ships, aircraft and any movable property, of production lines and machinery: ordinary VAT.
• Cleaning of buildings in ports, airports and border crossings falling within Article 9(1), point 6: non-taxable (non imponibile), so no reverse charge (circular 37/E/2015, paragraph 16).
• Supplier under the flat-rate regime (regime forfettario): no reverse charge, invoice without VAT under the flat-rate regime’s VAT franchise (circular 14/E/2015, paragraph 7).

A little-known corollary follows from the same paragraph 16: the reverse charge presupposes a taxable transaction, and if the client is a habitual exporter (esportatore abituale) that has sent its declaration of intent (dichiarazione d’intento), the cleaning is invoiced as non-taxable under Article 8(1)(c), without the reverse charge and with stamp duty above €77.47. The Agenzia applied the same principle to exempt cleaning in vaccination hubs (reply to a ruling request (risposta a interpello) No. 502/2022).

The link with the new codes remains open. At Telefisco on 24 September 2026 the Agenzia clarified that for construction subcontracting under point (a) it is section F of ATECO 2025 that counts, but it did not comment on point (a-ter); the new 81.22.09, which combines buildings and industrial cleaning, is not enough on its own to determine the treatment. The prudent reading, shared by ANCE (the national association of construction firms), is to look at the objective nature of the service as described in circular 14/E, not at the code.

Sanitisation, mixed services and facility management

There is no official clarification on sanitisation, and the question must be treated in the same way in all the business’s documents. Ministerial Decree 274/1997 distinguishes it from cleaning, circular 37/E/2015 excluded pest control from the reverse charge, and the new code 81.23.10 places it with disinfection and pest control, outside the building cleaning codes. Some commentators bring it within specialised cleaning when it is carried out on buildings; the prevailing view, and the solution we recommend until the Agenzia rules on it, is to invoice sanitisation supplied as a separate service, priced and documented separately, with ordinary VAT. The reverse also holds: ordinary cleaning carried out with disinfectant products remains cleaning, and calling it sanitisation on the invoice to avoid the reverse charge does not stand up.

In global service contracts a single fee often covers cleaning, concierge services, minor maintenance, grounds maintenance and pest control. The Court of Justice treats a composite service as a single supply when its elements form a transaction that it would be artificial to split, or when one is principal and the others ancillary (C-349/96, Card Protection Plan; C-41/04, Levob), but in facility management the test almost always leads to disputes, because concierge services are not ancillary to cleaning, nor grounds maintenance to either.

The Agenzia requires the consideration to be broken down using objective criteria: contractual agreements, prices, floor areas, hours (circular 14/E/2015, paragraph 8). The solution lies in the contract before it lies in the tax treatment: each service priced separately in the specification and invoiced on separate lines, each with its own treatment: reverse charge for building cleaning and for maintenance of installations in buildings, ordinary VAT for outdoor areas, pest control, separate sanitisation, grounds maintenance, reception and portering. If the client wants a single fee, the apportionment must be anchored to the hours, square metres and frequencies in the specification and kept in the contract file.

For portering supplied to transport and logistics businesses with a predominant use of labour, a reverse charge is provided for, subject to EU authorisation, and in the meantime an optional regime under which the client pays the VAT on the supplier’s behalf (Article 1(57) to (59) of Law 207/2024; resolution No. 47/E of 28 July 2025).

Clients that change the treatment

• Condomini and private individuals. They are not taxable persons: VAT at 22% and, for the condominio, 4% withholding tax. Shopping centres, office complexes and large multi-building complexes, however, are often managed by consortia or companies with a VAT number: in that case cleaning of the common parts is subject to the reverse charge and withholding tax does not apply. Before the first invoice, check the client’s tax identification number (codice fiscale) in the tax register, not the name on the contract.
• Non-commercial bodies with business activities. If the cleaning concerns premises used partly for commercial and partly for institutional activities, the consideration is apportioned using objective criteria, for example floor areas: reverse charge for the commercial share, ordinary VAT or split payment for the rest (circular 14/E/2015, paragraph 8).
• Public authorities and controlled companies. For the bodies and companies covered by Article 17-ter of Presidential Decree 633/1972, as listed by the Department of Finance, the business charges VAT with chargeability code ‘S’ and collects only the taxable amount. The EU authorisation has been extended without interruption until 30 June 2029 (Council Implementing Decision (EU) 2026/1728 of 10 July 2026).
• Relationship between the two mechanisms. If the public body buys for a commercial activity, the reverse charge prevails; split payment applies only to institutional purchases (circular 14/E/2015, paragraph 4). A hospital or a municipality that has premises under commercial management cleaned may ask for reverse-charge invoices for that part.

Consortia, subcontracting and invoice chains

Services supplied by consortium members to the consortium follow the treatment that the consortium applies to the end client (circular 19/E/2007, referred to in circular 14/E/2015, paragraph 5): if the consortium invoices under the reverse charge, so do its members; if it works for a public authority under split payment, it collects only the taxable amount while its members charge it ordinary VAT, and the consortium builds up a structural credit. The reverse charge between members and a consortium awarded public contracts (point (a-quater)) is subject to an EU authorisation which, as far as we are aware, has not been granted. In subcontracting the logic is different: the subcontractor invoices the main contractor, which is a taxable person, and therefore under the reverse charge if it is building cleaning, even when the end client is a public authority under split payment. The two chains should be kept separate from the outset in the customer master data of the accounting software.

The structural VAT credit: refunds and set-off

Under the reverse charge the business does not charge VAT, and under split payment it does not collect it; but it does pay VAT on products, equipment, vehicles, fuel, hire and consultancy. Labour, the main cost, carries no VAT, but the rest is enough to generate a credit that recurs every year; the chapter of examples shows how it builds up. Here we look at the ways of recovering it.

A refund is available to those who make exclusively or mainly supplies whose average rate, increased by 10%, remains below the rate on purchases, counting reverse-charge and split-payment supplies among the supplies made (Article 30(3)(a) of Presidential Decree 633/1972; instructions to form TR). For businesses working this way the requirement is normally met, including for the quarterly refund when the quarter’s credit exceeds €2,582.28 (Article 38-bis(2)). Above €30,000 the refund is made without a guarantee only with a compliance endorsement (visto di conformità) and a statement in lieu of an affidavit on the asset and contribution requirements, except in the risk situations in paragraph 4, such as having been in business for less than two years; a good ISA (synthetic reliability index) score gives relief from the endorsement and the guarantee within the annual thresholds.

The priority refund is the natural route for these businesses, and it is often overlooked. It is available to those who supply the services in point (a-ter) (Ministerial Decree of 29 April 2016) and to those who deal with bodies under split payment, up to the VAT applied to those supplies (codes 8 and 6 of form TR), subject to the requirements of the Ministerial Decree of 22 March 2007: at least three years in business, a credit claimed of at least €10,000 a year or €3,000 a quarter, equal to at least 10% of the VAT on purchases for the period. Refunds in the sector are among the most closely checked, with attention to consistency between purchases and hours worked, to suppliers of products and to vehicles registered in shareholders’ names; and the EU decision on split payment requires Italy to report on the impact of the measure on refunds by 30 September 2027.

For set-off, a credit above €5,000 requires the compliance endorsement and can be used from the tenth day after the return or application is filed, up to €2,000,000 a year (Article 1(72) of Law 234/2021). From 2026 set-off is barred where amounts over €50,000 entrusted to the collection agent are overdue and not suspended, a threshold reduced from €100,000 by the 2026 budget law (Article 37(49-quinquies) of Decree-Law 223/2006). In contracts subject to Article 17-bis, without the certificate of requirements the credit cannot be set off against the withholding tax, contributions and insurance premiums for the workers on the contract, which are precisely the largest payments. The annual credit claimed as a refund can also be assigned (Article 5(4-ter) of Decree-Law 70/1988), comparing the assignee’s discount with the actual time the refund takes.

Credit and debit notes and contractual penalties

Invoices to public authorities show the unique office code and the CIG (tender identification code). When a contract ends and the client disputes hours, contractual penalties (penali) or services not provided, credit and debit notes (note di variazione) follow the treatment of the invoice they adjust. A reduction following a subsequent agreement is allowed only within one year of the supply (Article 26(3) of Presidential Decree 633/1972); after that, it is dealt with under civil law but does not recover the VAT.

Contractual penalties for service failures are compensatory in nature and are outside the taxable amount (Article 15(1), point 1, of Presidential Decree 633/1972). VAT is calculated on the consideration before deducting the penalty, and under split payment the downward adjustment is an option for the supplier that the public body cannot exercise in its place (reply No. 436 of 28 October 2019). Many contracting authorities nonetheless ask for a credit note for the penalty: none should be issued for the penalty as such; the body pays the net amount and the business records the penalty as a negative item. A credit note is issued only when the consideration is genuinely reduced, for a service not provided or for reduced services provided for in the contract.

