Introduced by the 2026 Budget Law, the 2026 Super Depreciation scheme allows businesses to increase the depreciable value of eligible Industry 4.0 capital assets by up to 180%, including a wide range of industrial software. However, subscription-based SaaS fees remain ineligible, as they are classified as operating expenses rather than capitalizable intangible assets under the current regulatory framework.
The 2026 Super Depreciation scheme is an enhanced tax deduction introduced by the 2026 Budget Law (Law No. 199/2025) for businesses investing in Industry 4.0 capital assets. It allows companies to increase the depreciable value of eligible investments by up to 180%, replacing the previous Transition 4.0 and Transition 5.0 tax credit schemes.
The incentive applies to investments made between 1 January 2026 and 30 September 2028, with a total budget allocation of €9.8 billion.
When it comes to software, however, the rules are more nuanced. While several categories of software fully qualify for the incentive, subscription-based SaaS fees remain ineligible under the current legislation.
Let’s take a closer look at how the scheme works, which assets qualify for the incentive, and what businesses should know before planning a digital transformation investment.
What’s Changed Compared to Previous Incentive Schemes
The Super Depreciation scheme is not entirely new. A similar incentive existed in the past before being replaced by the Industry 4.0 and Transition 5.0 tax credit programs. With the 2026 Budget Law, the Italian government has reintroduced the enhanced tax depreciation mechanism, bringing back the increased tax basis approach with several key differences from the tax credit system that businesses had become accustomed to:
- Nature of the incentive: No longer a tax credit that can be offset through the F24 tax payment system. Instead, it is an enhanced tax depreciation allowance that increases the tax-deductible cost of eligible assets, reducing the IRES or IRPEF taxable base over the asset’s useful life.
- Application through the GSE platform: All required notifications and filings are managed through the Gestore dei Servizi Energetici (GSE) platform, which can be accessed using Italy’s SPID (Public Digital Identity System) or CIE (Electronic Identity Card) credentials.
- Country-of-origin requirement removed: Decree-Law No. 38/2026 eliminated the requirement that eligible tangible assets be manufactured within the European Union or the European Economic Area (EEA), expanding the range of qualifying suppliers.
- Software is once again eligible for the incentive after being excluded in 2025—although only under specific conditions, as we’ll see below.
Enhanced Depreciation Rates
The incentive is structured on a tiered basis, with enhanced depreciation rates determined by the total amount of eligible investment:
| Investment Amount | Enhanced Depreciation Rate |
| Up to €2.5 million | 180% |
| From €2.5 million to €10 million | 100% |
| From €10 million to €20 million | 50% |
For SMEs making relatively modest investments, the highest enhanced depreciation rate applies to the most common investment bracket, making the incentive particularly attractive for small and medium-sized businesses.
Eligible Tangible Assets (Annex IV)
Assets listed in Annex IV include traditional Industry 4.0 capital goods: machinery, plants, and production systems equipped with digital control systems, provided that they are interconnected with the production management system or the company’s supply network.
The eligible assets also include renewable energy self-generation systems and energy storage solutions, which qualify for the incentive up to a maximum limit of €900 per kWh.
Eligible Intangible Assets (Annex V): What Software Really Qualifies
This is the most relevant section for companies such as AzzurroDigitale, which work daily with software solutions supporting the digital transformation of manufacturing businesses. Annex V covers software, systems, platforms, applications, algorithms, and digital models designed to enable digital transformation, with an updated list that includes modern categories such as artificial intelligence, ESG platforms, and cognitive and adaptive systems for the optimization of production processes.
In practice, the initial clarifications provided by MIMIT and GSE identify the following as eligible:
- PLCs, SCADA systems, and HMIs connected to production processes and integrated through interconnection.
- ERP systems, but only for production-related modules; administrative and accounting components remain excluded.
- Industrial HVAC systems, when they are functional to maintaining the required environmental conditions for production processes.
- Industrial analytics, AI, cybersecurity, and energy management platforms, provided they fall within the scope of Annex V and are interconnected with the relevant systems.
The common requirement across all these categories is twofold: documented technical interconnection and the capitalization of the software as an intangible asset on the balance sheet (such as a multi-year license, internally developed software, or a perpetual usage license).
The SaaS Issue: Why Subscription-Based Fees Remain Excluded
This point requires clarity, as conflicting information is circulating online and not all available sources are reliable.
The implementing decree signed by MIMIT on 7 May 2026, which became effective in mid-June with the opening of the GSE platform, excludes software delivered through the SaaS (Software as a Service) model with subscription-based fees. The technical rationale is straightforward: a SaaS subscription fee is considered an operating expense, not an intangible asset owned on a long-term basis by the company. It does not generate its own depreciation charges, meaning there is no depreciable tax base to which the enhanced depreciation allowance can be applied.
Furthermore, under the SaaS model, ownership of the infrastructure, technological risks, and software updates remain with the service provider. This is a key factor that the legislator considered incompatible with the underlying principles of the Super Depreciation scheme.
The preliminary drafts of the decree actually included a provision that would have extended the incentive to access fees, limited to the portion attributable to the relevant tax period. However, this provision was not included in the final version of the legislation.
There is, however, a development worth monitoring: in response to a parliamentary question before the Chamber of Deputies’ Productive Activities Committee, the Government opened the possibility of a corrective legislative measure, confirming that MIMIT and the Ministry of Economy and Finance (MEF) are evaluating potential solutions to overcome the exclusion.
