Software tax credit in Italy 2026: what is left and what ended

The 4.0 tax credit on intangible capital goods, the 15% on Annex B that for years paid for a slice of every new management system, has been repealed: the last usable window closed on 30 June 2025. The technological innovation credit, the 5% that covered software projects which counted as new but carried no research content, stopped with the tax period under way on 31 December 2025, and the 2026 budget law did not extend it. The Transizione 5.0 plan, Italy’s green-and-digital investment scheme, declared its funds exhausted on 6 November 2025.

Three channels closed in eighteen months. Anyone searching today for an Italian software tax credit lands on guides last updated in 2024, because nobody rewrites an article that keeps bringing traffic, and ends up deciding on spend against measures that no longer exist.

What sits in their place works differently, and the difference matters more than the rates. The relief is not a refund: it is a deduction. The iperammortamento, the enhanced depreciation regime introduced by article 1, paragraphs 427 to 436 of Law 199/2025, raises the deductible cost instead of generating a credit to be offset through an F24 payment form.

The part almost nobody has opened sits in Annex V to that law. Among the eligible intangible assets appear, written exactly like this in the text published in the Gazzetta Ufficiale, Large Language Models, Agentic AI systems, MLOps platforms, process mining, and low-code and no-code platforms. Before 2026 no list of eligible assets in Italian tax law had ever named AI agents.

TL;DR

• Closed: the 4.0 intangible assets credit under Annex B (last eligible investment 30 June 2025), the technological innovation credit (up to the tax period under way on 31 December 2025, not extended), and Transizione 5.0 (funds exhausted as of 6 November 2025).
• Closing: the 4.0 capital goods credit under Annex A, with investments to be completed by 30 June 2026 and the completion notice filed by 15 September 2026 (MIMIT directorial decree of 31 July 2026).
• Iperammortamento 2026-2028: an uplift of the cost for depreciation and lease instalment purposes only, 180% up to 2.5 million euros, 100% up to 10 million, 50% up to 20. Investments from 1 January 2026 to 30 September 2028, restricted to business income earners.
• Research and development credit: 10%, capped at 5 million euros a year, running to the tax period under way on 31 December 2031, offset through F24 in three annual instalments.
• Design credit: reopened for 2026 only at 10%, annual cap of 2 million euros, a 60 million euro pot while funds last, MIMIT platform open since 7 July 2026.
• MIMIT Voucher Cloud & Cybersecurity: a 50% grant up to 20,000 euros, budget of 150 million euros of which 71 million reserved for the South. Pre-loading from 20 October 2026, applications from 10 November 2026 to 20 January 2027, suppliers only from the ministerial list.
• Annex V names: LLMs for generating content, technical documentation and code, Agentic AI, MLOps and process mining under letter dd); low-code and no-code under gg); cybersecurity under u); supply chain including drop-shipping e-commerce under z); MES, SCADA and CMMS under d).
• The sequence counts as much as the content: an advance notice to the GSE before the investment, confirmation within 60 days with at least 20% of the cost paid, completion by 15 November 2028 with a sworn technical appraisal and an accounting certification.

What ended, and the exact date it ended

The three closures have different causes, and confusing them leads to the wrong conclusions.

The 4.0 intangible assets credit (Annex B to Law 232/2016, the historic list of eligible software) was repealed by the 2025 budget law: the last usable window was 30 June 2025, and only for assets booked by 31 December 2024 with a 20% deposit paid.

The technological innovation credit covered most software projects that qualified as new without qualifying as research: 5% with a cap of 2 million euros, 4 million in the 4.0 and green variants, up to the tax period under way on 31 December 2025. In the text of Law 199/2025 the only amendment to Law 160/2019 on research, innovation and design concerns design: of any extension there is no trace.

The Transizione 5.0 plan ran through its budget and the directorial decree of 6 November 2025 certified the fact. What survives is the tail set out in article 8 of Decree-Law 38/2026, which grants for 2026 a contribution equal to 89.77% of the credit claimed in the applications left without cover, within a spending limit of 1,302.3 million euros and usable as an F24 offset by 31 December 2026. The original text of DL 38 spoke of 35% and 537 million euros: anyone still quoting those figures is reading a version superseded by DL 42/2026.

15 September 2026, for the Annex A capital goods credit

The credit on Annex A tangible assets is still alive for investments completed by 30 June 2026, with the order accepted and a 20% deposit paid by 31 December 2025, at rates of 20% up to 2.5 million euros, 10% up to 10 million and 5% up to 20, inside a national pot of 2.2 billion euros.