Errors of treatment and penalties

Taxes, accounting and audits

Choosing the legal form

Many businesses start as sole proprietorships or artisan partnerships. Entry in the register of artisan businesses requires the owner to take part personally in the work and to stay within the limits of Article 4 of Law 443/1985: for businesses that do not produce in series, 18 employees including up to nine apprentices, which can rise to 22 with apprentices. These numbers, which for part-timers are as a rule counted in proportion to their hours (Article 9 of Legislative Decree 81/2015), are soon exceeded with large workforces, and that is when the artisan form ceases to be suitable, with effects also on the collective agreement and on the INPS and INAIL classifications. For medium-sized businesses the srl (limited liability company) is the most common form: it ring-fences assets, offers banks and contracting authorities readable financial statements and pays IRES (corporate income tax) at 24% instead of the IRPEF (personal income tax) rates. A consortium, ordinary or permanent (stabile), is used for tenders that no member would tackle alone.

The flat-rate regime is rare, not because of the €85,000 revenue limit but because of the limit on expenditure on employees and collaborators, which must not exceed €20,000 gross (Article 1(54) of Law 190/2014): one part-time employee for a year is enough to approach it. It remains suitable for those who work alone for private individuals and condomini: they do not apply the reverse charge, are not subject to the condominio’s withholding tax (paragraph 67) and do not deduct VAT on machinery. The move to the ordinary regime should be planned before the first hire.

Cooperatives: prevalence, tax relief, ristorni

A production and labour cooperative has predominantly mutual status (mutualità prevalente) when the labour cost of its members exceeds 50% of its total labour cost (point (b) of Article 2513 of the Civil Code); social cooperatives have that status by law. In cooperatives that take on staff in changes of contractor, often with non-member employees for long periods, the ratio can fall below the threshold without anyone noticing, with effects on the indivisible reserves and on the treatment of profits: it should be calculated at least every six months and documented in the notes to the financial statements.

Production and labour cooperatives are exempt from IRES if the pay to members is not less than 50% of other costs, excluding raw and ancillary materials, and pay half the IRES between 25% and 50% (Article 11 of Presidential Decree 601/1973). For cooperatives other than social cooperatives, however, since 2005 the exemption applies only to the income deriving from the non-deductibility of IRAP, and a share of net profits remains taxable even if allocated to an indivisible reserve (Article 1(460) to (462) of Law 311/2004; social cooperatives are excluded, paragraph 463): the benefit is much more limited than many members believe.

Ristorni are deductible (Article 12 of Presidential Decree 601/1973) if they derive from activity with members, are allocated in proportion to the work done and are resolved upon with the financial statements (Article 2545-sexies of the Civil Code); ristorni calculated also on the work of non-members or on results of activity with third parties are the most frequent finding in audits. Some regions provide IRAP reductions for social cooperatives, to be checked in the regional law of the registered office. Spurious cooperatives, which have nothing to do with genuine cooperation, risk being placed under a commissioner or wound up (Article 2545-sexiesdecies of the Civil Code).

IRAP: the weight of fixed-term work

Since 2015 the cost of permanent employees, including part-timers, has been fully deductible for IRAP purposes (Article 11(4-octies) of Legislative Decree 446/1997), and for a business with a stable workforce the tax becomes very modest. The burden returns with fixed-term contracts and agency work: for seasonal workers employed for at least 120 days in two tax periods, 70% of the cost is deductible, from the second contract with the same employer within two years (Article 1(73) of Law 208/2015); for the others only the smaller deductions in paragraph 1 of Article 11 remain. In businesses that cover seasonal peaks, such as schools, tourist facilities or one-off sanitisation work, the choice between fixed-term and permanent contracts has an IRAP effect that should be calculated beforehand: converting repeated contracts sometimes costs less in tax terms too.

The enhanced deduction for new hires

For the tax periods from 2024 to 2027 the cost of new permanent hires is deductible for IRES and IRPEF purposes with a 20% uplift, increased to 30% for certain categories, if at the end of the period both permanent employees and the total workforce have increased compared with the previous year (Article 4 of Legislative Decree 216/2023; Article 1(399) and (400) of Law 207/2024; Ministerial Decree of 25 June 2024; circular No. 1/E of 20 January 2025). The delicate case is the change of contractor: the staff taken on are neither assigned with the contract nor transferred with a business unit, situations that the circular does regulate, and for the incoming contractor it is a new hire, for the outgoing one a fall in workforce. There is no official clarification on staff hired under a social clause; the prudent solution is set out in the grey areas. In any case the count should be made year by year and kept with month-by-month workforce schedules.

Article 17-bis and the DURF

Article 17-bis of Legislative Decree 241/1997 applies when a resident client that is a withholding agent and carries on a business or profession entrusts a business with works or services worth more than €200,000 a year, with a predominant use of labour at its premises and with capital goods attributable to it: the typical profile of cleaning in a factory or a shopping centre. Condomini and non-commercial bodies acting in their institutional capacity are excluded (circular No. 1/E of 12 February 2020).

These are the calculations that clients get wrong most often. The threshold is measured for each contractor and each calendar year; in multi-year contracts at a fixed price the consideration is apportioned by month, in framework contracts payments made count and the obligations start with the payment that exceeds the threshold. The predominance test is the ratio of the staff’s gross pay to the price of the service, and in cleaning it almost always exceeds 50%. Capital goods count if attributable to the client on any basis: premises, storerooms, machinery on free loan, goods lifts.

When the rule applies, the contractor pays the withholding tax of the workers employed on the contract using separate F24 payment forms for each client, without set-off, and within five working days of the due date sends the forms and a list of names with the hours worked; a client that finds failures suspends payments up to 20% of the value of the service or up to the amount of unpaid withholding tax and notifies the Agenzia within ninety days, failing which it becomes liable for an amount equal to the penalty imposed on the business (paragraph 4). The ban on set-off also covers contributions and insurance premiums for the workers on the contract (paragraph 8).

None of this applies if the business provides the certificate that the requirements are met, the so-called DURF, valid for four months: at least three years in business, compliance with filing obligations, payments into the tax account over the last three years of not less than 10% of declared revenue, and no debt over €50,000 entrusted to the collection agent that is overdue and not being paid in instalments (paragraphs 5 and 6).

The 10% looks difficult for those working under the reverse charge, but all F24 payments count before set-off, including contributions and INAIL premiums, and the Agenzia includes the VAT on reverse-charge and split-payment supplies paid by clients in place of the business (resolution No. 53/E of 22 September 2020), payments made in the three-year period on notices following automated checks (avvisi bonari) (reply No. 63/2026) and, according to reply No. 174/2026, also withholding tax on bank interest income and foreign taxes up to the credit under Article 165 TUIR. The percentage should be monitored in advance and the certificate’s expiry entered in the schedule of deadlines: a DURF that expired a few days ago blocks payments from a major client and freezes the VAT credit.

The condominio’s 4% withholding tax

The condominio withholds 4% of the consideration for service contracts supplied in the course of a business, on the taxable amount net of VAT (Article 25-ter of Presidential Decree 600/1973), and pays it over using tax codes 1019 or 1020, being able to wait until the amount reaches €500 and in any case paying by 30 June and 20 December (paragraph 2-bis, introduced by Law 232/2016). If the administrator withholds the tax but does not pay it over, the business subject to withholding is not jointly liable (Cass., Joint Divisions, 12 April 2019, No. 10378) and retains the right to credit it, because Article 22 TUIR refers to withholding ‘made’; but the credit must be supported by the Certificazione Unica or, failing that, by bank transfers, receipts and accounts showing payment of the net amount. With many condomini it is advisable to reconcile net receipts, certificates and the online tax records (cassetto fiscale) every year, and to ask for missing certificates immediately.

DURC: compliance as a condition for being paid

The DURC, valid for 120 days (Article 4 of Decree-Law 34/2014; Ministerial Decree of 30 January 2015), is a condition for being paid by public bodies, for taking part in tenders and for many forms of relief. In the event of non-compliance the contracting authority withholds the amount due and pays it to the bodies concerned (Article 11(6) of Legislative Decree 36/2023), and Law 82/1994 in turn makes public payments conditional on proof that contributions have been paid (Article 5(2)). A late F24 or an unexplained discrepancy in UniEmens can block cash flow from several contracts at once: compliance should be checked every month, not when the notice of irregularities arrives.

