SIMEST: 200 million for AI from 21 September, cost by cost

From 09:00 on 21 September 2026 SIMEST, the Italian state-backed export finance company, opens a new section of its Digital or Green Transition line dedicated to investment in artificial intelligence and quantum computing, with a reserve of 200 million euros. The portal goes offline from 18:00 on 20 September until it opens.

The 200 million figure is the one every outlet picked up. The useful part sits elsewhere, in a public document almost nobody has opened: Annex 2 to Circular 4/394/2023, which lists line by line the artificial intelligence costs that Italy’s Fondo 394/81 treats as eligible. Inside it, verbatim, are custom development of proprietary models, fine-tuning, prompt engineering, integration with ERP, CRM, MES and SCADA, the model APIs of OpenAI, Anthropic and Google, AI Act compliance and algorithm auditing.

This article reproduces that list in full, explains the condition that lowers the export revenue threshold and opens the measure to companies that do not export at all, and says what stays out. It closes with the e-commerce line of the same fund, which follows different rules and contains a supplier requirement worth reading before choosing who builds the platform.

TL;DR

• 21 September 2026, 09:00: the “AI and Quantum Computing Investment” section opens on the SIMEST Digital or Green Transition line. Portal offline from 18:00 on 20 September.
• Dedicated reserve: 200 million euros. Rolling window in chronological order of submission, with possible early closure once funds run out.
• How the facility is built: a subsidised loan at 0.371%, six years extendable to eight on this section, a 50% advance on the first tranche, plus a 10% grant element on the subsidised amount.
• Amounts: minimum 10,000 euros; maximum equal to the lower of 35% of average revenue over the last two financial statements and 500,000 euros for a micro enterprise, 2,500,000 for SMEs, innovative SMEs and innovative start-ups, 5,000,000 for everyone else.
• The condition that opens the measure: committing 100% of the funds to artificial intelligence and quantum computing. In exchange, the ordinary 10% export revenue threshold drops to 3%, and an alternative test exists for companies selling to exporters.
• The list of eligible costs covers infrastructure and computing, licences and APIs, development and integration, data, skills and training, certification, security and compliance.
• The whole of Fondo 394/81 runs under de minimis rules per Regulation (EU) 2023/2831, so the three-year ceiling for the single undertaking sits above everything else.
• E-commerce line, different rules: it needs two filed sets of accounts, and the platform has to be built by a supplier active for at least two years with at least two platforms delivered in the previous two.

How Fondo 394/81 works, in two paragraphs

Fondo 394/81 is not a grant scheme. It is a subsidised loan at a reduced rate, managed by SIMEST on behalf of the Italian foreign ministry, alongside a grant element where certain conditions apply. Almost all of it is repaid, at a rate that today is a fraction of the European Commission reference rate.

Applications are filed on the SIMEST portal and assessed in chronological order of submission, within the fund’s available resources. No ranking, no merit score. With the new platform introduced in early September 2026, access was managed through a virtual queue: once through, you have 30 minutes to complete the form before rejoining the queue. That operational detail matters more than it sounds when a 200 million euro section opens.

The AI and Quantum Computing section: numbers and conditions

The package, per the SIMEST product page, is this: subsidised rate 0.371%, six-year term extendable to eight on this section, 50% advance on the first tranche, 10% grant element on the subsidised amount requested. The minimum facility is 10,000 euros; the maximum depends on company size and on average revenue over the last two sets of accounts.

The condition for accessing the section is that the company commits 100% of the funds to investment, services and initiatives in artificial intelligence and quantum computing. The condition covers the whole project rather than a share of it.

The eligible costs, line by line

This is why the annex is worth reading instead of the press release. The eligible artificial intelligence items, as the circular lists them:

Infrastructure and computing. AI and quantum cloud on a consumption basis for training and inference, GPUs and TPUs on-premise or in co-location, storage for datasets and models, edge computing embedded in machinery or IoT devices.

Software and licences. AI and quantum platform licences, model APIs (the circular names OpenAI, Anthropic and Google Gemini), MLOps software, data labelling tools, automation software combining RPA and AI.

Development and implementation. Custom development of proprietary models, fine-tuning of pre-trained models with model drift monitoring, integration with existing systems (ERP, CRM, MES, SCADA), model testing and validation, prompt engineering and optimisation.

Data. Dataset collection and purchase, cleaning, labelling and preprocessing, data governance and data infrastructure (data lake, data warehouse), data quality tooling.

