Italy's Nuova Sabatini: when software counts as capital goods

Italy’s Nuova Sabatini scheme is officially called “capital goods”, talks about machinery on every institutional page, and for that reason three quarters of Italian software houses treat it as a measure that has nothing to do with them. It is a costly mistake, because application software does qualify, it is written into the ministerial circular, and on a 60,000 euro project it moves real money.

The opposite mistake costs more. You tell the client the project is fundable, they sign, and at payout stage you discover that half the quote was booked under headings the Ministry does not recognise. At that point the grant is not reduced: on those lines it is lost.

The difference between the two outcomes turns on a single question, and it is not a technical one. Does this invoice land in the fixed assets of the client’s balance sheet, or does it go to the profit and loss account? Nuova Sabatini does not think in projects, it thinks in balance-sheet lines, and everything else follows from there.

TL;DR

• Nuova Sabatini is not a grant on the investment. It is a capital contribution calculated on the notional interest of a five-year loan, and without a bank loan or a finance lease it does not exist.
• Loan: from 20,000 to 4,000,000 euros per company, maximum term 5 years, can cover up to 100% of the investment.
• Grant rate: 2.75% a year on ordinary capital goods, 3.575% on Industry 4.0 and green investments.
• Application software qualifies only where it can be capitalised under B.I.3 (owned outright or licensed indefinitely) or B.I.4 (fixed-term licence paid as a single up-front sum). System software capitalised into the cost of the hardware qualifies as a tangible asset.
• Does not qualify: recurring subscription fees, consulting of any kind, software developed in-house by the client, barter deals, assets under construction, invoices below 516.46 euros net of VAT, payments settled by set-off.
• No like-for-like replacement: rebuilding a system with identical functionality is not an eligible investment programme.
• Open as of 13 September 2026, rolling window in chronological order with no click day, with just over 1.2 billion euros left on the ordinary line per the Ministry’s 26 August 2026 figures, plus 650 million of refinancing from the 2026 budget law.
• It stacks with tax credits, because those are not State aid. With other State aid, cumulation is capped by European intensity limits: 20% of eligible costs for small enterprises, 10% for medium-sized ones.

How it works, before we get to software

The mechanism confuses people because it involves three parties rather than two. The company applies for a loan from a bank or financial intermediary signed up to the agreement between the Ministry, the banking association and Cassa Depositi e Prestiti, or takes out a finance lease. In parallel the Ministry awards a capital contribution equal to the interest calculated notionally on a five-year loan of the same size as the investment.

Three practical consequences that change how the scheme should be presented to a client:

1. The form is filled in on the Ministry’s platform and sent to the bank. It has to be completed through the Ministry’s online procedure, where the project code is generated, then signed digitally by the legal representative and sent by certified email to the chosen institution. There is no click day: reservation requests reach the Ministry monthly and are met in chronological order.
2. The loan contract is signed after the application, never before.
3. The grant is worth a fraction of the investment. Anyone describing it as “a grant on the machine” is saying something untrue, and the disappointment arrives when the figures are read.

Beneficiaries are micro, small and medium enterprises entered in the business register, across every productive sector except financial and insurance activities. One exclusion worth stating early, because it rules out a client category typical of software vendors: sole practitioners and professional firms not entered in the business register are not eligible.

Does software qualify? The answer is in the balance sheet

The circular allows the purchase of machinery, plant, capital goods, factory-new equipment for productive use, hardware, software and digital technologies. The real filter comes immediately afterwards: assets have to be classifiable in fixed assets under headings B.II.2, B.II.3 and B.II.4 of article 2424 of the Italian civil code, with the sole exception of application software classifiable under B.I.3 and B.I.4.

Translated into quote lines:

The rule the ministerial FAQ sets out explicitly is that no other category of intangible asset is eligible. No goodwill, no start-up costs, no capitalised development costs that are not application software.

From which follows the question to put to the client’s accountant before the quote is written rather than after: can this supply be capitalised under B.I.3 or B.I.4? If the answer is no, the project remains a good project and it is not fundable through this scheme.

2.75% or 3.575%: the 24 items that change the rate

The grant rate rises from 2.75% to 3.575% where the supply falls within the Industry 4.0 asset lists, which in the circular are annex 6/A for tangible assets and 6/B for intangible ones, modelled on annexes A and B to law 232/2016.