ISA: DG70U and the labour indicators

For the 2025 tax period, codes 81.21.00, 81.22.09, 81.23.10, 81.23.99 and 81.30.00 are assigned to ISA DG70U ‘Cleaning services and landscape care and maintenance services’, which has not changed its code, unlike other indices; sterilisation (81.22.01) and street cleaning (81.23.91) fall under DG15U ‘Services n.e.c.’ (2026 ISA instructions, general part). The ISA do not apply above €5,164,569 of revenue. The indicators relate revenue, value added and income to the number of workers calculated on paid days: many hours and little revenue give a low score, and the causes are often accounting ones, such as contracts lost in mid-year, staff on sick leave or wage supplementation counted in full, December revenue invoiced in January and not recognised on an accrual basis. The score gives access to reward benefits, including relief from the compliance endorsement or the guarantee for VAT refunds, and it weighs on the concordato preventivo biennale (the two-year advance tax agreement) (Legislative Decree 13/2024): it should be simulated before the year is closed.

Labour costs, provisions, accrual

At year end, accrued and untaken holiday, paid time off and additional monthly pay must be recognised, with the related contributions, and the TFR provision reconciled with payments to the Treasury Fund and to pension funds. Probable liabilities from changes of contractor, such as workers not taken on or differences in level and hours, are covered by a provision for risks (OIC 31), which is not deductible for tax purposes (Article 107(4) TUIR): the cost is deducted when it becomes certain. The same applies to the provision for onerous contracts, when it is already known in the first year that a service won with a large discount will close at a loss. Arrears from contract renewals are deducted in the year in which the agreement is signed and their amount can be determined (Article 109(1)). An item allocated to the wrong year is not non-deductible as such: the tax office challenges its allocation, and the correction is made in the right year with an amended return (dichiarazione integrativa).

A cleaning business makes or loses money contract by contract. It needs a cost centre for each contract, fed by the hours in the libro unico del lavoro (the statutory payroll and attendance register) for each site, and by products and vehicles: with it the business decides on renewals, requests price revisions and justifies its tender bid. For continuous services, consideration is deemed earned on the date it accrues (point (b) of Article 109(2) TUIR): the December fee invoiced in January is revenue of the year just closed, and a price revision is recognised when it is certain and determinable.

Equipment, vehicles and stock

The Ministerial Decree of 31 December 1988 has no category for cleaning businesses. The most widespread practice applies the residual item for activities not specified, with 15% for sundry machinery and equipment, such as scrubber-dryers, rotary floor machines, vacuum cleaners and pressure washers; the choice should be justified and applied consistently. Goods vehicles have 20%, cars 25%; in the first year the rate is halved, and assets costing up to €516.46 may be deducted in full (Article 102(2) and (5) TUIR).

For cars the limits in Article 164 TUIR and VAT deduction at 40% apply (point (c) of Article 19-bis1 of Presidential Decree 633/1972); vans carrying teams and materials to sites are fully deductible, and it is useful for the vehicle log to show the contract to which each is assigned. Stocks of detergents, paper and spare parts distributed across sites are often not counted: when significant they must be valued (OIC 13; Article 92 TUIR), because a systematic understatement is read in an audit as a deliberate choice.

Receivables from public authorities

On late payments, default interest runs without any formal demand: the period is thirty days, sixty for health service bodies (Article 4 of Legislative Decree 231/2002), and the rate is the ECB rate plus eight points (Article 5), 10.40% for the second half of 2026, with €40 per invoice for recovery costs. Few businesses claim it, for fear of damaging the relationship; a formal request made at regular intervals, in a neutral tone, is in fact normal practice.

Default interest is excluded from the VAT taxable amount, does not enter the IRAP base and is included in income only when received (Article 109(7) TUIR): if it is recognised in the financial statements on an accrual basis, a downward adjustment is needed and then an upward one on receipt. A business that waives it in a settlement has no loss to deduct, because it was never taxed on it. Receivables certified on the Commercial Receivables Platform (Piattaforma dei crediti commerciali) can be set off against amounts entered on the collection roll (Article 28-quater of Presidential Decree 602/1973), a little-used tool that often avoids having to pay in instalments.

The 0.50% retention on payments, released at final settlement after the DURC has been checked (Article 11(6) of Legislative Decree 36/2023), is a receivable that builds up over years and should be kept in a separate account. Premiums for tender guarantees are costs to be spread over their term, with the commitments disclosed in the notes; cash security deposits are receivables. For public contracts whose procedure began on or after 1 July 2023, stamp duty on the contract is a flat amount by bracket, from zero below €40,000 up to €1,000 (Annex I.4 to Legislative Decree 36/2023), paid with the F24 Elide form (code 1573), and does not cover invoices (circular No. 22/E of 28 July 2023). Commissions paid to agents who introduce private contracts are subject to 23% withholding tax on 50% of the amount, or on 20% if the agent uses employees or third parties (Article 25-bis of Presidential Decree 600/1973), and are deductible only if the activity is documented.

Change of contractor: hiring or transfer of a business unit

The tax consequences of a takeover depend on how the transaction is documented. An agreement that transfers equipment, stock, contracts and staff with the related liabilities is a transfer of a business unit: outside the scope of VAT (point (b) of Article 2(3) of Presidential Decree 633/1972), subject to proportional registration tax, with the transferee jointly liable for the transferor’s tax debts within the limits of Article 14 of Legislative Decree 472/1997, which a certificate of pending tax liabilities requested before signing makes it possible to limit. If, on the other hand, the incoming contractor hires the workers under new contracts and perhaps buys individual assets at market price, with an invoice and VAT, there is no business. Following the amendment of Article 20 of the consolidated registration tax Act (Law 205/2017) and Constitutional Court judgment No. 158/2020, the tax office cannot recharacterise the instrument on the basis of elements extraneous to its content: how the agreement is drafted is decisive. An assumption of TFR in exchange for a price, inserted carelessly in a private agreement, is the clue that most often leads to recharacterisation, for tax and employment purposes alike.

Spurious cooperatives and non-genuine contracts: the tax bill

The first to suffer are compliant businesses, forced to compete against impossible prices: cooperatives or companies with no organisation of their own, which supply only labour at prices incompatible with the collective agreement, last a few years and leave debts behind. According to the criminal division of the Court of Cassation, anyone who uses invoices for a contract that conceals an unlawful supply of labour commits the offence of fraudulent tax return (Article 2 of Legislative Decree 74/2000), because the invoices document a transaction different from the real one (among others Cass. crim., Section III, No. 45114/2022 and No. 34407/2024), even if the issuer has paid the VAT and the cooperative exists and operates. The client loses the deduction and, for IRAP purposes, the cost is treated as a staff cost.

In cleaning for businesses there is a particular feature: under the reverse charge the client accounts for the tax itself, and the loss to the Treasury typical of VAT fraud is absent. Article 6(9-bis.3) of Legislative Decree 471/1997 therefore provides that on assessment both the liability and the deduction are eliminated, with a penalty proportional to the taxable amount (5%, with a minimum of €1,000, in the wording resulting from Legislative Decree 87/2024), whereas if knowing participation in a fraud is proven the deduction is lost and the ordinary proportional penalties apply. The greater risk shifts to IRAP, contributions, joint liability and the offence under Article 18 of Legislative Decree 276/2003. For income tax purposes, costs of transactions that are fictitious as to the parties remain deductible if they are real, related to the business and accrued in the period, except those directly used to commit an intentional offence (Article 14(4-bis) of Law 537/1993).

Where audits start

In a cleaning business the ratio between hours worked and revenue is almost fixed, and the analytical-inductive assessment (point (d) of Article 39(1) of Presidential Decree 600/1973) starts from there: revenue per hour that is too low compared with rates suggests undeclared revenue, and a labour cost that is too low compared with the areas cleaned suggests undeclared work. The Ispettorato and INPS compare the same figures, and a finding in one area almost always becomes an assessment in the others. Cash transfers of €5,000 or more are prohibited (Article 49 of Legislative Decree 231/2007), and cash payments to suppliers and occasional collaborators are the first thing an auditor looks for.

Worked examples: accounting entries and tax calculations

The rules in the previous chapters are easier to understand with figures. Here we follow an imaginary cleaning business, built on proportions we often find in the sector’s accounts: €1,350,000 of revenue, forty employees, mostly part-time, under the CCNL Multiservizi, half of revenue from businesses under the reverse charge, a significant share from public bodies under split payment, a few condomini and a few households. First we record in double entry the transactions that distinguish it from any other service business: the four VAT treatments in its invoicing, the VAT credit that re-forms every year, payroll, the change of contractor, investments, the receivable from the public body that pays late, and contracts subject to Article 17-bis. Then we take the same profit and tax it under the possible legal forms, to see how much is really left for those who run the business.

References are to the rules in force in 2026. From 1 January 2027 the articles of Presidential Decree 633/1972 cited here are incorporated into the consolidated VAT Act (Legislative Decree 10/2026) and Article 17-bis of Legislative Decree 241/1997 into the consolidated Act on tax payments and collection (Legislative Decree 33/2025): the numbering changes, and the rules illustrated should be reread in those texts. In every entry total debits equal total credits; summary amounts are rounded to the nearest euro.