People and skills. Temporary placement of management figures, an AI project manager for instance, to deliver projects and handle change management; training of existing staff delivered by third-party companies, bodies, training institutes or certified independent professionals; apprenticeships or internships for people with an AI or quantum background, with costs covered for up to six months.

Certification and intellectual property. Certification in AI and quantum, with ISO/IEC 42001 named explicitly, and tools protecting the intellectual property of AI projects.

Security and compliance. Cybersecurity applied to AI and quantum systems, privacy and GDPR compliance including impact assessments and audits, AI Act compliance, algorithm audits and explainable AI.

For AI costs the circular requires a declaration of compliance of the expenditure with artificial intelligence regulation.

What makes this list different from every other Italian incentive is the fourth entry in the third block. Most public schemes fund the purchase of a technology; here the work of integrating with systems the company already runs is explicitly eligible, and that is where almost all the real cost of an AI project in a manufacturing SME sits.

The export requirement, and why it drops on this section

On the Digital Transition line the ordinary access requirement is export revenue of at least 10% in the last financial year. For companies devoting the entire project to artificial intelligence and quantum computing the circular lowers that threshold to 3%, and provides an alternative test for companies invoicing exporters. In its launch statement SIMEST says the instrument is aimed at companies not operating in foreign markets too.

That is the condition that changes who qualifies. An SME in Marche selling to a subcontractor that exports, which until now considered itself outside anything carrying the word “internationalisation”, has a route on this section. Before counting on it, though, the exact threshold applicable to a given case has to be read in the current version of Circular 4/394/2023, because SIMEST circulars were updated at least five times between December 2025 and September 2026.

The e-commerce line, which follows different rules

Same fund, different circular (6/394/2023), and conditions worth not confusing with the Digital Transition ones.

Who can apply. Any company, not just SMEs, with a registered and operating office in Italy and at least two filed sets of accounts covering two complete prior financial years. That requirement effectively excludes companies incorporated less than two years ago and would-be founders: for them the route is a different one, Autoimpiego and Resto al Sud 2.0.

What it is worth. A maximum equal to the lower of 500,000 euros and 20% of average revenue over the last two sets of accounts, minimum 10,000 euros. Four-year term, two of grace and two of repayment. The grant element runs up to 10% of the facility and no more than 100,000 euros, where at least one priority requirement is met: among them youth-led, women-led and innovative SMEs, environmental certification, and average export revenue of at least 20% over the last two years.

What it funds. Creating or improving a proprietary platform, or joining a third-party marketplace. On a proprietary platform the circular allows creation, acquisition and configuration, hardware and software components, and in its own words software component extensions to add functionality, with these examples: order management, payment rails, cloud services, integration with ERP, CRM, AI and augmented reality. Plus app creation and configuration, domain hosting, investment in data security, content and design, access monitoring, navigation analytics and tracking, and consulting aimed at developing or modifying the platform.

The composition rule. Creation, development and investment in the platform have to account for at least 50% of the facility. Indexing, web marketing, communication and training sit in the other half and cannot absorb the whole project.

The supplier requirement almost nobody reads

The proprietary platform has to be built or improved by a supplier that, when the contract is signed, has been active for at least two years and has delivered at least two platforms in the previous two years, attested by a formal declaration.

Obsidian Technologies has been developing software since 2018 and handles around 120 projects a year, from short engagements to enhancements for existing clients and month-long builds: that is the kind of track record the circular asks the platform builder to attest.

Two further guardrails point the same way: platforms configured purely as marketplaces are not eligible, nor are those where third parties sell directly, and the domain has to be registered by the applicant company. Anyone whose online shop is built on the agency’s domain discovers the problem at reporting stage.

What stays out

The e-commerce exclusions are exhaustive and they hit line items that an agency quote almost always contains:

• export-related activity, including commissions tied to volumes sold, and setting up or running a distribution network;
• costs directly tied to commercial activity: after-sales support, transport, warehousing;
• costs for the company’s ordinary running, including its own staff or anyone connected to it, shareholders and officers included;
• continuous or recurring consulting and anything covering ordinary operating costs, such as tax, legal or advertising advice;
• costs already covered by other public aid that cannot be combined.

One derogation is worth knowing: consulting to prepare and manage the application is eligible up to 5% of the approved amount, provided the contract and the consultant’s independence declaration are sent to SIMEST in advance. That is the opposite of almost every other Italian measure, where the item is excluded by law.

The mistakes that cost the facility

1. Spending before the project code. Costs have to be incurred, invoiced and paid after the project code is received and relate to activity inside the implementation period. An earlier invoice does not count.