The completion notice has to be filed by 15 September 2026, the day after this article goes out. The deadline comes from the MIMIT directorial decree of 31 July 2026, which extended it by derogation to investments completed by 31 December 2025 as well, and filing the forms is a precondition for using the credit: without it the procedure is never perfected.

Anyone reading after that date who has not filed still has one useful move before writing the position off. The deadline has already been moved three times (31 March, then 31 July, then 15 September 2026), so it is worth checking the MIMIT site for a fourth and taking the case to your accountant.

Which software incentives survive into 2026?

Four, and only one of the four is a tax credit offsettable through F24 that can absorb an invoice for bespoke development: the research and development credit at 10%. The other three are the design credit at 10% for 2026 only while the pot lasts, the iperammortamento 2026-2028 with an uplift of up to 180%, and the MIMIT Voucher Cloud & Cybersecurity at 50% in grant form.

The work behind those headings is concrete. At a professional services firm, Obsidian Technologies took the preparation of a complex insolvency file from half a day of a senior associate to 40 minutes, with procedural deadlines tracked and compliance reconstructable after the fact. Whether software of that kind qualifies depends on who buys it and how it lands in the accounts, and that question is the rest of this article.

Three notes the table leaves out, and they change the choice.

The voucher is the only channel open to professionals, and the only one where SaaS and subscription costs are eligible in writing. In exchange it is de minimis aid, and the services have to be bought from suppliers on the list defined by the directorial decree of 29 July 2026: a contract with an unaccredited supplier cannot be reimbursed. The MIMIT sheet also mentions a minimum spend of 4,000 euros, a figure to recheck against the decree before building a quote on it.

The iperammortamento falls outside de minimis, because it is a general tax measure, which keeps it available to anyone who has already used up their allowance on other schemes. What it asks for in return is taxable capacity: a loss-making company draws no immediate benefit, and a flat-rate taxpayer draws nothing at all.

The R&D credit comes into play only where scientific or technical uncertainty exists. The way in for a software house’s invoice is the extra muros research contract under article 1, paragraph 200, letter c) of Law 160/2019, eligible where the contractor is tax resident or located in Italy, in another EU or EEA state, or in a white-list state.

What software falls under Annex V?

A good deal more than fell under the old Annex B. The list covers software, systems, platforms, applications, algorithms and digital models, and the letters that touch an IT supply run to at least a dozen.

• c) decision support software that acquires and interprets data or images, on premise, in the cloud and on edge devices;
• d) production management and coordination: MES, SCADA, CMMS, fieldbus, IoT and cloud systems;
• l) quality management of the production system;
• n) industrial analytics on big data from IoT sensors;
• o) artificial intelligence and machine learning for process quality and machine reliability;
• u) cybersecurity: protection of networks, data, programs, machines and plant, including observability, detection and response and lifecycle management of connected devices;
• v) virtual industrialisation and Digital Twin;
• z) supply chain management systems including those aimed at drop-shipping for e-commerce;
• bb) platforms for logistics management and coordination;
• dd) advanced artificial intelligence, with five explicit sub-items;
• ee) sustainability: Carbon Footprint, LCA, ESG, Digital Product Passport integrated with PLM, ERP and MES;
• ff) data spaces compliant with the European IDS-RAM standard, and IT/OT convergence;
• gg) low-code and no-code platforms for industrial applications, operational dashboards and process automation.

Letter dd), which is the real novelty

The five sub-items under advanced artificial intelligence deserve to be read as written:

1. generative AI, including Large Language Models, for automated generation of content, technical documentation, code and decision support;
2. Agentic AI: autonomous systems that carry out complex tasks, orchestrate workflows and operate with automated decision-making capability inside business processes;
3. MLOps platforms: versioning, performance monitoring, continuous updating, deployment;
4. AI for predictive maintenance;
5. process mining.

On the hardware side, the new section IV of Annex IV includes HPC infrastructure and GPU servers for training AI models, industrial edge computing, machine learning workstations, enterprise storage for data lakes and training datasets, private 5G networks and enterprise Wi-Fi 6, 6E and 7.

One question stays open, and it carries real weight for anyone buying software alone. Paragraph 429, letter a) cites Annex IV and Annex V together without making intangible assets conditional on an investment in tangible ones, unlike the old 2016 iperammortamento which did exactly that, and several consultants’ guides assert the opposite. The letter of the law appears to allow software on its own, no MIMIT or GSE guidance has confirmed it yet, and until that happens the point has to be treated as unsettled.