The model business and the starting assumptions

The business is based in Emilia-Romagna, ATECO code 81.21.00 (general non-specialised cleaning of buildings), and has been operating for more than three years. It keeps ordinary accounts, because its revenue has long exceeded the €500,000 limit for service businesses (Article 18 of Presidential Decree 600/1973). The owner, or the shareholders in the corporate forms, runs the business, looks after clients and organises the teams.

Labour costs are 62.6% of revenue; all the other costs together amount to 27.9%. Profit before taxes and before any remuneration of the owner or shareholders is €128,809, 9.5% of revenue. This is a healthy business, not an extreme case; yet one lost contract or one delay by a public body is enough to show how little room is left.

1. Four clients, four VAT treatments

The same service, cleaning an office, is invoiced in four different ways depending on who receives it. Towards a business or professional that is a taxable person, the reverse charge under point (a-ter) applies, which according to circular No. 14/E of 2015 covers activities under codes 81.21.00 and 81.22.02 relating to buildings: the invoice is without tax, with nature code N6.7, and the client adds the VAT. Towards a public body split payment applies: VAT is shown, but the body pays it over. The condominio is not a taxable person, so it pays ordinary VAT, but as a withholding agent it withholds 4% of the taxable amount. A private individual pays VAT at 22%.

Invoices a) and b) go in the sales register but carry no tax into the VAT settlement; b) has chargeability code ‘S’. Invoices c) and d) do. The most common risk lies in choosing between a) and c): the reverse charge does not apply to a condominio, to a private individual or to cleaning of plant and machinery, which is not ‘relating to buildings’. An invoice issued without VAT to a condominio is a taxable supply that has not been invoiced, with the tax payable by the issuer. As for split payment, it has been extended by the Council of the European Union until 30 June 2029 (Implementing Decision 2026/1728); since 1 July 2025 companies listed on the FTSE MIB index have been removed from it (Article 10 of Decree-Law 84/2025), and therefore receive ordinary invoices or, where the conditions are met, reverse-charge invoices.

2. The monthly settlement and the VAT credit that re-forms every year

On 81% of revenue (€1,100,000 out of €1,350,000) the business collects no VAT: €151,800 is left with the client under the reverse charge, and €90,200 is paid over by the public body. On purchases, on the other hand, it pays VAT in full to the supplier. So the year’s output VAT, €55,000 on the invoices to condomini and private individuals alone, is lower than the deductible VAT: €56,980 on running costs and €8,580 on the investments in point 5. The glazing subcontract, under the reverse charge on purchases, generates €8,800 of output VAT and the same amount of input VAT, and is neutral.

Take March, the month in which the van and the scrubber-dryer are bought.

With the credits for January (€350) and February (€250), the first quarter closes with a credit of €9,334. There are three ways to recover it.

The first is the quarterly refund (Article 38-bis(2) of Presidential Decree 633/1972), with form TR to be filed by 30 April: it is allowed because the credit exceeds €2,582.28 and because the business is in the situation in Article 30(3)(a), that is, it makes supplies at an average rate lower than the rate on purchases. The provision expressly states that in the calculation reverse-charge and split-payment supplies count as supplies without tax.

Over the year, the average rate on sales is 4.07% (55,000 out of 1,350,000), which increased by 10% becomes 4.48%; the rate on purchases, excluding depreciable assets, is 22%. The condition is met by a wide margin, and will be every year. Below €30,000 the refund requires neither a compliance endorsement nor a guarantee. For the part of the credit attributable to split-payment supplies and to reverse-charge services under point (a-ter) the refund is given priority (Article 8 of the Ministerial Decree of 23 January 2015; Ministerial Decree of 29 April 2016), subject to the requirements of the Ministerial Decree of 22 March 2007.

The second is set-off in the F24. Up to €5,000 a year it is unrestricted; above that, the quarterly credit requires the compliance endorsement on form TR and can be used from the tenth day after it is filed, and the annual credit requires the endorsement on the return and can be used from the tenth day after the return is filed. Set-off is in any case barred if the business has amounts over €50,000 entrusted to the collection agent that are overdue and not suspended (Article 37(49-quinquies) of Decree-Law 223/2006, introduced by Law 213/2023; threshold reduced from €100,000 to €50,000 from 2026 by Law 199/2025).

The third, deferring everything to the annual return, is the most costly, and it is what happens by default when nobody plans ahead.

For the year the total credit is €10,560: after the first-quarter refund €1,226 remains, which is carried forward. Article 30(3)(e), sometimes cited in such cases, does not concern a cleaning business: it refers to the non-resident persons in Article 17(3). The other route to an annual refund, in Article 30(4), applies when the credit has arisen in three consecutive years, and is limited to the lowest of the three amounts.

3. A month’s payroll for forty employees

Pay figures are assumptions. The CCNL Multiservizi was renewed in 2025 with stepped increases up to 2029, but the sources we consulted do not agree on the table rates after the October 2026 instalment: for level 2 full-time we use monthly pay of €1,400, to be replaced with the figure from the tables in force. Also assumptions are the INPS rates borne by the employer (30%) and by the employee (9.19%), which depend on the business’s classification and size, the average INAIL rate (1.8%), which depends on the business’s INAIL registration, and the amount of the supplements for night and public holiday work. The CCNL provides for fourteen monthly payments.

The cleaner is paid for 1,404 hours a year (27 × 52); after holidays, public holidays, paid time off and absences, he or she works about 1,193. The cost per hour actually worked is therefore about €16.44: this is the figure every quote starts from, and the one clients do not see when they compare bids.

In a month without additional monthly payments, the forty employees’ earnings are €43,237 (€34,020 of cleaners’ table pay, €6,900 for team leaders and office staff, €2,317 of supplements). The thirteenth and fourteenth monthly payments accrue each month at one twelfth each, €6,820, and are provided for with the related contributions. IRPEF withholding is as calculated by the payroll software (here €2,400); for many part-time cleaners, with income of around €14,000, the withholding agent advances more on the payslip than it withholds, between the trattamento integrativo (supplementary payment to low-income employees) and the amount for the reduction of the tax wedge (Article 1(4) of Law 207/2024): in the example €4,300.

The month’s cost is €70,433, which multiplied by twelve gives the annual cost in the table, apart from rounding. Net pay is higher than earnings less contributions and withholding precisely because of the amounts advanced. On 16 April the F24 form carries €16,944 of contributions and €2,400 of withholding tax, and the amounts advanced are recovered by set-off using the relevant tax code (1655 for the trattamento integrativo): in the absence of the Article 17-bis constraints the net payment is €15,044. At 31 December the entry for accrued and untaken holiday and paid time off is added: with 1,100 hours outstanding at €8.09 (1,400 / 173), this comes to €8,899 of pay and €2,670 of contributions, recorded as liabilities.

With fewer than fifty employees, TFR stays in the business for those who do not join a supplementary pension scheme and is paid to the fund for those who do; from fifty upwards the share of those who do not join goes to the INPS Treasury Fund. Retained TFR is a source of finance that should be seen in the cash flow statement, together with the liability it represents in a change of contractor (point 4).

4. The change of contractor: winning and losing a contract

In May the business wins the tender for cleaning the offices of a consortium. Ten part-time cleaners transfer from the outgoing business under the social clause (Article 57 of Legislative Decree 36/2023 in public contracts, the CCNL rules on changes of contractor in other cases). This is not a transfer of a business: the taking on of staff by a contractor with its own organisation, where there are elements of discontinuity, does not fall within Article 2112 of the Civil Code (Article 29(3) of Legislative Decree 276/2003). The relationship with the outgoing contractor ends, and a new relationship begins with the incoming one.

In the ordinary case the outgoing business pays the workers their accrued TFR, accrued thirteenth and fourteenth monthly pay and untaken holiday. The incoming business takes over nothing from that past: it hires the ten workers and from then on accrues its own costs. It must, however, allow for start-up costs, which the tender price often overlooks: medical examinations (10 × 60 = €600), safety training (€1,200), uniforms and PPE (€800). These come to €2,600, costs for the year.

The parties may agree otherwise: with the workers’ consent the contracts are assigned (Article 1406 of the Civil Code) and the incoming business assumes the accrued TFR, accrued additional monthly pay and holiday, receiving their equivalent value from the outgoing business. If the ten workers bring with them €22,000 of TFR, €3,800 of accrued monthly pay and €2,900 of holiday, the incoming business’s entry is as follows:

Without the equivalent value, the incoming business would be assuming someone else’s debt with nothing in return: a cost that is hard to justify as related to the business, which should be avoided or documented as the price of acquiring the contract.

In September, on the other hand, the business loses a school contract: eight cleaners transfer to the new contractor. The accrued TFR (€17,600), additional monthly pay (€4,160) and holiday (€2,400) are already recorded as liabilities, because they have accrued month by month; the payout produces no new costs, but it absorbs cash.