2. Not opening the dedicated account. Payments have to run through a dedicated bank account opened before any eligible cost is incurred. Opening it later means costs that cannot be claimed.

3. Invoices and transfers without the project code. Every transfer and every invoice has to carry it. Set-off is excluded.

4. Underestimating de minimis. The whole of Fondo 394/81, subsidised loan and grant element alike, runs under de minimis. If the single undertaking’s remaining headroom is too small, SIMEST scales the facility down. Checking your position on the national State aid register beforehand is worth the time.

5. Reaching the queue unprepared. Thirty minutes of session time is not enough to gather documents. The file is prepared beforehand, and access is only for submitting.

6. Overrunning the implementation period. On the e-commerce line it starts when the project code is issued and ends within 24 months of signature, with a single automatic six-month extension on request, which shortens the repayment period by the same amount.

Obsidian Technologies prepares quotes with the line items split between platform development, integrations, security and promotional activity, so the 50% rule can be checked before submission, and states which parts fall within the circular’s list: that is the information needed to decide whether to apply at all, and asking for it commits you to nothing.

FAQ

Who can access the SIMEST AI and Quantum Computing section?

Companies eligible for the Digital or Green Transition line that commit 100% of the requested funds to artificial intelligence and quantum computing costs. For them the ordinary 10% export revenue threshold drops to 3%, with an alternative test for companies invoicing exporters. SIMEST states the measure is aimed at companies not operating in foreign markets too.

Is developing a bespoke AI agent an eligible cost?

Yes. Annex 2 to Circular 4/394/2023 lists custom development of proprietary models, fine-tuning of pre-trained models, prompt engineering, testing and validation, and integration with existing systems such as ERP, CRM, MES and SCADA. Buying model APIs is covered too.

How much can be requested?

From 10,000 euros up to the lower of 35% of average revenue over the last two sets of accounts and 500,000 euros for micro enterprises, 2,500,000 euros for SMEs, innovative SMEs and innovative start-ups, and 5,000,000 euros for everyone else. Ten per cent of the subsidised amount comes through as a grant.

Is it a grant?

Only partly. The bulk is a subsidised loan to be repaid, at 0.371% over six years extendable to eight on this section, with a 50% advance on the first tranche. The grant element is 10% of the subsidised amount.

Can I fund an e-commerce build through this section?

A platform project belongs on the e-commerce line, which has its own rules: two filed sets of accounts, at least 50% of the spend on creating and developing the platform, the domain in the applicant’s name, and a supplier with two years of activity and two platforms delivered. The AI section funds the artificial intelligence project, not the online shop.

Are cloud fees eligible?

On the AI section, annex 2 allows AI and quantum cloud on a consumption basis for training and inference. As with every cost, it has to be incurred and paid inside the implementation period, after the project code, from the dedicated account: a subscription running beyond that window cannot be claimed for the excess.

Does it combine with other grants?

Fondo 394/81 runs under de minimis, so the constraint is the single undertaking’s three-year ceiling. Costs already covered by other non-combinable public aid have to be left out: the same invoice cannot be claimed twice.

How long will the money last?

Nobody can say. No public source reports how much is left on any window, and SIMEST explicitly warns that the portal can close early once funds run out. The only verified allocation figure is this section’s 200 million reserve.

Who can move by 21 September, and who is better off waiting

A week is not enough to invent an artificial intelligence project, and it is plenty to submit one that already existed. The practical distinction is this.

Worth moving now: companies that already have a defined project, with a written technical scope and a supplier identified, and that can open the dedicated account and prepare the file this week. For them 21 September is only the submission date.

Better off waiting: anyone still deciding what to do with artificial intelligence. The reserve is 200 million and the window stays open while resources last, so turning up with a badly written project to be first is the quickest way to burn de minimis headroom without building anything.

If you have an AI agent, ERP integration or automation project and want to know which quote lines fall within annex 2 before opening the file, let’s talk: half an hour is enough, and the answer arrives before the 21st.

For the rest of the map: the 2026 Double Transition Voucher covers smaller projects with a real grant, Autoimpiego Centro-Nord covers businesses that have just opened, and on the technical side the AI agents pillar and the AI integration into your ERP page describe the kind of project discussed here.

Sources: the SIMEST Digital or Green Transition product page with the AI section’s conditions and dates, the e-commerce line page, and operating circulars 4/394/2023 and 6/394/2023 as updated on 30 July 2026, which contain the cost lists quoted here. Figures verified on 13 September 2026: SIMEST circulars were updated five times between December 2025 and September 2026, so every number should be rechecked against the current circular before committing spend.