Tax Observatory › Employment and sport › Sports volunteers: the reimbursement is not income, but it eats into the €15,000 allowance

Sports volunteers: the reimbursement is not income, but it eats into the €15,000 allowance

Flat-rate reimbursements to sports volunteers, up to €400 a month, are not income, but they take up room within the €15,000 allowance for sports-work fees. Someone who only volunteers cannot exhaust it; someone who also earns fees from other bodies can, and then the excess is taxed — provided the self-declaration is there. Circular 7/E of 7 August 2026 explains how.

In circular no. 7/E of 7 August 2026 the Italian Revenue Agency answered seven questions on Legislative Decree no. 36 of 28 February 2021, bringing together, in guidance addressed to its own offices, positions that had so far rested on a single legal-advice reply. Two of those answers bear directly on amateur sports clubs and companies: the treatment of flat-rate reimbursements paid to volunteers, and the scope of the €15,000 allowance where the sports worker is engaged as an employee. The season starts again in September and contracts are being signed now: the arithmetic is better done in advance than after the event.

One point first, to dispose of needless alarm. Flat-rate reimbursements to volunteers are capped at €400 a month — that is, €4,800 a year. Someone who only volunteers cannot exhaust the €15,000 allowance on their own. The issue arises for those who, in the same year, combine volunteer reimbursements with sports-work fees from other bodies — the position of anyone working with more than one body in the same season. The reassurance, however, holds for the tax allowance alone. On the social security side the link is not to be found in tax practice, but in article 29(2), last sentence, of legislative decree 36/2021, which refers back to the limits of exclusion from the contribution base set by article 35(8-bis). The latter provides not an exemption but an annual allowance of €5,000 deducted from the contribution calculation base: the pension contribution rate, and the corresponding rate used to compute pension benefits, are applied to the part of the remuneration exceeding the first €5,000 per year. The rule concerns sports workers in the amateur area who are registered with the Gestione separata INPS — coordinated and continuous collaborators, and self-employed workers — and not employed sports work. Flat-rate reimbursements paid to a volunteer, although they do not form part of the recipient’s income, do count towards the exceeding of those limits and, once the limits are exceeded, form part of the social security contribution base; twelve full months of reimbursement, €4,800, remain below the allowance. Lastly, until 31 December 2027, contributions to that scheme are due within the limit of 50 per cent of the contribution base (article 35(8-ter)).

The €15,000 allowance operates on the tax base

Article 36(6), first sentence, of Legislative Decree 36/2021 provides that «fees for sports work in the amateur field do not form part of the tax base for tax purposes up to a total annual amount of €15,000.00». The Agency observes that the legislature tied the provision to the objective nature of the activity performed, without distinguishing by contractual form: since article 25(2) of the same decree allows sports work to be the subject of an employment relationship or of a self-employment relationship, including in the form of continuous and coordinated collaboration, the exclusion operates «upstream», whatever class of income the fee falls into.

It therefore applies to the athlete or the instructor engaged under a contract of employment as well. Any excess then follows the ordinary rules of the Income Tax Code for the class concerned: in employment, the rules on employment income. The conclusion follows the reply to legal-advice request no. 14 of 30 September 2025, which the circular itself cites.

The contractual form, however, is not at the parties’ disposal. Article 28(2) presumes — a rebuttable presumption — that, in the amateur field, sports work is the subject of continuous and coordinated collaboration where, in relation to the same principal, two conditions are met together: the duration of the services, while continuous in character, does not exceed twenty-four hours a week — excluding time spent taking part in sporting events — and the services are coordinated in technical and sporting terms in accordance with the rules of the national sports federations, the associated sports disciplines and the sports promotion bodies, including Paralympic ones. The risk therefore runs the opposite way to the one usually feared: employment is not the cautious choice, because where those conditions are met the presumed form is collaboration, and the reclassification actually alleged is rather that of a formal collaboration concealing a relationship that is in substance one of employment under article 2094 of the Civil Code. Where the classification is uncertain, the way to put it beyond doubt is certification of the contract (article 25(3) of Legislative Decree 36/2021 and article 78 of Legislative Decree no. 276 of 10 September 2003).

Reimbursements to volunteers are not income, but they take up the allowance

Article 29 of Legislative Decree 36/2021 allows sports bodies to draw on volunteers who give their time personally, spontaneously and free of charge, for purely amateur purposes. Subsection 2 states that those services are not remunerated in any way, not even by the beneficiary, and that volunteers may be granted flat-rate reimbursements for expenses incurred for activities carried out, including activities within their own municipality of residence, up to an overall limit of €400 a month, on the occasion of sporting events recognised by the national sports federations, the associated sports disciplines, the sports promotion bodies — including Paralympic ones —, CONI, CIP and Sport e salute S.p.a., provided that it is those same bodies that identify, by their own resolutions, the categories of expense and the volunteer activities for which the reimbursement is allowed.