In the income statement the loss shows up in another way: the contract’s margin disappears, while the overheads remain, as does the equipment dedicated to that site, which must be redeployed or, if no longer needed, assessed for a write-down. The outgoing workers’ contributions on the accrued pay and holiday paid out are paid with the month of termination.

5. Scrubber-dryer, van and a separate job

In March the business buys a floor scrubber-dryer for €9,000 plus VAT and a van, type-approved as an N1 goods vehicle, for €30,000 plus VAT. The Ministerial Decree of 31 December 1988 has no category for building cleaning businesses: Group XXII covers personal hygiene services, municipal waste services and laundries, not cleaning. The item ‘Other activities’ for activities not previously specified must therefore be used, which provides 15% for sundry machinery, apparatus and equipment and 20% for goods vehicles. The 25% rate for ‘general equipment’ in personal services, which is sometimes seen applied to cleaning machines, has no secure basis. In the first year the rate is halved (Article 102(2) TUIR).

The van that carries teams and machines to sites is a goods vehicle and does not fall within the limits of Article 164 TUIR, which concern cars, motor caravans, motorcycles and mopeds: cost, depreciation and running costs are fully deductible, and the VAT is fully deductible. The limit comes back into play for vehicles registered as goods vehicles but with the characteristics of a car, which the Agenzia treats as cars, and for a vehicle left with the team leader for both business and private purposes. Registration document, actual use and refuelling must be consistent with one another.

In November a construction firm entrusts the business with the end-of-works cleaning of a block of flats for €18,000, under the reverse charge. The job is assessed separately, because mistaken quotes almost always arise here:

At 31 December 330 hours of the work have been performed and it has not yet been invoiced. The service, agreed as a single object and to be completed in less than a year, is valued on the basis of the costs incurred (Article 92(6) TUIR): €5,425 of labour, €800 of materials, €1,800 of hire and €400 of travel. The entry is Work in progress on services, debited, against Change in inventories, credited, for €8,425; the revenue is recognised in 2027, on completion (point (b) of Article 109(2) TUIR).

6. The receivable from the public body that pays late

In June a municipality receives an invoice for €20,000 plus €4,400 of VAT under split payment, due at thirty days (Article 4 of Legislative Decree 231/2002; sixty for bodies of the National Health Service). It pays 120 days late, all in the second half of the year. For commercial transactions with public authorities, default interest is that under Legislative Decree 231/2002: the ECB reference rate for the half-year, 2.40% from 1 July 2026, plus eight points, i.e. 10.40% (Ministry of Economy and Finance notice, Official Gazette No. 163 of 16 July 2026). A flat amount of €40 is also due for recovery costs (Article 6(2)).

Interest is calculated on the taxable amount, because under split payment the VAT is not owed to the supplier: 20,000 × 10.40% × 120/365 = €683.84.

Interest is excluded from the VAT taxable amount (Article 15(1), point 1, of Presidential Decree 633/1972) and does not enter the IRAP base. For income tax purposes it is included in income in the year in which it is received (Article 109(7) TUIR). If it is recognised in the financial statements on an accrual basis, because receipt is reasonably certain, a downward adjustment is made in the year it accrues and an upward adjustment in the year of receipt; if, as more often happens with public bodies, it is recognised only when paid, financial statements and tax return coincide.

7. Article 17-bis contracts: what changes in the accounts and the payment forms

A food manufacturer entrusts the business with cleaning its plants for €260,000 a year. The service is performed with a predominant use of labour at the client’s premises; it remains to be checked whether the requirement of capital goods owned by or attributable to the client is met, which in cleaning, where the business often uses its own machines but on the client’s premises and with the client’s utilities, must be documented contract by contract. If the conditions are met, Article 17-bis of Legislative Decree 241/1997 applies, and there are four consequences.

• The withholding tax of the workers employed on the contract is paid with a separate F24 form for that client, without set-off against the business’s own credits (paragraph 1). Circular No. 1/E of 2020 allows the use of credits accrued as withholding agent, such as amounts advanced on the payslip, up to the amount of the withholding tax.
• Within five working days of the due date the business sends the client the payment forms and the list of workers, with the hours worked on the contract, and each worker’s pay and withholding tax (paragraph 2).
• If the documentation is missing or does not add up, the client suspends payments up to 20% of the value of the service or up to the amount of unpaid withholding tax (paragraph 3).
• For the contributions and insurance premiums of the workers on the contract, set-off is excluded (paragraph 8).

In accounting terms this means that payroll must be kept by cost centre: each worker with the hours attributed to each client. If in the month 40% of the business’s hours were worked in that plant, of the €2,400 of withholding tax €960 goes in the client’s payment form and €1,440 in the ordinary one; contributions for the workers employed there are paid without setting off the VAT credit. Here points 2 and 7 connect: a business with a structural VAT credit and many contracts under the 17-bis regime cannot use it up in the F24, and the refund becomes the only way.

The obligations do not apply if the business provides the certificate that the requirements are met, the DURF (paragraph 5): at least three years in business, compliance with filing obligations, payments into the tax account over the last three years of not less than 10% of revenue, and no debt over €50,000 entrusted to the collection agent. Each year the model business pays about €235,000 of INPS contributions (employer and employees), €10,800 of INAIL premiums and the withholding tax: we are at about 20% of revenue, counting payments before set-off. In addition, under resolution No. 53/E of 22 September 2020, the count also includes the VAT on split-payment and reverse-charge supplies, which the business does not pay over: a further €242,000. The requirement is met by a wide margin. The certificate is valid for four months and must be renewed without gaps.

8. Taxes on the same profit under the possible forms

We compare the same profit of €128,809, before taxes and before remuneration of those who run the business, under five structures: sole proprietorship; snc with two partners at 50%; srl with the same two shareholders, as directors receiving a fee; production and labour cooperative; flat-rate regime, only to show why it is not workable. The rates and parameters are as follows.

• IRPEF 2026: 23% up to €28,000, 33% up to €50,000, 43% above (Article 1(3) of Law 199/2025).
• Emilia-Romagna regional surcharge 2026: 1.33% up to €15,000, 1.93% up to €28,000, 2.78% up to €50,000, 3.33% above (L.R. (regional law) 1/2025). Municipal surcharge at 0.8%, as an assumption.
• IRAP: 4.20% (see the box below). Individuals carrying on a business have not paid it since 2022 (Article 1(8) of Law 234/2021).
• 2026 contributions to the Gestione artigiani and Gestione commercianti (the INPS schemes for artisans and traders) (INPS circular No. 14 of 9 February 2026): minimum income €18,808; rate of 24% for artisans and 24.48% for traders up to €56,224, one point more above; ceiling of €122,295 for those registered since 1996 (€93,707 for the others); minimum contribution of €4,521.36 for artisans and €4,611.64 for traders.
• IRES: 24%. The reduced rate under Law 207/2024 concerned the 2025 period and does not appear to have been renewed for 2026.
• Gestione separata (INPS separate scheme) 2026 for a director already registered with another compulsory scheme: 24% of the fee, two thirds borne by the company and one third by the director (INPS circular No. 8 of 3 February 2026).

We do not consider dependants, other income or deductible expenses other than contributions. The deduction of IRAP from income taxes is calculated on the year’s tax, whereas the law allows it on a cash basis.

8.1 Sole proprietorship

The owner does not pay IRAP and has no tax credit by type of income: the one in Article 13(5) TUIR is available for business income under simplified accounting (Article 66), not under ordinary accounting. Business income of €128,809 exceeds the contribution ceiling. As an artisan the owner would pay €30,019 of contributions (56,224 × 24% plus 66,071 × 25% plus €7.44 for maternity), and on taxable income of €98,790, €34,680 of IRPEF, €2,687 of regional surcharge and €790 of municipal surcharge. The total burden is €68,176 and €60,633 is left. The marginal rate, including IRPEF and surcharges, is 47.13%. The tax withheld by condomini (€6,400) is a payment on account and does not change the calculation.

The calculation, however, assumes that the business is an artisan business, and ours is not. Article 4 of Law 443/1985 sets for a business not producing in series a maximum of 18 employees, which can rise to 22 with apprentices; under the general rule in Article 9 of Legislative Decree 81/2015 part-timers are counted in proportion to their hours, and the model business’s forty employees are equivalent to about 28 full-time units (36 × 0.675 + 4). Once the limit is exceeded, the owner of a non-artisan service business registers with the Gestione commercianti: €30,606 of contributions, €34,427 of IRPEF, €2,667 and €786 of surcharges. The burden is €68,486 and €60,323 is left: €310 less, because the extra contributions are partly offset by their deductibility.

