What does total grid injection mean under Italian excise law?

It means running a power plant that feeds 100% of its output into the grid, with no self-consumption share. For excise purposes the producer is classified as a 'non-liable party' (Art. 53-bis c.1 TUA), because the tax is applied downstream by the seller to the end customer. A reduced power plant notice and a semi-annual AD-1 flow declaration are still mandatory.

Why does a total-grid-injection producer not pay excise?

Electricity excise applies to final consumption (Art. 52 c.1 TUA). A producer that transfers all output to the GSE (under dedicated take-off, scambio sul posto, or residual conto energia) or to an open-market trader does not consume directly. The tax liability shifts to the market seller, which bills the end customer and pays the excise. The total-grid-injection producer still has formal registration and flow-reporting duties.

By when must the new power plant notice be filed?

Art. 22 c.5 DM 10 March 2026 (G.U. no. 66 of 20/03/2026) requires total-grid-injection operators already active on 31/12/2025 to submit a confirming power plant notice by 31 March 2026. New total-grid-injection plants commissioned after 1 January 2026 must file within 30 days of commissioning (ordinary Art. 53-bis c.1 regime).

Which AD-1 quadri must a full-injection producer file?

A reduced set: Quadro A (plant identification), Quadro G (excise calculation, always zero), and the Suppliers list (GSE and trader counterparties). Quadri C, E, H, and I are excluded, because they cover paid transfers and self-consumption that do not apply when the producer is not a final-consumption taxpayer.

Is a surety bond required for total grid injection?

No. Art. 10 DM 10 March 2026 limits the bond obligation to parties liable for excise payment. Since a total-grid-injection producer is not liable, no bond is required. Any existing guarantee can be released on request to the competent local ADM office.

What happens if I start even a small amount of self-consumption?

Starting any self-consumption (for example, plant auxiliaries no longer drawn from the grid, internal EV charging points, or electricity for management offices) automatically terminates the total-grid-injection status. The operator reverts to a self-producer or liable party under Art. 53 c.2 lett. a TUA. You must file a change notice with ADM within 30 days and recalculate the 15% bond on the taxable share.

Can I be in total grid injection and also use scambio sul posto?

No. Scambio sul posto involves a clear gap between injected and withdrawn energy, with a share consumed instantly or netted monthly. Any net self-consumption, however small, rules out the total-grid-injection category. A producer under scambio sul posto is a self-producer under Art. 53 c.2 lett. a, not a total-grid-injection operator.

AD-1 Total Grid Injection in Italy: Full Feed-In Producers and the New 2026 Notice

Total grid injection (Italian: cessione totale or immissione integrale) describes a producer that feeds 100% of its electricity into the grid, with no self-consumption share. Under excise law it is governed by Art. 53-bis c.1 TUA: the producer is classified as a non-liable party for excise, because the tax falls on final consumption and is applied downstream by the seller. The producer is still required to file a reduced power plant notice and a semi-annual AD-1 flow declaration. For 2026 there is one critical milestone: Art. 22 c.5 DM 10 March 2026 requires total-grid-injection operators already active on 31/12/2025 to file a confirming notice by 31 March 2026. New plants commissioned in 2026 follow the ordinary 30-day post-commissioning rule. No 15% bond is due, but even a single kWh of self-consumption ends this status and triggers reclassification as a self-producer under Art. 53 c.2 lett. a.

What total grid injection is (Art. 53-bis c.1 TUA)

Art. 53-bis c.1 TUA, introduced by D.Lgs. 43/2025, formalizes a category that until 2025 was only addressed through ADM interpretation: the producer that transfers all output to the GSE, to an open-market trader, or to an end customer via a seller, without keeping any self-consumption share. Three traits define the category:

Zero self-consumption: plant auxiliaries (inverter supply, control systems, monitoring) must be powered from the grid or from a separate circuit. No share of net output (gross output minus auxiliaries) can be consumed on site.
Documented full transfer: the relationship with the GSE (dedicated take-off, scambio sul posto in its exclusive form, or residual conto energia) or with an open-market trader must be set out in a signed contract. Informal transfer without a contract is not enough.
Non-liable for excise: the tax is applied by the seller to the end customer, not by the producer. The producer is still required to file the power plant notice and report flows on a semi-annual basis.

Critical deadline: 31 March 2026 (DM 10/03/2026 Art. 22 c.5)

Art. 22 c.5 of the implementing decree requires total-grid-injection operators already active on 31/12/2025 to file a confirming notice by 31 March 2026. The notice aligns the ADM register with the new D.Lgs. 43/2025 classification. Today some operators appear in the register as exempt self-producers and others as sellers; the confirming notice locks in the total grid injection status under Art. 53-bis c.1. Consequences of failure:

Reclassification ex officio: ADM may assign the self-producer status, with the related bond and full declaration duties.
Recovery of past excise: in the worst case, ADM may attribute a presumed self-consumption share and recover unpaid excise for the 2021-2025 periods (within the assessment time limits).
Penalty: an administrative penalty of up to twice the recovered tax, plus interest at the legal rate (2% for 2025-2026).

Required AD-1 quadri (reduced set)

A total-grid-injection producer files the semi-annual AD-1 declaration as a pure flow statement. The set of quadri is reduced because there is no excise to settle:

Quadro	Content
A	Plant identification, generation source, capacity, injection POD, and active GSE or trader contracts.
G	Excise calculation, always zero, but required to formally close the declaration.
Suppliers list	Counterparties to the transfer contracts: GSE, trader, and any ESCo acting as intermediary.

Excluded: Quadro B (taxable net output, not applicable because the energy is transferred), Quadro C (paid transfers to third parties, replaced by the suppliers list), and Quadri E, H, I, L, P, Q (all irrelevant for a non-liable party).

How to file the confirming notice by 31 March 2026

Verify zero self-consumption: collect documentary evidence that 100% of the energy produced in 2025 was transferred. Plant auxiliaries must be powered from the grid or from a separate circuit.
Gather plant data: firm code, location, VAT number, capacity, generation source, fiscal meters, GSE or trader contracts, and POD.
Complete the confirming notice: use the AD-1 "denuncia" template with the flag "cessione totale art. 53-bis c.1 TUA". Attach the contracts and the plant layout.
Submit to ADM: use the PUDM or S2S telematic channel, signed with an XAdES-BES digital signature. Or file in person with the local office by 31 March 2026.
Keep the receipt and update the PoA: record the protocol number and date. Check the Sottoscrittore's special power of attorney. Plan the H1 2026 AD-1 by 30 September 2026.

Common errors and grey areas

Plant auxiliaries powered by the plant itself: many operators forget that inverters, monitoring systems, cooling fans, and cabinet lighting run on the plant's own output. Technically, that is self-consumption. To regularize, either separate those consumptions in fiscal accounting or reclassify as a self-producer.
Scambio sul posto confused with total grid injection: scambio sul posto always involves some net self-consumption, even if small. It is self-production, not total injection. This is a common error in small residential plants of 20 kW or less.
Trader change mid-year: switching the open-market trader does not affect total-grid-injection status, but the suppliers list must be updated in the next semi-annual AD-1.
Unreported status loss: any new self-consumption must be reported within 30 days. A late notice qualifies as unauthorized operation of the plant in its new category.
Forgotten bond on status change: when switching from total injection to self-producer, you must post the 15% bond on the taxable share within the quarter in which the change happens.