Italy's 2026–2028 hyper-depreciation: what replaced Transition 5.0.

In short — for Industry 4.0 investments from 1 January 2026 to 30 September 2028 the incentive is the hyper-depreciation introduced by Italy's 2026 Budget Law. It no longer requires certified energy savings, but it remains a three-step procedure on the GSE portal, with a final technical appraisal.

What happened to Transition 5.0

Transition 5.0 was a tax credit for 2024–2025 investments that cut energy consumption by at least 3% across the production facility or 5% on the process, with savings certified before and after the intervention. The available funds ran out in November 2025: it is no longer an option for new investments.

What the 2026–2028 hyper-depreciation is

Law no. 199 of 30 December 2025 (art. 1, paragraphs 427–436) increases, for income-tax purposes, the deductible cost of new capital goods listed in Annexes IV (tangible assets) and V (intangible assets), provided they are interconnected with the production management system or the supply network. It is not a tax credit: the benefit comes as higher depreciation.

How to apply

Applications go through the GSE platform, open since 12 June 2026, with three filings:

  • advance notice, before the investment;
  • confirmation, within 60 days;
  • completion, by 15 November 2028, with a sworn technical appraisal and an accounting certification.

What changes for those who measure consumption

The certified energy-saving requirement is gone, so consumption data is not needed to obtain this incentive. It remains useful in three ways:

  • choosing the investment: machine-by-machine consumption shows where a new asset pays back most;
  • proving its return: before and after, in kWh per part and in euros, for management and lenders;
  • the energy audit remains mandatory for large and energy-intensive companies (Legislative Decree 102/2014), next due on 5 December 2027, and many regional and national calls still require an audit or measured consumption.

Whether a monitoring system counts as an eligible asset must be checked case by case with your advisor. Under the previous Industry 4.0 regime (Annex A of Law 232/2016) energy-consumption monitoring systems were explicitly included; for Annexes IV and V of the new regime, read the official text.

Open points

  • the requirement that assets be manufactured in the European Union or the European Economic Area: sources disagree after the 2026 amendments;
  • whether the €20 million cap applies per year or to the whole 2026–2028 period;
  • how subscription software (SaaS) is treated among intangible assets.

Sources

  • Law no. 199 of 30 December 2025 (2026 Budget Law), art. 1, paragraphs 427–436 — Official Gazette no. 301 of 30/12/2025, ordinary supplement no. 42
  • MIMIT–MEF implementing decree of May 2026 and operating instructions on the GSE portal
  • Legislative Decree no. 102 of 4 July 2014, art. 8 (energy audit)

This article describes the situation as of 11 October 2026 and is not tax advice: check with your accountant before investing. If something here looks out of date, let us know.