8.2 Snc with two partners

The income is attributed to the partners on a transparent basis (Article 5 TUIR), but the partnership pays IRAP. The base starts from the value of production, which does not deduct staff costs or interest; the cost of permanent employees is deductible in full, part-timers included (Article 11(4-octies) of Legislative Decree 446/1997). For fixed-term workers only the INAIL premiums are deductible (point 1 of Article 11(1)(a)). The standard deduction in paragraph 4-bis, which for partnerships reaches €13,000, is available in full only with a base not exceeding €180,759.91 and disappears above €180,999.91: here it is not available.

€4,178 of IRAP is deducted from income: €925 for the 10% standard deduction, which is available because interest expense contributes to the base (Article 6 of Decree-Law 185/2008), and €3,253 for the analytical deduction of the tax attributable to staff costs not deducted, those of the four fixed-term cleaners (Article 2 of Decree-Law 201/2011). Income is €124,631, €62,315 per partner. Each partner pays €15,323 to the Gestione commercianti and, on taxable income of €46,992, pays €12,707 of IRPEF, €978 of regional surcharge and €376 of municipal surcharge. The total burden is €68,021, of which €9,251 is IRAP, and €60,788 is left: almost exactly as for the sole proprietorship, because the benefit of splitting income across two sets of brackets is absorbed by IRAP.

8.3 Srl with two shareholders

The two shareholders are directors, each receiving a fee of €35,000, and work in the business habitually and as their main occupation: they are registered with the Gestione commercianti and pay 24% of the fee to the Gestione separata, €16,800 in total, of which €11,200 is borne by the company. Fees and contributions are not deductible for IRAP purposes, which remains the same as for the snc.

The analytical IRAP deduction is higher than for the snc because the staff costs not deducted also include the directors’ fees and the related Gestione separata contributions (€158,663 in total). Interest expense is fully deductible, because it remains below 30% of gross operating profit (Article 96 TUIR).

Each shareholder has total income of €32,200 (€35,000 of fees less €2,800 of Gestione separata contributions) and taxable income of €27,588, after the traders’ minimum contribution of €4,612. Gross IRPEF is €6,345. The tax credit for income treated as employment income (Article 13(1) and (1.1) TUIR) is calculated on total income, which contributions to the Gestione commercianti, being deductible expenses, do not reduce: 1,910 × 17,800/22,000 = €1,545, plus €65 of increase for income between €25,000 and €35,000, €1,610 in all. Net IRPEF is €4,735; the surcharges are €442 regional and €221 municipal.

The total burden is €63,151: €9,251 of IRAP, €9,605 of IRES, €16,800 of Gestione separata, €9,223 of Gestione commercianti, €10,796 of IRPEF and surcharges, €7,476 of withholding tax on dividends. €65,658 is left. If the profit stays in the company, the withholding tax is deferred until distribution.

The traders’ contribution on the minimum income alone is a contentious point. INPS maintains that the base includes the share of the srl’s profit attributable to the shareholder even if not distributed; in several orders of 16 September 2026 (including No. 25377), the Labour Section of the Court of Cassation excluded the retained profits of an srl that had not opted for tax transparency. With the transparency option (Article 116 TUIR) the company’s income, €40,020, would be added to the shareholders’ fees in the 33% bracket and would reduce their tax credit: at this level it is not worthwhile. Profits from transparency years, when distributed, are not subject to the 26% withholding tax and are reported in form 770, section SK.

8.4 Production and labour cooperative

A cooperative is not just another guise for the same entrepreneur, and the comparison should be read with this caveat. It has predominantly mutual status if the labour cost of its members exceeds 50% of its total labour cost (Article 2513 of the Civil Code): at least half of the workers must therefore be members. Profits are not distributed except within the limits of Article 2514 of the Civil Code; 30% goes to the legal reserve, 3% to the mutual funds, and the rest as a rule to indivisible reserves, which do not return to the members even on winding-up. The mutual benefit is passed on to members through pay and ristorni, deductible for the cooperative (Article 12 of Presidential Decree 601/1973) up to 30% of total pay (point (b) of Article 3(2) of Law 142/2001).

Suppose the two founders are worker-members with a permanent employment relationship and pay of €38,000 each, costing the cooperative €52,899 each (contributions, INAIL and TFR included). Profit falls to €23,011. For IRAP their pay is deducted like that of the other permanent employees: the base is €114,474, below the threshold, and the standard deduction of €8,000 is available, without the increase reserved for partnerships; IRAP is €4,472.

For IRES, a cooperative with predominantly mutual status excludes from income the profits allocated to indivisible reserves, except for 40% of net profit (point (b) of Article 1(460) of Law 311/2004) and 10% of the share allocated to the minimum compulsory reserve (Article 6 of Decree-Law 63/2002); it deducts the amounts paid to the mutual funds. If the members’ pay is not less than 50% of other costs, excluding raw materials, the exemption in Article 11 of Presidential Decree 601/1973 remains, but only for the income deriving from the non-deductibility of IRAP (paragraph 462). With four out of five workers as members the ratio is well above the threshold. In a simplified scheme, on the profit of €18,539 after IRAP, €7,416 is taxed (40% of profit, plus 10% of the legal reserve of €5,562, less the €556 for the mutual funds) and IRES is €1,780.

Each founding member has employment income of €34,508 after the contributions he or she bears. Gross IRPEF is €8,588; the tax credit under Article 13 is €1,410 (1,345 plus 65); the further tax credit for employees with income between €32,000 and €40,000 (Article 1(6) of Law 207/2024) is also available, here €687. Net IRPEF is €6,491, and the surcharges €631 and €276.

The total burden is €52,201: €4,472 of IRAP, €1,780 of IRES, €31,152 of INPS and INAIL contributions on the two members’ pay, €14,797 of IRPEF and surcharges. The two members are left with €59,848, of which €5,630 is TFR accruing in the business; €16,203 goes to indivisible reserves and €556 to the mutual funds: these increase the cooperative’s assets, not those of the members.

8.5 The flat-rate regime: why it is not workable

The flat-rate regime is closed to those with revenue above €85,000 (with immediate exit above €100,000) and to those who incur expenditure on employees and collaborators above €20,000 gross (Article 1(54), (57) and (71) of Law 190/2014). A single part-time cleaner on 27 hours, in point 3, costs €19,617: with the second the regime is lost. The flat-rate regime remains for those who work alone. An artisan cleaner with no employees, €60,000 of revenue and the 67% profitability coefficient for division 81, has income of €40,200; he or she pays €9,655 of artisan contributions (€6,276 with the 35% reduction, which also reduces the pension) and a 15% substitute tax on €30,545, i.e. €4,582, or 5% in the first five years of a new business that meets the requirements. No VAT is applied, not even under the reverse charge: for condomini and households, which cannot deduct it, the price is lower for the same fee.

8.6 The comparison

At this level of profit the srl is the lightest form: directors’ fees stay in the low brackets, and the profit pays 24% IRES and 26% only when distributed. The sole proprietorship and the snc are equivalent, because what the snc gains by splitting income it pays in IRAP. The cooperative has the lowest burden, but leaves the founders only their pay and keeps the rest in indivisible assets: it is chosen for a mutual project, not to pay less tax.

The comparison shifts with the figures. In the sole proprietorship every euro of taxable income above €50,000 pays 47.13% in IRPEF and surcharges, plus contributions up to the ceiling; in the srl retained profit pays 24% plus IRAP, and for a business that has to finance working capital towards public bodies, the TFR for the next change of contractor or a fleet of vehicles, retained profit taxed at 24% weighs much less than profit taxed at 47% in the sole proprietorship. In the other direction, IRAP weighs on the snc and the srl and not on the sole proprietorship, and it grows with fixed-term workers. The choice should be made on real figures, over several years, and together with the questions that tax does not answer: who must be able to join the company, how the business takes part in tenders, what happens if it loses its main contract.

Note on the examples

The examples are simplified. CCNL Multiservizi pay, INPS and INAIL rates, withholding tax and amounts advanced on the payslip are assumptions, to be replaced with data from the payroll software and the business’s INAIL registration. We do not consider dependants and other income, the actual municipal surcharge rate, the 0.50% contribution that reduces the TFR accrual, the deductibility of IRAP on a cash basis, payments on account, deferred taxes, the additional contribution on fixed-term contracts or the contribution treatment of ristorni. The cooperative’s IRES calculation follows a simplified scheme. The legal form, the organisation of employment contracts and the strategy on the VAT credit should be decided on the data of the individual business, with a multi-year simulation.

Public and private contracts

A labour-intensive service

For many businesses public contracts are the most stable part of revenue: schools, municipal offices, health authorities, barracks. The public procurement code (Legislative Decree No. 36 of 31 March 2023, amended by the corrective Legislative Decree No. 209 of 31 December 2024) treats cleaning as a labour-intensive service, in which staff costs are at least half the value of the contract (point (e) of Article 2(1) of Annex I.1). It follows that the award criterion is the most economically advantageous tender on the basis of the best price-quality ratio (point (a) of Article 108(2)), with the lowest-price criterion excluded even below the EU thresholds (Article 108(3); Article 50(4)) and a price score of no more than 30% (Article 108(4)).

