Innovative start-ups 2025: the Ministry for Enterprises and Made in Italy (MIMIT) clarifies requirements, 36→60-month extensions and removals
August 6, 2025
The Ministry for Enterprises and Made in Italy (MIMIT) clarifies the conditions for recognition and maintenance of innovative start-up status in 2025. In brief, the enterprise must qualify as a Small and medium-sized enterprise (SME) and, from the second financial year, comply with the €5 million production-value cap. Performing agency or consultancy as the prevalent activity is excluded. The guidance aims to align practices and checks at the Companies Register. (MIMIT Circular 29.07.2025; DL 179/2012, Art. 25; Law 193/2024).
For the 36 to 60 months extension, holding at least one “reinforced” criterion is sufficient, including:
- Research and Development (R&D) at least 25%;
- a pilot contract with a Public Administration;
- significant growth in revenues or employment;
- creation of an equity reserve over €50,000 with the entry of a third-party investor and R&D at least 20%;
- ownership of at least one patent.
The Circular specifies that, for the extension, patent ownership is essential: a licence, a utility model or mere software registration are not sufficient. (MIMIT Circular 29.07.2025).
Further “scale-up” periods of two years each are also provided where specific conditions occur: an equity increase exceeding €1 million per period by a collective investment undertaking (OICR), or doubling of revenues year-on-year. (MIMIT Circular 29.07.2025; DL 179/2012, Art. 25).
Enterprises that had exceeded 60 months as at 18 December 2024 are removed ex officio from the special section of the Companies Register; in such cases, switching to innovative SME status may be considered if the requirements are met. (MIMIT Circular 29.07.2025).
Operational guidance
It is advisable to:
- verify the SME test and the €5 million cap from the second year;
- check ATECO codes and activity description to exclude agency/consultancy as the prevalent activity;
- prepare in advance the 36→60 dossier (financial statements, notes, R&D evidence, any pilot contract with a Public Administration, capital/share premium resolutions, patent);
- plan any “scale-up” (entry of an OICR or +100% revenue growth) with a consistent timeline and documentation. (MIMIT Circular 29.07.2025)
Published on: 06/08/2025
Allegati
