Hyper-depreciation 2026 in Italy: software and ERP rules for SMEs

Italy’s 2026 hyper-depreciation (iperammortamento) raises the tax-deductible cost of new capital goods, software included, by up to 180%, for investments made from 1 January 2026 to 30 September 2028. For an SME, one detail matters: the scheme covers the “4.0” software listed in Annex V (Allegato V), bought and depreciated, and interconnected with production. SaaS subscriptions are left out, because neither the law nor the implementing decree (decreto attuativo) provides for them. Before you sign an order, check whether the ERP system you have in mind really qualifies.

Hyper-depreciation 2026: what it is

The 2026 hyper-depreciation is an uplift on the purchase cost of new capital goods. The uplift only counts when calculating the depreciation allowances and lease payments that are deductible for income tax purposes.

The legal basis is the 2026 Budget Law (Legge di bilancio 2026), namely Law no. 199 of 30 December 2025, Article 1, paragraphs 427-436. The Ministry of Enterprises and Made in Italy (MIMIT) presents it as the “New Transition 5.0 Plan – Hyper-depreciation” (Nuovo Piano Transizione 5.0 – Iperammortamento).

If you are considering a new ERP system for your company, the incentive can lower the net cost of the project. The saving only arrives as lower tax over the depreciation years, though, not as an upfront grant.

Under Article 4 of the implementing decree, the uplift applies from the tax period in which the company sends the GSE its completion notice (comunicazione di completamento). The asset must have entered into service in that same period, and the GSE’s checks must have a positive outcome.

Rates and timeframe

According to the MIMIT page and the summary by FiscoOggi, the magazine of the Italian Revenue Agency (Agenzia delle Entrate), the uplift is tiered.

Investments must be completed between 1 January 2026 and 30 September 2028. Completion follows the rules of Article 109 of Italy’s consolidated income tax code (TUIR), as the implementing decree specifies. The final notice to the GSE must be sent by 15 November 2028.

A worked example

Take a company that spends €100,000 on interconnected production planning software and capitalises it. The example is simplified and only meant to show how the mechanism works.

The saving is spread across the depreciation years and needs enough taxable income to absorb it. The uplift does not count for regional business tax (IRAP). Appraisal and certification costs reduce the net benefit.

Paragraph 431 rules out the uplift for investments that benefit from the Transition 4.0 tax credit (credito d’imposta Transizione 4.0) under Article 1, paragraph 446, of Law 207/2024. It can, however, be combined with other national and EU incentives on the same costs, on two conditions. The support must not cover the same portions of cost, and it must not exceed the cost incurred. The calculation base is taken net of any other grants received for the same costs.

Which software and ERP systems qualify

Software qualifies if it is a new intangible asset listed in Annex V of Law 199/2025. Annex V follows the approach of the old Annex B (Allegato B) of the Industry 4.0 plan, with new items such as generative artificial intelligence, AI agents and low-code platforms. It is published in Ordinary Supplement no. 42 to the Official Journal (Gazzetta Ufficiale) of 30 December 2025.

The items include software for managing and coordinating production, with a high level of integration of service activities such as logistics. Simulation, plant monitoring, artificial intelligence and cybersecurity are also listed.

Annex V mentions cloud computing among the eligible technologies, for example in points d) and m). That does not make the subscription fee eligible: the uplift only applies to an asset that is bought and depreciated.

The deciding requirement: interconnection

The asset must be interconnected with the company’s production management system or with the supply network. The law requires it, and Article 3 of the implementing decree repeats it.

In practice, an ERP with production, planning, warehouse and traceability modules is more likely to qualify. A purely accounting or administrative module is harder to fit under the Annex V items. The final assessment is up to the appraiser.

For manufacturers, we describe a typical path on our page about ERP for manufacturing SMEs.

Licence, custom development or subscription

Watch out for “on-premise” licences sold as an annual subscription. The name is not enough: what counts is how the cost is booked. Ask your accountant whether the expense will be capitalised or recorded as an operating cost.