A cleaning tender awarded on the maximum discount, or with 40 points for price, should be challenged immediately: clauses that prevent a meaningful bid are challenged within thirty days of publication, not after losing. Paragraph 7 requires points to be awarded for gender equality certification, an investment that, in a sector where most workers are women, benefits the organisation of work first and also earns points in tenders.

Labour costs and safety costs

The contracting authority states the labour costs, calculated on the Ministry tables, and separates them, together with safety costs, from the amount subject to the discount, without prejudice to the bidder’s ability to show that the overall discount derives from more efficient business organisation (Article 41(13) and (14)). In its financial bid the bidder must state, on pain of exclusion, its own labour costs and its own internal safety costs (Article 108(9)): forgetting the item, or entering it in the wrong field of the e-procurement platform, means exclusion, and according to the prevailing view it cannot be remedied through the procedure for supplementing documentation (soccorso istruttorio).

The courts were divided for two years on whether these costs can be discounted. Section V of the Council of State has now settled on a consistent line (among others, judgments No. 5712, No. 7813 of 7 October 2025, No. 8225 and No. 9577 of 2025): stating them separately serves transparency and control, but does not remove labour costs from the discount. Unless the tender rules provide otherwise, the discount applies to the total amount; a bid that reduces these costs is not excluded for that reason alone, but the reduction must be justified in the abnormally low tender check, by showing a more efficient organisation and without going below minimum wages. The correct formula is not ‘not subject to discount’ but ‘separated and subject to discount only with justification’; safety costs relating to interference risks, on the other hand, remain fixed. A bidder offering fewer hours than the specification must arrive at the check with a credible work plan, made up of square metres per hour, frequencies, machines and shifts, and must always read the tender rules (disciplinare) of the individual tender.

The collective agreement and equivalent protection

Article 11 of the code requires staff to be covered by the comparatively most representative agreement closely connected with the subject matter of the contract, as stated in the contract notice. The business may apply another agreement guaranteeing the same protection, by submitting a declaration of equivalence with its bid (Article 5 of Annex I.01); the notice cannot make an agreement a condition of participation (Article 2(4) of Annex I.01). If services other than cleaning, such as grounds maintenance or portering, account for at least 30%, the notice also states the agreement for those staff (Article 11(2-bis)). Equivalence is measured on the fixed components of total annual pay and on sixteen regulatory parameters, including additional hours and part-time, probation, notice, protected sick-leave period, sickness, maternity, bilateral bodies, supplementary pension and health cover (Article 4 of Annex I.01): it is recognised if the economic value is at least equal and the regulatory differences are marginal. In a part-time sector, clauses on additional hours carry more weight than elsewhere, and an agreement with reduced supplements is unlikely to pass the check.

The social clause in tenders

Article 57 requires social clauses for the employment stability of the staff employed, to be applied in a manner compatible with the business’s organisation and with the needs of the new contract, according to a principle that ANAC guidelines No. 13 of 2019 had laid down and that the case law has maintained. It is not an automatic obligation to take everyone on again at the same hours, but the bid must show how the staff will be absorbed, and the re-absorption plan becomes a contractual commitment whose breach is a breach of contract. A plan that is inconsistent with the labour cost figures is one of the most common reasons for exclusion or for an abnormally low tender check.

Price revision

Price revision clauses are mandatory (Article 60). For services, following the corrective decree, they are triggered when the change in cost exceeds 5% of the total amount and they grant 80% of the excess, measured also by the ISTAT (National Institute of Statistics) index of contractual hourly wages (Article 60(2) and (3) and Annex II.2-bis). With the Multiservizi increases phased up to 2029 this is the main defence of the margin: it must be calculated and requested in writing, including for extension periods, because the contracting authority rarely grants it on its own initiative. The same clauses must be included in subcontracts (Article 119(2-bis)).

Subcontracting, reliance on another business’s band and consortia

In labour-intensive contracts, entrusting the greater part of performance to third parties is void (Article 119(1)). The subcontractor must guarantee the same protection as the contractor (Article 11(5)) and be registered for cleaning, otherwise the offence in Article 6(3) of Law 82/1994 is committed. Tenders often require a minimum band: according to ANAC, registration for the activity is a requirement of professional suitability and cannot be lent, whereas the band expresses economic and financial capacity and can be obtained by relying on the capacities of another business (avvalimento) (resolution No. 567 of 6 December 2023; Article 104). For a young business this is the way into the public market, provided the avvalimento contract specifies the resources made available and these are actually used (Article 104(1) and (9)). Permanent consortia (point (d) of Article 65(2) and Article 67) work if there is a real common structure behind them; if they serve only to circulate requirements, checks will bring this to light.

Abnormally low tenders, exclusions and reputation

In the abnormally low tender check (Article 110) the business has at most fifteen days to justify its bid; justifications concerning mandatory minimum wages or safety costs are not allowed. The justifications that succeed are always the same: productivity by type of surface, actual hours net of absences and replacements, depreciation of machines, products meeting environmental criteria, a profit that may be modest but is positive, all drawn from the cost centre for the contract.

Grounds for non-automatic exclusion include serious breaches of safety and social obligations (point (a) of Article 95(1)) and serious professional misconduct (Article 98), which may arise from shortcomings in a previous contract that led to its termination (point (c) of Article 98(3)). A termination in a municipal contract can follow the business into subsequent tenders: complaints during performance should always be answered in writing and, if unfounded, taken to court. Serious contribution breaches, even if not final, can lead to exclusion unless paid or covered by a binding commitment before the bid deadline (Article 95(2)). The legality rating of the Italian Competition Authority (Article 5-ter of Decree-Law 1/2012) is given weight in many tenders and in access to credit; in Emilia-Romagna L.R. No. 18 of 28 October 2016 promotes legality protocols that regional tenders often refer to.

Minimum environmental criteria

The technical specifications and contract clauses of the minimum environmental criteria (CAM) are mandatory in all public contracts (Article 57(2)). For cleaning, the Decree of the Ministry of Ecological Transition of 29 January 2021 applies (Official Gazette No. 42 of 19 February 2021), in force since 19 June 2021, on cleaning and sanitisation services for buildings and premises for civil and healthcare use and on detergent products; as of today it does not appear to have been replaced. The decree in force on the date the tender is launched applies, and ancillary services from other sectors may require other decrees. The CAM also cover staff training, dosing systems, machines, waste and periodic reporting, the last of which is often neglected during performance and a source of contractual penalties.

Below threshold, rotation, extensions

Below €140,000, services may be awarded directly to operators with documented experience; up to the EU threshold the negotiated procedure with at least five operators is used (points (b) and (e) of Article 50(1)). The rotation principle (Article 49) prohibits two consecutive awards to the same contractor in the same sector; the outgoing contractor may be invited again only in justified cases, and the rule does not apply below €5,000 or if the market survey did not limit the number of invitees. ANAC criticised an award to a business linked by family and corporate ties to the outgoing operator (resolution No. 567/2023). A technical extension is allowed only for the time strictly needed for the new tender, at the same prices and on the same terms (Article 120(11)): for the outgoing contractor, repeated extensions after a contractual pay increase are a loss unless a revision is requested. In Emilia-Romagna many services for public bodies and health authorities go through the Intercent-ER framework agreements, in Lombardy through ARIA S.p.A.: small businesses should follow the territorial lots and the permitted sub-awards.

Guarantees, advance payment, direct payments

The tender guarantee is 2% of the value of the procedure, adjustable from 1% to 4% (Article 106); it is reduced by 30% with ISO 9001 certification or by 50% for micro, small and medium-sized enterprises, not cumulatively, by a further 10% for a digital surety and by up to another 20% for the certifications in Annex II.13 referred to in the notice. The reductions must be declared and documented in the bid. The 20% advance payment (anticipazione) (Article 125(1)) is also available for services, on each year of multi-year contracts, against a guarantee of the same amount: for a business that has to pay wages from the first month it is often useful. If the business does not dispute, within fifteen days, a request to pay wage arrears, the contracting authority pays the workers directly, deducting the amounts from the consideration (Article 11(6)).

When a tender is lost

When the award is notified, the platform makes the successful bid and the minutes available to bidders, and to the first five also each other’s bids (Article 36(1) and (2)). Decisions on redacted parts are challenged within ten days (paragraph 4), and an appeal against the award within thirty (Article 120 of the Code of Administrative Procedure). Studying the successful bidder’s justifications of labour costs, that is hours offered, levels, hourly cost and productivity, is almost always where a well-founded appeal starts, and it should be done in the first few days. ANAC’s pre-litigation opinion (Article 220) does not suspend the time limit.

