INDUSTRIES, ENERGY | Simplified Provisions on the Cumulation of Photovoltaic Energy Incentives enacted

Law No. 182 of 2 December 2025 introduces an extraordinary option for taxpayers owning photovoltaic systems who have not already made use of the facilitated settlement provided for in Article 36 of Law Decree Law No. 124/2019, allowing them to retain the incentive rates under the Conto Energia by submitting a specific application to the Energy Services Operator (GSE) within sixty days from the date of entry into force.

By submitting the application, the applicant agrees that the incentive rates will be subject to compensation equal to the amount of tax benefit received and a 5% reduction of the incentive for the entire duration of the agreement. The procedure also applies to pending tax and administrative proceedings, which are suspended pending compensation. The termination of such proceedings requires full compensation of the amounts due, acceptance of the reduction, and payment in cash of any differences not absorbed by the incentives. The Energy Services Operator (GSE) must certify compliance with these conditions in order to allow the termination of the proceedings and may indicate the failure to complete the settlement. Once the correct application of the compensations and reductions has been verified, the judge proceeds to declare the case closed with compensation of legal costs.

Newsletter n. 113 – December 2025