Why SaaS is excluded

Paragraph 427 of the law limits the uplift to depreciation allowances and finance lease payments. A SaaS subscription is a service cost, so there is no depreciation to apply the uplift to.

The final text of the interministerial decree of 7 May 2026 contains no rules on fees for cloud software. The text makes no reference to the cloud or to SaaS.

The Council of Ministers (Consiglio dei ministri) press release no. 195 of 28 October 2026 on the 2027 budget announces “funding for cloud computing” (finanziamenti per il cloud computing).

The release does not say what form this funding will take or for which years, and it says nothing about extending the hyper-depreciation. The 2027 Budget Bill (A.C. 3174, presented to the Chamber of Deputies on 30 October 2026) is being debated in Parliament, so the measures need to be checked against the text that is finally approved. Until then, do not budget for a SaaS subscription as if it qualified, and keep working to the 30 September 2028 deadline.

How to apply: the notices to the GSE

The implementing decree puts the GSE in charge of the scheme. All notices go through the Client Area (Area Clienti) of the GSE website, which you log in to with SPID or CIE, the Italian digital identity credentials.

1. Advance notice (comunicazione preventiva): states the production site, the assets, the amounts and the expected interconnection date.
2. Confirmation notice (comunicazione di conferma): within 60 days of a positive outcome, after paying a deposit of at least 20% of the cost.
3. Completion notice: once the investment is complete and the asset is interconnected, by 15 November 2028.

On top of these come periodic notices: by 20 January each year, on the investments and the expected use of the benefit, and by 30 June, with the depreciation schedule. This is set out in Article 3, paragraph 6, of the implementing decree.

The window for completion notices has been open since 15 October 2026, as laid down by the directorial decree (decreto direttoriale) of 14 October 2026.

Technical appraisal and accounting certification

Article 6 of the decree requires a sworn appraisal by an engineer or industrial technical expert (perito industriale) registered with their professional body, or a certificate from an accredited certification body. The appraisal proves the technical features and the interconnection.

Article 7 requires an accounting certification of the expenses, issued by a statutory auditor (revisore legale). Put these costs in the budget from the start.

What to prepare before choosing your ERP

An ERP project takes months. If you want to use the incentive, plan the project with the appraisal in mind from the outset.

• Process map: which departments and machines the ERP will need to connect.
• Architecture: on-premise installation or a dedicated server, or a SaaS service, which the measure excludes.
• Documented interconnection: data exchanges with machines, the warehouse or suppliers, described in a way that can be verified.
• Clear contracts: licences, custom development and services invoiced as separate lines, to make the appraisal easier.
• Schedule: 20% deposit, acceptance testing and interconnection by 30 September 2028.

If you choose Odoo, keep the cost items separate. An Odoo Enterprise subscription is a fee and should be assessed as one. Custom module development and integration with machines, on the other hand, can be capitalised. We cover this on our page about Odoo implementation and integration.

The server can be your own or managed by us. The options are described in our managed VPS servers service. For an overview of production modules, read our guide to management software for manufacturing.

Frequently asked questions

Does the 2026 hyper-depreciation apply to ERP and management software?

Yes, if the software is new, listed in Annex V of Law 199/2025 and interconnected with production or the supply network. Purely administrative software is harder to bring within the scheme.

Does a SaaS subscription qualify for the hyper-depreciation?

No, as things stand. The implementing decree of 7 May 2026 did not include fees for “as a service” software. The 2027 Budget Bill announces funding for the cloud, but it is still being debated in Parliament.

How long can the 2026 hyper-depreciation be used?

Investments must be completed by 30 September 2028. The completion notice must be sent to the GSE by 15 November 2028.

Is an appraisal needed even for low-cost software?

The implementing decree requires the sworn appraisal, or a certificate from an accredited body, to prove the features and the interconnection. The text sets no exemption threshold.

Does custom software development qualify?

It can, if the cost is capitalised and the result is listed in Annex V and interconnected. The appraiser and your accountant need to confirm it case by case.

About the author. Team URETECH: developers and consultants who design and integrate ERP systems, custom software and automations for SMEs. About us and how we work.