The constraint nobody mentions: you design it before the contract

The iperammortamento is booked in advance rather than claimed once the invoice is out. The MIMIT-MEF interministerial decree of 7 May 2026 sets out three notices on the GSE platform, in this order:

1. Advance notice for each production site, stating the type and amount of the investments in Annex IV and Annex V assets and the planned interconnection date. The platform has been open since 12 June 2026.
2. Confirmation notice within 60 days of a positive GSE outcome, evidencing payment of at least 20% of the acquisition cost of each asset together with the invoice details. For leases the 20% counts as met on signature of the contract.
3. Completion notice once interconnection has taken place and in any case by 15 November 2028, with a sworn technical appraisal by a chartered engineer or industrial expert on the professional register (or an attestation from an accredited certification body) and an accounting certification by a statutory auditor entered in section A of the register.

The GSE checks within 10 days and the order is chronological. The uplift takes effect from the tax period in which the completion notice is filed, provided the asset came into operation in that same period. Three consequences follow, and all three have to be decided before signature.

The payment schedule is part of the project. A contract paid in full before the file is opened, or conversely a token 5% deposit, puts the relief at risk on an asset that is otherwise perfectly eligible.

The software has to be capitalised. The uplift works on depreciation instalments, and a cost expensed in full in the year generates no instalments to uplift. The decision to book development among intangible fixed assets is taken with your accountant while the contract is being drafted.

Interconnection has to be demonstrated. Paragraph 429, letter a) requires assets interconnected to the company’s production management system or to the supply network. The appraisal has to be able to verify that, so documentation of the data flow is needed: record layouts, endpoints, connected systems, rather than a generic declaration.

Obsidian Technologies writes its quotes with line items split between capitalisable development, services and recurring fees, prepares the technical description of the data flow the appraisal has to verify, and on research contracts hands the client the technical report that paragraph 206 places on the contractor.

The R&D credit has a formal sequence of its own: an advance notice to MIMIT on the form set by the directorial decree of 24 April 2024 before work starts and a completion notice at the end, an accounting certification from a statutory auditor (for companies not subject to statutory audit the cost increases the credit by up to 5,000 euros), and a technical report countersigned by the legal representative. There is also the optional certification under article 23 of DL 73/2022, issued by certifiers on the MIMIT register, which binds the tax authorities: on a borderline software project that certification is the difference between a defensible credit and a dispute.

Three things clients ask for that do not qualify

1. Customisation to order. The MIMIT guidelines of 4 July 2024, which restate article 3, paragraph 3 of the ministerial decree of 26 May 2020, exclude from technological innovation any work carried out to adapt or customise the company’s products or processes at the specific request of a client. From 2026 that measure no longer exists, so the point carries as a general warning: bespoke software is not in itself an eligible activity, neither as innovation nor as research and development, where what is required is an uncertainty whose outcome is neither known nor deducible from the state of the art. The same goes for maintenance, defect correction, routine updates and adjustments to regulatory obligations.

2. The brochure site and the standalone e-commerce. Annex V contains no websites, graphic restyling or online shops as such. E-commerce appears in one form only, under letter z): supply chain management systems including those aimed at drop-shipping. The practical difference lies between an online shop that lives on its own and a system that moves orders, stock and suppliers through the chain.

3. The SaaS subscription inside the iperammortamento. Here a widespread inaccuracy circulates: the exclusion of SaaS fees does not appear in the text of the decree of 7 May 2026. Several guides present it as an express prohibition, and no such article exists in the decree. Ineligibility follows from the mechanism, from the fact that the uplift works on depreciation instalments and lease payments and presupposes an asset capitalised in the balance sheet. The practical result is the same, but knowing where the rule comes from matters when negotiating a mixed contract that combines a capitalised licence with a recurring service. For pure SaaS the right channel is the Voucher Cloud & Cybersecurity.

Does software developed in Italy count as an asset produced in the European Union?

Paragraph 427 makes the uplift conditional on assets produced in a member state of the European Union or in a state party to the Agreement on the European Economic Area, and the requirement applies to Annex V intangible assets as well. How the place of production of a piece of software should be established is left unexplained by both the law and the implementing decree, and no official guidance has been issued: does it turn on where the code is written, on the supplier’s registered office, or on the origin of the underlying models? None of the three readings has a ministerial answer today.

What can be said without forcing anything: a buyer purchasing from an Italian developer who writes the code in Italy can document the position through the contract, the place of performance and an attestation from the supplier, and it holds under all three readings. For a platform licence bought from a non-European vendor the same demonstration has to be built from scratch. It is a technical argument in favour of a European supplier, and it belongs in the contract in writing rather than being taken for granted, because this is the kind of requirement that gets checked during an audit years later.

The mistakes that cost you the relief

1. Signing and invoicing before the GSE file is open. The advance notice comes before the investment, and this is the most expensive mistake of all: it hits projects that are eligible on every other count.