The same subsection says two things in succession: «The reimbursements referred to in this subsection do not form part of the recipient’s income» and, immediately afterwards, that they «count towards exceeding the exemption limits laid down in article 35(8-bis), and form part of the base for social security contributions once that limit is exceeded, as well as towards the limits laid down in article 36(6)». The reimbursement is therefore not income, but it takes up room within the €15,000 allowance. The second half of that sentence, the social security half, is not dealt with in the circular: it follows directly from the statute. According to the circular, the €400 monthly limit applies to each volunteer individually, by reference to the sums received in the calendar year concerned, and reimbursements paid by more than one body in the same year count towards it.

The circular’s two examples: the excess is taxed, not the reimbursement

The circular builds the rule on two cases, and the difference between them is the whole substance of the matter.

Allowance already used up. A volunteer receives a monthly flat-rate reimbursement of €350 and declares to the paying body that other sports bodies have paid them €16,000 in sports fees under self-employment relationships. Because the allowance had already been used up before the payment, the whole €350 reimbursement forms part of the volunteer’s taxable income as self-employment income; the €1,000 already in excess remains taxable in their hands as well.

Allowance exceeded by that very payment. A volunteer receives €380 in reimbursement and declares that they have received €14,800 in self-employed sports fees from other bodies. The €380 is added to the fees already received: €15,180 in all. Only the €180 excess forms part of taxable income; up to €15,000 neither the other bodies nor the body paying the reimbursement apply withholding tax, provided — says the circular, extending the declaration requirement to volunteers as well — that they have received from the recipient, at the time of payment, the self-declaration under article 36(6-bis). What the basis for that declaration is, when the person making it is a volunteer, is a question we return to below.

Exceeding the allowance, then, does not make the whole reimbursement taxable: only the part in excess is taxable. The rule changes only where the allowance had already been used up before the payment.

Withholding tax: which one, when, with what consequences

There is not one withholding but three: it follows the relationship. On an excess paid under a self-employment relationship — the situation in the circular’s examples — the body applies the 20 per cent withholding on account under article 25 of Presidential Decree no. 600 of 29 September 1973, a provision which, as the circular itself notes, will be carried over, with effect from 1 January 2027, into article 38 of the consolidated act on tax payments and collection approved by Legislative Decree no. 33 of 24 March 2025, subject to any further postponement. On an excess paid to a continuous and coordinated collaborator, whose fees are assimilated to employment income under article 50(1)(c-bis) of the Income Tax Code, the withholding under article 24 of the same Presidential Decree 600/1973 applies instead; and on an excess paid under a contract of employment, article 23 applies, together with regional and municipal surcharges and the year-end adjustment. The point is not academic: in the amateur field the presumed form is precisely continuous and coordinated collaboration. In every case the withholding is paid over using form F24 by the 16th day of the month following payment, and is then reported in the Single Certification and in form 770.

One step deserves to be identified for what it is. The circular classifies the excess reimbursement as self-employment income even though there is no employment or self-employment relationship between the volunteer and the body paying it: article 29(1) of Legislative Decree 36/2021 requires the service to be free of charge, and article 25 of the same decree defines a sports worker as someone who acts for consideration. This is an administrative reading, consistent with the outcome the tax authority is seeking rather than with the test the circular itself sets out; and a circular is not a source of law: it binds neither the taxpayer nor the courts. As a matter of civil law, in any event, the tax classification does not alter the nature of the relationship: the reimbursement remains the reimbursement of expenses for a service given free of charge, and complying with the withholding obligation is not recognition of an employment relationship. Since that step nonetheless produces a Single Certification for self-employment income in the name of a person whose volunteer service article 29(3) declares incompatible with any self-employment relationship with the body, the resolution, the letter of appointment and the payment narrative should record the nature of the payment as a reimbursement and the basis on which the withholding was applied.

The self-declaration is not a formality: it is the condition of the exemption

No body can know what a person earns elsewhere. Article 36(6-bis) therefore places the burden of the declaration on the sports worker: at the time of payment — of every payment, not once a season — they issue a self-declaration stating the amount of the fees received for amateur sports services rendered in the calendar year. The circular attaches a precise consequence to it: the non-application of withholding tax up to €15,000 is conditional on the body having received that declaration. A body that pays without having received it cannot rely on the exemption.