The items in annex 6/B that intersect the work of a software house are more numerous than expected:

• EDM, PDM, PLM and big data analytics systems across the product life cycle;
• decision support software interpreting field data;
• production management and coordination with strong service integration, explicitly naming SCADA, MES, CMMS and solutions attributable to the IoT and cloud computing paradigms;
• software that communicates and shares data, meaning industrial IoT;
• quality management at production system level;
• cloud computing supporting production processes and the supply chain;
• industrial analytics on big data from IoT sensors;
• artificial intelligence and machine learning, with a qualification that matters: the text ties them to production process quality and to the reliability of the machine or plant, not to a commercial conversational assistant;
• cybersecurity, protecting networks, data, programmes, machines and plant from attack and unauthorised access: the broadest item on the list and the natural hook for a technical NIS2 remediation project;
• supply chain management for drop shipping in e-commerce, the only explicit reference to online retail in the whole annex;
• immersive experiences, 3D reconstruction and augmented reality;
• logistics management with telematic integration of on-field and mobile devices.

The trap at point 7.7

Here sits the real economic decision, and almost no guide covers it. If a cost is declared on the 4.0 line and the Ministry concludes it does not belong in annex 6/B, that cost does not drop back to the ordinary 2.75% line: it is excluded entirely.

On frontier software, say a bespoke agent platform, the choice between declaring a safe 2.75% and a contestable 3.575% is a risk decision rather than a formality. And on this scheme there is no advance ministerial opinion to lean on: the statement that the assets fall within the annexes is signed by the beneficiary’s own legal representative in the payout request. What backs that signature, on projects of any size, is the sworn technical report the tax rules on Industry 4.0 assets already require.

There is also a documentary point worth stating rather than resolving in the reader’s favour. Annex B to law 232/2016 is titled, in its original version, “Intangible assets connected to investments in Industry 4.0 tangible assets”. Annex 6/B of the circular reproduces the 24 items without carrying over that title. In the same circular, though, the definition of an Industry 4.0 investment refers back to annexes A and B of law 232/2016, so the link to the source rule survives. The question is open, and on a programme made up of software alone it has to be settled with your accountant and your bank before applying: that is where the scope gets decided, and an article is not enough.

The like-for-like rule, and legacy modernisation

The circular excludes investment programmes consisting of the purchase of assets that merely replace existing ones. Applied to software, that rule decides the outcome of almost every modernisation project.

Replacing a business system with a new one that does exactly the same things is the textbook case of an ineligible programme. Replacing it while introducing functions that were not there before, interconnection with the shop floor, traceability, analytics on production data, integration with logistics, is an investment, and on the 4.0 line it is often the 3.575% too.

On a modernisation of a custom ERP built in the 2000s handled by Obsidian Technologies the work was carried out in phases, module by module, without ever stopping production, and weekly planning efficiency rose by 20%. The distinction between a like-for-like rebuild and the introduction of new functions into the production cycle is the same one the ministerial circular uses to separate an eligible investment from a replacement.

The operational consequence is that the scope has to be decided and written at the outset, in the quote and the technical report, rather than reconstructed afterwards when the payout request comes round.

What never qualifies

The list of ineligible costs is exhaustive. The items that concern an IT supply:

• service supply and consulting of any kind. This is the most important line for anyone selling software alongside analysis work: assessment, requirements gathering, organisational design, project management, training, audits. All out;
• internal work orders, meaning software developed by the client’s own staff;
• assets acquired through barter or contributions in kind;
• assets under construction and advance payments: the programme has to be completed and paid in full;
• running costs, stock and consumables of any kind;
• purchase or lease of land and buildings;
• invoices below 516.46 euros net of VAT, except where several functionally related assets appear on a single invoice at or above that threshold;
• costs settled by set-off of receivables against suppliers.

From which follows something that belongs in the contract before it reaches the invoice: a project mixing licence, development and consulting days has to be split into separate line items, so the capitalisable part gets through and the rest does not drag the whole invoice into rejection.

Obsidian Technologies already separates the capitalisable share from the service share in its quotes and states for each line where it lands in the accounts, so the client’s accountant can confirm it before the application goes in: that is the information needed to decide whether the scheme is viable at all, and asking for it commits you to nothing.

The formal requirements that trigger revocation

They are mundane and they are the most frequent cause of full revocation.

• Electronic invoices, deposit and balance, have to carry the project code and, separately, the reference “art. 2, c. 4, D.L. n. 69/2013”. The wording has to be agreed with the supplier before issue, because fixing it afterwards is not always possible.
• Payments have to be traceable: bank transfer, SEPA credit transfer or the Italian RI.BA instrument. No cash, no set-off.
• The programme has to be completed within 12 months of the loan contract being signed, on pain of revocation. The date of the last invoice governs.
• The payout request has to be filed within 120 days of the completion deadline, solely through the Ministry’s online platform. A form completed outside the platform cannot be processed.
• A supplier release declaration generated by the platform is required, in which the supplier certifies that the assets are factory-new and, for green investments, provides the environmental certification or self-declaration. The statement that the assets fall within the Industry 4.0 lists is instead made by the company’s legal representative in the payout request: it is the beneficiary’s responsibility, not the supplier’s.
• Assets have to be capitalised and held on the balance sheet for at least 3 years, and cannot be sold, transferred or diverted from productive use for 3 years after completion.

