2026 enhanced tax depreciation: reservation and investment confirmation now available on the GSE platform
July 21, 2026
From 21 July 2026, the new enhanced tax depreciation regime became operational in the first two stages of the GSE procedure: the preliminary notice available since 12 June was joined by the investment confirmation notice. The latter requires, among other things, evidence that the advance payment has reached at least 20% of the acquisition cost of each asset and the identifying details of invoices for eligible costs.
What type of incentive is enhanced tax depreciation?
The incentive was introduced by Article 1, paragraphs 427-436, of Law No. 199 of 30 December 2025 and implemented by the Interministerial Decree of 7 May 2026. It grants an uplift of the tax basis of eligible assets for income tax purposes and is therefore not an F24-offsettable tax credit.
How does the preliminary notice work?
The procedure is divided into several stages. The preliminary notice is filed for each production facility and includes company details, the type and amount of the planned investments and the expected interconnection or commissioning date.
How is the investment confirmed?
Following a positive outcome of the preliminary notice, the company must submit the investment confirmation within the applicable deadline. The confirmation certifies payment of the advance amount required to reach at least 20% of the acquisition cost of each asset and includes the identifying details of invoices relating to eligible costs. It may not include different assets or higher amounts than those stated in the preliminary notice.
How is the procedure completed?
The process is completed through a final completion notice after the investments and interconnection have been completed and within the deadline set by the applicable rules. The supporting documentation includes a sworn technical appraisal and the accounting certification required to confirm that the expenditure was actually incurred.
What should the business do?
- verify the technical classification of the assets before filing the preliminary notice;
- coordinate purchase orders, advance payments and invoices with the confirmation deadline;
- appoint the technical professional responsible for the sworn appraisal and the statutory auditor responsible for accounting certification in good time;
- maintain a detailed reconciliation among GSE filings, accounting records, fixed-asset registers, invoices and payments.
What are the main legal and administrative references?
Legal and administrative references: Law No. 199 of 30 December 2025, Article 1, paragraphs 427-436; Interministerial Decree of 7 May 2026; MIMIT Directorial Decree of 10 June 2026; MIMIT Directorial Decree of 20 July 2026.