For volunteers the position is different: a volunteer is not a sports worker and the obligation under subsection 6-bis does not apply to them, yet the circular’s examples assume that they declare to the paying body what they have received elsewhere. It is therefore advisable to obtain such a declaration in any event, in the form of a declaration in lieu of an affidavit under article 47 of Presidential Decree no. 445 of 28 December 2000 — noting that the duty to accept such declarations concerns dealings with public administrations and with public-service concessionaires, not a sports club — and above all to provide for it as a contractual obligation in the letter of appointment, with an undertaking to update it on each payment and an indemnity clause. It is that clause, not the form, that gives the body a basis for recovering the loss caused by a missing or untrue declaration: penalties, interest, the cost of regularising and of amending the Single Certification.

These are two distinct matters and it is worth keeping them apart. The right of recourse for the withholding is a different matter, and does not depend on any clause: a person obliged to pay tax in place of another «must exercise recourse unless otherwise expressly provided» (article 64, first paragraph, of Presidential Decree 600/1973), and article 25, first paragraph, of the same decree imposes the withholding «with an obligation of recourse». It is not an option: a body that forgoes recovering the withholding from the recipient takes a step that, in an association, may be held against its directors. What the circular does not address, by contrast, is the fate of an incomplete or untrue declaration: who answers for an excess that comes to light later is not stated.

To this must be added the duty, laid down by article 29(2), to report through the dedicated section of the national register of amateur sports activities the names of the volunteers receiving flat-rate reimbursements and the amount paid to each, by the end of the month following the quarter in which the services were performed. The same provision requires that report to be made immediately available, within their respective remits, to the National Labour Inspectorate, to INPS and to INAIL: it is data the body places in the hands of the supervisory authorities, and it needs to be consistent with the association’s books and the resolutions.

Two constraints that have nothing to do with tax

The first is insurance. Article 29(4) requires amateur bodies that draw on volunteers to insure them against third-party liability, referring to article 18(2) of Legislative Decree no. 117 of 3 July 2017. It is the duty whose breach exposes the body’s assets most directly: the volunteer is embedded in the body’s organisation and acts under its technical direction, so the body may answer for harm caused to third parties under article 2049 of the Civil Code, once the relationship of appointment and the requisite connection of necessary occasion between the duties entrusted and the harmful act have been established on the facts. A word on scope: the provision requires cover for third-party liability, not for injury to the volunteer, which is the most frequent claim in sport. A body that takes out accident cover believing it has complied has not complied; one that takes out liability cover alone remains exposed on the other front.

The second is the incompatibility in subsection 3 of the same article 29, which applies even to a volunteer who receives nothing: «Volunteer sports services are incompatible with any form of employment or self-employment relationship and with any other paid working relationship with the body of which the volunteer is a member or associate or through which they carry out their sporting activity». The prohibition is not conditional on a reimbursement and does not look at the content of the relationship, which may equally be administrative and managerial. On its scope the text admits two readings: the reading that confines the incompatibility to the body named in the provision is closer to its letter, but the question is unsettled and the circular does not address it.

Regional tax on productive activities (IRAP): €85,000 is a threshold, not an allowance

The second sentence of article 36(6) provides that all individual fees paid to continuous and coordinated collaborators in the amateur field below the annual amount of €85,000 do not form part of the tax base under articles 10 and 11 of Legislative Decree no. 446 of 15 December 1997. The Agency takes the view that the provision is not confined to sports workers in the strict sense: since article 37(4) brings administrative and managerial activity performed for amateur sports bodies within article 36(6) «whatever the type of relationship», fees for continuous and coordinated collaboration of an administrative or managerial nature also stay outside IRAP if they are below €85,000 a year.

Two warnings. First: unlike the €15,000 allowance, the €85,000 figure is not an allowance but a threshold applied to each individual fee — a fee that reaches or exceeds that amount forms part of the tax base in full, and not only in respect of the excess. Second: article 37(4) refers to the persons covered by subsection 1, which expressly excludes those who provide administrative and managerial services in the exercise of a profession for which registration in a professional register or roll is required. Fees paid to an accountant, a labour consultant or a lawyer for such work therefore do not benefit from the exclusion and form part of the tax base. A comparable exclusion for sports workers appears in the third sentence of article 25(1); administrative and managerial duties are in turn excluded from the definition of sports worker by the second sentence of that same subsection.

Social security is a separate account, and it is not symmetrical

Here the symmetry with the tax side breaks down, and overlooking that is the easiest mistake to make. The contribution allowance in article 35(8-bis) — the pension contribution rate is calculated on the part of the fee exceeding the first €5,000 a year — and the reduction in article 35(8-ter) — until 31 December 2027 contributions to the fund are due only on 50 per cent of the contribution base, with an equivalent reduction of the pensionable base — concern the rates «referred to in subsections 6, 7 and 8», that is, the workers covered by subsection 2: amateur-field workers engaged under a continuous and coordinated collaboration or on a self-employed basis, enrolled in the INPS separate scheme, at a pension contribution rate of 24 per cent for those already insured under other compulsory schemes and 25 per cent for those who are not, plus the additional rates applying to members of the separate scheme. By virtue of article 37(4), the same social security regime applies to administrative and managerial collaborators.