At present, however, this remains a political statement rather than an enacted provision. Until an explicit amendment is introduced, SaaS subscription fees remain outside the scope of the incentive.
What Can a Company Using Subscription-Based Software Do?
If your company has already planned investments in SaaS software, it is advisable to:
- Separate costs: distinguish between items that are clearly eligible (capitalizable modules, licenses, and internally developed software) and subscription fees that remain subject to regulatory uncertainty.
- Assess with your tax advisor whether part of the software investment can be capitalized, for example through multi-year licenses instead of recurring subscription fees.
- Do not postpone investments while waiting for a potential regulatory amendment: ERP production modules, SCADA/HMI/PLC systems, and AI platforms structured as capitalizable intangible assets remain fully eligible for the incentive under the current rules.
- Monitor regulatory developments closely, as any potential extension of the incentive to cloud subscription fees would have a significant impact, given how widespread the SaaS model has become in industrial digitalization.
Documentation Requirements and Compliance Obligations
The 2026 scheme introduces stricter control procedures compared with previous versions of the Super Depreciation incentive:
- Mandatory sworn technical assessment for all investments, regardless of value — the previous €300,000 threshold, below which a self-certification by the company’s legal representative was sufficient, has been removed. The technical assessment must be issued by a qualified engineer, industrial expert, or accredited certification body (for the agricultural sector, it may also be issued by agricultural engineers or agricultural experts).
- Accounting certification confirming that the expenses were actually incurred and that they match the relevant accounting documentation.
- Five mandatory communications to the GSE throughout the entire process: from the initial reservation of available funds to the final reporting stage, including annual periodic communications (by 20 January) and supplementary communications (by 30 June).
- Requirement to keep the asset in Italy for the entire tax depreciation period, generally six years: early disposal or relocation abroad results in the loss of the incentive and the recovery of the tax deductions already claimed.
Compatibility with Other Incentives
The Super Depreciation scheme cannot be combined with the Industry 4.0 and Transition 5.0 tax credits for the same costs. However, it is compatible with other incentives as long as there is no duplication of the benefit, such as the New Sabatini scheme for financing capital goods or the Single ZES tax credit for companies operating in Southern Italy.
For manufacturing SMEs in Southern Italy, combining multiple incentives on the same investment may result in an overall benefit exceeding 100% of the net cost of the investment.
How to Access the Incentive
The entire process is digitalized and managed through the GSE platform, which has been active since 12 June 2026 (currently only for the ex ante preliminary notification; the section for the confirmation notification relating to the advance payment will be activated at a later stage):
- Access to the GSE platform through SPID or CIE credentials
- Ex ante notification for the reservation of available funds
- Confirmation notification with the advance payment
- Investment completion notification
- Annual periodic notifications until the end of the depreciation period
An operational circular from the Ministry providing further clarifications and FAQs is expected in July 2026.
Super Depreciation in Summary
The 2026 Super Depreciation scheme represents a concrete opportunity for manufacturing companies investing in digital transformation, but it requires careful classification of investments. Capitalizable software modules, interconnected production systems, and Annex V platforms currently remain the most reliable investment categories to qualify for the incentive.
SaaS subscription fees are still excluded for the time being, but this is an area that should be closely monitored in the coming months.
Would you like to understand which of your digitalization investments qualify for the 2026 Super Depreciation scheme? The AzzurroDigitale team can help you assess your specific case and structure your investment in the most effective way.
Regulatory sources: Law No. 199 of 30 December 2025 (2026 Budget Law), Article 1, paragraphs 427–436; Decree-Law No. 38 of 27 March 2026; MIMIT-MEF implementing decree of 7 May 2026; Director’s Decree of 10 June 2026.
FAQ – Frequently Asked Questions about Super Depreciation
Is SaaS software eligible under the 2026 Super Depreciation scheme?
No. The MIMIT-MEF implementing decree of 7 May 2026 excludes subscription-based SaaS fees, as they are considered operating expenses rather than capitalizable intangible assets.
Software acquired through traditional licenses, internally developed software, or on-premise installations remains eligible, provided that it is capitalized as an intangible asset on the company’s balance sheet.
What is the maximum enhanced depreciation rate available under the 2026 Super Depreciation scheme?
The enhanced depreciation rate reaches up to 180% for investments of up to €2.5 million, decreases to 100% for the portion between €2.5 million and €10 million, and to 50% for the portion between €10 million and €20 million.
Which software qualifies for the 2026 Super Depreciation scheme?
Software listed in Annex V qualifies when it is capitalized and interconnected with the company’s systems. Eligible categories include PLC, SCADA, and HMI systems; production-related ERP modules (excluding administrative and accounting components); and artificial intelligence, cybersecurity, and industrial analytics platforms that support digital transformation.
Can the 2026 Super Depreciation scheme be combined with other incentives?
It cannot be combined with the Industry 4.0 and Transition 5.0 tax credits for the same costs. However, it is compatible with other incentives, such as the New Sabatini scheme and the Single ZES tax credit, provided that there is no duplication of benefits on the same expenditure.
Could the exclusion of SaaS software change?
It is possible. In response to a parliamentary question, the Government opened the possibility of evaluating a regulatory amendment to include cloud subscription fees, with MIMIT and MEF working on the matter.
At present, however, this remains a political statement rather than an effective legal provision. Companies cannot yet rely on this possibility when planning their investments.