Private contracts and the condominio

With private clients the contract is a service contract (Articles 1655 et seq. of the Civil Code), with the rules on supply contracts applying to recurring services (Article 1677). Many contracts amount to no more than a signed quote, and that is a mistake. A good contract describes areas, frequencies and performance standards, joint quality checks, proportionate penalty clauses (Article 1384 of the Civil Code), price revision on renewals of the collective agreement, which without a clause is left to Article 1664 of the Civil Code and is triggered only above one tenth of the price, the notice period for withdrawal, the indemnity under Article 1671 of the Civil Code if the client withdraws, and the VAT treatment of each service.

A client that is an employer checks the business’s technical and professional suitability and draws up the DUVRI (the single document assessing interference risks) (Article 26 of Legislative Decree 81/2008), except for services of up to five person-days a year without particular risks; these include high fire risk, confined spaces, asbestos, explosive atmospheres and carcinogenic, mutagenic, reprotoxic or biological agents, so occasional cleaning in a clinic or laboratory requires the DUVRI even if it lasts a day. Safety costs must be stated in the contract on pain of nullity and are not subject to discount (Article 26(5)), and this is the clause most often missing; each worker carries an identity card with a photograph and the employer’s name (paragraph 8).

In a condominio the contract is signed by the administrator: ordinary expenditure falls within the approved budget, but a new contractor or a multi-year contract should be expressly approved by resolution. The invoice carries ordinary VAT and the condominio withholds 4%; the administrator must check the business’s registration to avoid the penalty and the nullity under Article 6 of Law 82/1994. If several businesses work in the building at the same time, written coordination is prudent in any case.

Damage and insurance

Marble damaged by acid, swollen parquet, scratched glazing, flooding left by a scrubber-dryer, a visitor slipping on a wet floor: these are the typical claims. Towards the client the business is liable in contract, towards third parties for the acts of its staff (Article 2049 of the Civil Code) and for things in its custody (Article 2051 of the Civil Code), hence the importance of wet-floor signs and of being able to prove they were put out. The liability policy must be read for its exclusions: many exclude damage to things ‘in its care or custody’ or ‘on which the work is carried out’, which are precisely the most frequent, and others exclude keys, alarms or damage caused by chemicals. A policy that does not meet the limits required by a public client is a breach of contract and may justify revocation of the award.

Grey areas

Some questions do not yet have a settled answer. We set them out here with the solution that, in our view, carries the least risk for the business.

Issues already encountered

Three conflicts have been dealt with in previous chapters, and we simply recall them. On labour costs in tenders the Council of State has settled its case law: separated, but subject to discount with justification in the abnormally low tender check. On the use of the new ATECO codes for the reverse charge there is no clarification: look at the nature of the service as described in circular 14/E/2015. On clocking apps with geolocation, until the picture between the Garante and the first-instance courts becomes settled, it is advisable to limit recording to the moment of clocking in.

Sanitisation

No administrative guidance establishes whether sanitisation of buildings falls within the reverse charge. The prudent solution must be applied everywhere, in the bid, in the contract and on the invoice: sanitisation supplied as a separate service is invoiced with ordinary VAT, on a separate line and with its own price; cleaning with disinfectant products remains cleaning and is subject to the reverse charge. If the choice were challenged, the penalty under Article 6(9-bis.1) and (9-bis.2) of Legislative Decree 471/1997 would be fixed and limited, provided the tax has been paid. On the administrative side, sanitisation requires a technical manager, disinfection does not.

Enhanced deduction for new hires and the social clause

There is no clarification on counting staff hired under a social clause for the purposes of the 20% uplift. We count them only if the total workforce really grows, documenting the number of workers and the averages month by month. In the absence of guidance from the Agenzia, we do not carry over to this relief the exclusion that Article 31 of Legislative Decree 150/2015 provides for contribution incentives, but nor do we take the opposite for granted: where the amounts are significant, a ruling request (interpello) is advisable.

The worker absent at the change of contractor

First-instance case law recognises the right to be hired even for a worker who is temporarily unfit or on sick leave, if assigned to the contract; there is no settled view on how the protected sick-leave period is counted with the incoming contractor. The point should be settled in the handover minutes, with the trade unions.

The condominio as client

Two points remain open: whether the condominio is jointly liable under Article 29(2) of Legislative Decree 276/2003, given that paragraph 3-ter excludes only individuals not carrying on a business or profession, and whether it must draw up the DUVRI when it has no employees. The prudent course for the administrator is the same in both cases: check the business’s registration, DURC and compliance, and coordinate in writing the businesses working in the building.

Businesses that are members of ANIP

Since the Multiservizi renewal was not signed by ANIP-Confindustria, there is no public guidance on the terms applied by its member businesses. Until the situation is clarified, it is advisable to guarantee terms at least equivalent to those of the renewed agreement and to document them, because that is the benchmark that contracting authorities, the Ispettorato and the courts will use.

Resignation by conduct and maternity

It is not clear whether termination for unjustified absence during the protected period requires validation under Article 55 of Legislative Decree 151/2001. In a sector with many women workers, the prudent choice is not to use the procedure in that period without specific advice.

What to do

Before starting up or taking over a contract

1. Check the good character and financial capacity of everyone required to meet them, and the in-house technical manager if pest control, rodent control or sanitisation will be carried out.
2. File the SCIA through the Comunicazione Unica, notify local branches and choose the ATECO 2025 codes for each activity.
3. Choose the legal form taking account of the artisan limits, the flat-rate regime’s ceiling on staff expenditure and, for a cooperative, predominantly mutual status.
4. Choose the collective agreement and record its code consistently on UNILAV, UniEmens and payslips.
5. On taking over a contract: staff list and four months of workforce data, documented organisational discontinuity, no assumption of TFR or debts without a prior tax and employment law review.

For every new contract or tender

1. Check the client in the tax register: taxable person, body under split payment, condominio, non-commercial body, habitual exporter.
2. Draw up specification, bid and price list broken down by service, with the VAT treatment of each line and separate sanitisation shown apart.
3. Assess Article 17-bis and the validity of the DURF; open the cost centre for the contract.
4. In tenders: check the award criterion, the weight of price and the social clause within thirty days of publication; state labour costs and safety costs; prepare the re-absorption plan and justifications; declare the guarantee reductions.
5. In private contracts: DUVRI or coordination, safety costs, penalty clauses, price revision, keys and confidentiality, insurance policy checked for exclusions.
6. Before working on a construction site: points-based licence.

During the year

1. Every month: invoices with the correct VAT nature code; hours in the libro unico by site, travel included; DURC and F24 compliance; payment forms for clients subject to Article 17-bis; receipts from public bodies and default interest.
2. Every month, in payroll: contractual instalments from the official tables; part-time contracts realigned with hours worked on a continuous basis; substitute taxes with the income statements; schedule of residence permit expiry dates.
3. Every quarter: refund with form TR and request for priority payment; DURF expiry and the 10% percentage.
4. At every contract renewal: written request for price revision on every contract, including for extension periods.
5. During the year: DVR (risk assessment document), training under the 2025 Agreement, PPE and identity cards; average workforce for the Treasury Fund.
6. By December 2026: incentivised hires, after checking the net increase in employment and excluding those under a social clause.
7. At year end: staff accruals, TFR and Treasury Fund reconciled, stock on sites, risk provisions for changes of contractor, 0.50% retentions to be released, 4% withholdings reconciled, workforce count for the uplift on new hires, ISA simulation before closing.
8. To be kept for an audit: specifications and price lists broken down by service, average-rate workings, travel log, handover minutes, records of hours, checks on subcontractors.

What the firm does for cleaning businesses

In a cleaning business, accounts, payroll and contract rules cannot be separated. A badly drafted specification changes the VAT treatment of years of invoices; a carelessly documented takeover brings the outgoing contractor’s debts with it; a quarter of an hour of unrecorded travel, repeated every day across the whole workforce, becomes unpaid time for the staff and, later, an employment dispute.

We assist cleaning and multi-service businesses, whether artisan firms, companies or cooperatives, with accounting and VAT, with recovering the credit through refunds and set-off, and with financial statements and tax returns. We process payroll under the sector’s agreements, with shifts and part-time work across several sites, and we prepare changes of contractor from both the employment and the tax side. We read tender notices, specifications and contracts before they are signed, prepare with the business the justifications of labour costs and price revision requests, and assist in tax audits and inspections, with lawyers when needed.

We know that the owner is on site early in the morning and in the evening, and that the office is often a single person: we ask for documents only when they are really needed and we keep the schedule of DURC, DURF and certificate deadlines ourselves. The firm has offices in Codigoro, Ferrara and Milan.

This guide is for general information only and does not constitute professional advice on any specific case, which requires an examination of the documents and the specific facts. The content is up to date as at 16 October 2026; subsequent legislation, administrative practice and case law may alter its conclusions.

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