The 2026 Budget Law reintroduces hyper depreciation, an increase in the tax deductible cost for investments in new tangible and intangible capital goods that support digital transformation (Industry 4.0 assets) and the energy transition (assets for self production from renewable sources). The measure applies to investments made from 1 January 2026 to 30 September 2028. The incentive is not automatic: communications and certifications must be submitted via the GSE platform, according to procedures that will be defined by an implementing decree issued by MIMIT MEF.
Eligible beneficiaries
Access is limited exclusively to entities generating business income:
· Sole proprietorships (including family businesses) and spousal businesses;
· Partnerships;
· Corporations;
· Cooperatives and mutual insurance companies;
· Public and private entities engaged in commercial activities;
· Permanent establishments in Italy of non resident entities.
Additional requirements
· Compliance with workplace health and safety regulations;
· Social security compliance (DURC).
Eligible investments
Investments are eligible in the following categories:
A) Industry 4.0 tangible and intangible assets (Annexes IV and V to the 2026 Budget Law) – new capital goods interconnected to the company’s system or supply chain. Examples include:
· Machines and equipment controlled by digital systems and sensors;
· Systems for quality assurance and sustainability;
· High performance computing (HPC) infrastructure, connectivity, and industrial cybersecurity;
· Advanced software and platforms (Agentic AI, MLops).
Key requirement – Interconnection: The asset must exchange data with internal/external systems through standard protocols (e.g., TCP IP, HTTP, MQTT) and be uniquely identifiable (e.g., IP address).
B) Assets for self production from renewable sources intended for self consumption, including storage systems. For photovoltaic systems, only high efficiency modules produced in the EU are eligible; remote self consumption is allowed in accordance with TIAD rules and the producer/end customer identity requirement.
General requirements for all assets
· Instrumental to business activity;
· New (newly manufactured assets; limits apply to showroom/rental goods as per case law);
· Territoriality: produced in the EU/EEA and allocated to production facilities in Italy.
Incentive amount
The increase in cost is applied progressively and is relevant only for calculating depreciation allowances and leasing instalments (principal component). The deduction is made off book, through a downward adjustment in the tax return (not relevant for IRAP).
For eligible investments, the acquisition cost is increased by:
· 180% for investments up to €2.5 million;
· 100% for investments over €2.5 million and up to €10 million;
· 50% for investments over €10 million and up to €20 million.
Key operational aspects
Timing of investment completion:
· Purchase: date of delivery/shipment or subsequent transfer of ownership;
· Leasing: date of delivery to the lessee;
· Contract work: invoiced work progress (SAL) or final completion;
· Self constructed assets: costs incurred during the eligible period.
Requirements for access
· Communications and certifications via the GSE platform;
· Technical reports certifying Industry 4.0 features and interconnection;
· Retention of all supporting documentation for audit purposes.
Use and limitations
· Off book deduction spread over the depreciation period (Ministerial Decree 31/12/1988);
· Amounts not deducted in a given year cannot be carried forward; recovery only through amended tax return/refund request;
· 2026 tax prepayments must be calculated without the incentive (historical method).
Disposal/relocation of the asset
· If the asset is sold or moved abroad during the incentive period, the benefit stops;
· No repayment of deductions already legitimately taken;
· Replacement within the same tax period with an equivalent or superior new asset: the incentive continues (adjustments apply if the replacement asset has a lower cost).