Cumulation, where the scheme is more generous than it looks

On this front the measure is the opposite of others. The grants stack with tax credits, because the Ministry treats them as general tax measures rather than State aid: the FAQ says so explicitly for both the capital goods credit and the 5.0 credit, with the single internal limit that the sum of the benefits cannot exceed the cost of the asset.

With other State aid, de minimis included, cumulation is allowed on the same costs provided the maximum applicable intensity is not exceeded: for a company outside agriculture and fisheries the ceiling is 20% of eligible costs for small enterprises and 10% for medium-sized ones. If cumulation goes beyond, the Ministry reduces the grant and leaves the loan untouched. Worth knowing: the SME Guarantee Fund guarantee is itself State aid, and the Ministry counts it automatically.

FAQ

Does business software qualify for Nuova Sabatini?

Yes, where it can be capitalised as an intangible asset under B.I.3 of the balance sheet (software owned outright or licensed indefinitely) or B.I.4 (fixed-term licence with a single up-front payment for the whole term). Software on a recurring subscription, which goes to profit and loss, does not qualify.

How much is the grant worth?

2.75% a year for ordinary capital goods and 3.575% for Industry 4.0 and green investments, calculated on the notional interest of a five-year loan equal to the investment. On the capitalisation line it rises to 5% for micro and small enterprises. The Ministry publishes an official calculation sheet for the exact figure.

Can I fund software alone, with no machinery?

On the ordinary line there is no explicit obstacle. On the 4.0 line the question is open: annex B to law 232/2016 refers in its title to intangible assets connected to tangible ones, and the Sabatini circular’s annex does not carry that title over, while still defining Industry 4.0 investments by reference to annexes A and B of the same law. On a software-only programme the question has to be settled with your accountant and your bank before applying, because the Ministry does not issue advance opinions on this scheme.

Is IT consulting eligible?

No. Service supply and consulting of any kind are excluded outright. That is the main difference from the chamber-of-commerce vouchers, which do fund consulting, and it should shape which scheme a given project is taken to.

Is rebuilding the same system eligible?

No. Programmes consisting of the mere replacement of existing assets are excluded. For a modernisation project to qualify it has to introduce new functions into the production cycle, and that has to be described in the quote and the technical report from the start.

Can Sabatini be combined with a tax credit?

Yes. The Ministry clarifies in its FAQ that the capital goods tax credit does not constitute State aid, so the Sabatini cumulation limits do not apply, subject to the sum of the benefits not exceeding the cost incurred for the asset.

Is there money left?

As of 13 September 2026 the window is open. Residual resources on the ordinary line stand at just over 1.2 billion euros per the Ministry’s 26 August 2026 figures, and the 2026 budget law added 200 million for 2026 and 450 million for 2027. The figure updates on the ministerial page and should be read there.

Can a professional firm apply?

Only if entered in the business register. Sole practitioners and firms outside the register are not eligible beneficiaries, and their route has to be found elsewhere.

The question to ask the accountant before signing the quote

The whole scheme reduces to a check that takes five minutes and that belongs at the front rather than the end: ask the client’s accountant whether this specific supply will be booked under B.I.3 or B.I.4, or expensed through profit and loss. If the answer is the second, Sabatini is not the route, and a chamber-of-commerce voucher is worth a look instead, since it does fund consulting and treats capitalised assets far more broadly.

If the answer is the first, the next step is writing the quote with the line items already separated and the line, ordinary or 4.0, stated for each. If you want a quote structured that way for a business system, integration or modernisation project, get in touch.

For technical context: the legacy modernisation pillar, the custom ERP replacement page, and the article on what it costs to modernise a custom ERP from the 2000s, useful for working out which slice of a project is capitalisable.

Sources: the official Nuova Sabatini page at the Italian Ministry of Enterprise, the ministerial FAQ which contain the detailed software rules at points 6.4 and 9.7, and directorial circular no. 410823 of 6 December 2022 with its annexes. Figures verified on 13 September 2026: the Ministry has announced an interministerial decree aligning the scheme with the catastrophe insurance obligation, so the ministerial page is worth rereading before applying.