2. Stacking the iperammortamento and the 4.0 credit on the same asset. Paragraph 431 allows cumulation with other national and European aid on the same costs, provided the support does not cover the same portions of cost, the cost actually incurred is not exceeded, and the base is taken net of other subsidies. It expressly prohibits the uplift on investments benefiting from the 4.0 capital goods credit under the 2025 budget law.

3. Counting on a cash benefit in 2026. The advance tax payment due for the period under way on 31 December 2026 is calculated without regard to the iperammortamento. The financial advantage arrives later, and it belongs in the cash plan with the right date against it.

4. Disposing of the asset without replacing it. Forfeiture is triggered by disposal without replacement by an asset of equivalent or better characteristics within the same tax period, by failure to retain documentation, or by untrue declarations. Recovery is carried out by the Agenzia delle Entrate on a report from the GSE, with interest and penalties.

FAQ

Is there still a tax credit for buying software in 2026?

Only the research and development credit at 10%, and only where the project involves overcoming a scientific or technical uncertainty whose outcome is neither known nor deducible from the state of the art. The 4.0 intangible assets credit under Annex B has been repealed and the technological innovation credit ended with the tax period under way on 31 December 2025. For software that is not research, the 2026 tax lever is the iperammortamento, which works as an enhanced deduction.

What is a 180% uplift actually worth?

The arithmetic is straightforward: on 100,000 euros of eligible acquisition cost the total deduction reaches 280,000 euros, spread across the depreciation instalments. What that converts to in tax saved depends on the applicable rate and on the company’s taxable capacity, and it has to be calculated on the accounts by your accountant.

Does an AI agent count as an eligible asset?

Letter dd) of Annex V expressly names Agentic AI systems capable of carrying out complex tasks, orchestrating workflows and operating with automated decision-making capability inside business processes. The general requirements still have to be met: a new asset, capitalised, interconnected to the production management system or the supply network, with a sworn appraisal and the GSE notices filed in the prescribed order.

Can a professional or a firm use the iperammortamento?

No. The measure is reserved for business income earners with production facilities on Italian territory. The only channel in this group that is also open to professionals is the MIMIT Voucher Cloud & Cybersecurity, which requires a connectivity contract of at least 30 Mbps download.

Is the subscription to a cloud management system eligible?

Not under the iperammortamento, because the uplift works on depreciation instalments and a periodic fee generates none. It is eligible under the Voucher Cloud & Cybersecurity, where SaaS services for accounting, HR management, ERP, CMS, e-commerce and CRM appear among eligible costs, alongside IaaS and PaaS cloud and cybersecurity, with ancillary configuration and support services capped at 30% of the spend.

Who writes the technical report for the research and development credit?

For activities carried out in house the company drafts it and the legal representative countersigns. For activities commissioned externally the contractor drafts it and hands it to the client, meaning the supplier doing the work. It is a statutory obligation and a contractual deliverable: it belongs in the proposal and it belongs in the price, because nobody produces it free of charge once the project has closed.

The four levers left, and which one to look at first

The right order for an SME that has to decide before the year is out runs like this. Production, logistics, quality, cybersecurity or artificial intelligence software: start with the iperammortamento, the largest lever and the only one that forces you to open a file before signing. A project containing genuine scientific or technical uncertainty: assess the research and development credit in parallel, with the advance notice to MIMIT and the technical report written into the contract from day one. Cloud, cybersecurity or a subscription management system: look at the Voucher Cloud & Cybersecurity and check immediately that your supplier is on the ministerial list, because pre-loading opens on 20 October 2026. The design credit stays in the table for completeness: it touches a software project only in particular cases.

If you have an AI agent project, a management system to modernise or document automation to build, and you want to know which item of Annex V each part of the quote falls under, get in touch: half an hour is enough to say whether opening the GSE file is worth it and what has to be capitalised.

For the rest of the map: the Voucher Doppia Transizione 2026, the chamber-of-commerce grant, covers consulting and training that find no home here, Autoimpiego and Resto al Sud 2.0 is the route for anyone starting out now, the Nuova Sabatini (the subsidised scheme for capital goods) works by balance-sheet line and combines with the iperammortamento within the limits of paragraph 431, and the AI agents, legacy modernisation and AI document automation pages describe the work that letters dd), d) and gg) name.

Sources: the text of Law 199/2025 in the Gazzetta Ufficiale with Annex IV and Annex V, the MIMIT page on the new Transizione 5.0 plan and the iperammortamento with the interministerial decree of 7 May 2026, the page on the research and development tax credit and the one on the Voucher for Cloud Computing and Cyber Security. Information verified against the legal texts on 13 September 2026: capped measures run out and administrative deadlines have already been extended more than once, so they should be rechecked on the relevant agency site before committing spend.