The employed sports worker, by contrast, is enrolled in the Sports Workers’ Pension Fund managed by INPS under subsection 1 of the same article 35, whether in the professional or the amateur field: for them neither the €5,000 allowance nor the 50 per cent reduction operates, and contributions are due under that fund’s own rules. Applying the allowance to them means under-declaring contributions. Flat-rate reimbursements to volunteers, for their part, count towards exceeding the limit in article 35(8-bis) and form part of the base for social security contributions once it is exceeded. Here too, however, the cross-reference is incomplete: article 35(8-bis) governs the rates for the workers covered by subsection 2, and the statute states the contribution effect without identifying either the scheme or the person liable to pay for a recipient who has no working relationship at all with the body making the payment. The provision presupposes that a separate-scheme relationship already exists for that person; beyond that, the point awaits guidance.

A note on VAT

The circular also deals with a point worth flagging: services closely linked to the practice of sport, including teaching and training services, supplied by non-profit organisations to persons taking part in sport or physical education, are exempt from VAT under article 36-bis(1) of Decree-Law no. 75 of 22 June 2023. The Agency takes the view that those making such supplies may rely on the dispensation from invoicing and recording duties under article 36-bis of the VAT decree — a different provision that happens to carry the same number — after notifying the tax office, while ordinary duties remain for any other taxable transactions carried out. The dispensation, though, has a price which the second paragraph of that same article states plainly: a person who relies on it may not deduct input tax on purchases and imports, and must still file the annual return, completing the list of suppliers. The notification is given in the annual return for the previous year or in the return declaring the start of business, is binding for at least three years and has effect until revoked. It is not a cost-free simplification: it is a waiver, and the input tax at stake has to be weighed against the paperwork saved.

In practice

Before the season opens: obtain, on each payment, the self-declaration under article 36(6-bis) from every sports worker, remembering that without it the withholding exemption does not operate, and provide by contract for an equivalent declaration from reimbursed volunteers; check that the body which recognised the event — federation, associated discipline, promotion body, CONI, CIP or Sport e salute S.p.a., and it does not always coincide with the affiliating body — has passed a resolution identifying the categories of expense and the activities eligible for reimbursement; make sure third-party liability cover for volunteers is in place.

Then, on day-to-day management: keep a single running total per person covering both fees and reimbursements, bearing in mind that the €15,000 tax allowance looks at everything the person has received during the year, whereas the duty to pay contributions rests with each principal for what it pays and follows the social security scheme of the individual relationship — though this does not multiply the allowance, because the €5,000 in article 35(8-bis) is annual and attaches to the person, and is to be managed, like the tax allowance, on the basis of the recipient’s own declaration; apply withholding tax to the excess alone, under article 25 of Presidential Decree 600/1973 for self-employment relationships, under article 24 for continuous and coordinated collaborations and under article 23, with surcharges and year-end adjustment, for employment relationships; send the national register the details of reimbursed volunteers by the end of the month following the quarter; and do not allow volunteer service and a working relationship to coexist for the same person with the body of which they are a member or associate or through which they carry out their sporting activity.

That leaves the past. The circular contains no saving clause and no guidance on conduct before 7 August 2026: anyone who has omitted withholding tax actually due during the year can regularise the position through voluntary correction and amend the Single Certification, assessing each case on its own facts. For the wider picture see our guide to amateur sports work; on employer duties generally, the guide to the cost of labour.

Frequently asked questions

Should someone who only volunteers be concerned?

For tax purposes, no: the €400 monthly cap comes to €4,800 a year, and on its own the reimbursement cannot exhaust the €15,000 allowance. The question concerns those who combine volunteer reimbursements with sports fees from other bodies. Social security is another matter: there the relevant threshold under article 35(8-bis) is €5,000, which twelve full months of reimbursements all but reach.

Once the allowance is used up, is the whole reimbursement taxable?

Only if the allowance had already been used up before the payment. If it is that payment which exceeds it, only the excess forms part of income: in the circular’s example, €180 out of a €380 reimbursement.

Does the €15,000 allowance also apply to an instructor engaged as an employee?

Yes, for tax purposes: the exclusion operates on the determination of the tax base whatever the class of income, and the excess is taxed under the rules on employment income. For social security purposes, by contrast, the €5,000 allowance does not apply to them.