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. 56-bis TUA), because the tax is applied downstream by the seller to the end customer. A reduced power plant notice and an 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. That is a one-off transitional duty, not a recurring deadline. New total-grid-injection plants starting up after 1 January 2026 follow the ordinary regime instead: the notice goes in beforehand, ahead of the start of operations (Art. 53-bis c.1 TUA). The 30-day deadline applies only to changes at an existing plant, to changes in ownership, and to cessation.

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

A reduced set: Quadro A (production meter readings), Quadro G (outflows by type, which is where grid injection sits), and the suppliers list (GSE and trader counterparties). The consumption and settlement quadri are excluded, because there is no self-consumption and no excise to settle when the producer is not a final-consumption taxpayer. Plant identification is not in Quadro A at all: location and capacity in kW are declared in the power plant notice itself (art. 2 DM 10 March 2026).

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

Q: Does a total-grid-injection producer file the semi-annual declaration?

No. Circular 9/D of May 7, 2026 from the Italian Customs Agency (ADM) expressly excludes the parties named in Art. 56-bis TUA from the new semi-annual declarations, because they do not qualify as soggetti obbligati. A total-grid-injection producer therefore stays on the annual flow declaration: the one covering tax year 2026 is due by March 31, 2027. The semi-annual deadlines of September 30 and March 31 do not apply to it.

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. 56-bis 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 an AD-1 flow declaration. That declaration is annual, not semi-annual: ADM Circular 9/D of May 7, 2026 keeps parties outside the soggetti obbligati perimeter off the new semi-annual filings, and the next deadline for tax year 2026 is March 31, 2027. For 2026 there is one further, one-off 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 starting up in 2026 follow the ordinary regime and file the notice beforehand, ahead of the start of operations (Art. 53-bis c.1 TUA). 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. 56-bis TUA)

Art. 56-bis TUA, in the wording that applies after the D.Lgs. 43/2025 reform, covers the non-liable parties: producers that inject their entire output into the grid, and parties that transport or distribute electricity. The first group is the one at issue here, namely 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 an 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. 56-bis TUA. 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).

Filing frequency: annual, not semi-annual

This is where most operators get it wrong. D.Lgs. 43/2025 introduced the semi-annual declaration, but not for everyone. ADM Circular 9/D of May 7, 2026 (prot. 263885) states that the parties named in Art. 26-quater and Art. 56-bis TUA are not required to file the new semi-annual declarations, because they do not qualify as soggetti obbligati. A total-grid-injection producer therefore stays on the annual flow declaration.

Category	Frequency	Next deadline
Soggetto obbligato (seller, own use, renewable plant above 20 kW with self-consumption)	Semi-annual	H1 by end September, H2 by end March
Soggetto obbligato a canone (flat annual fee)	Excluded from the semi-annual filing	Annual fee, paid January 1 to 31
Total grid injection (Art. 56-bis TUA)	Annual	March 31, 2027 (tax year 2026)
Renewable plant of 20 kW or less, own use (outside the excise scope)	Simplified annual notice	By end March

Do not conflate the two March dates. 31 March 2026 is the one-off transitional notice under Art. 22 c.5 DM 10 March 2026, owed only by plants already active. March 31, 2027 is the first deadline of the ordinary annual declaration. September 30, 2026 and March 31, 2027 as semi-annual deadlines do not concern a total-grid-injection producer.

Required AD-1 quadri (reduced set)

A total-grid-injection producer files the 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 - Production	Readings from the fiscal production meters: serial number, current and previous reading, difference, reading constant, kWh, plus the total.
G - Outflows by type	The energy leaving the plant, under the destination code that matches the transfer. For total grid injection this is where the whole output is reported.
Suppliers list	Counterparties to the transfer contracts: GSE, trader, and any ESCo acting as intermediary.

Excluded: quadri B, C, E and H (the other measurement and inflow quadri, none of which applies without purchases or own consumption), J, L and M (consumption by tax status, because nothing is consumed at the plant), and P and Q (settlement and balance, since there is no excise to settle). The plant's own details - location, source, capacity in kW, injection POD - are not in any quadro: they belong to the power plant notice itself (art. 2 DM 10 March 2026), and the declarant is identified in the cover sheet (frontespizio).

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. 56-bis 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. Then plan the annual flow declaration for tax year 2026, due by March 31, 2027, not the September 30 semi-annual filing, which does not apply to you.

Common errors and grey areas

Filing the semi-annual declaration by mistake: read the reform without Circular 9/D of May 7, 2026 and you end up on the semi-annual calendar, panicking about September 30. A non-liable party under Art. 56-bis TUA is not in that perimeter. Its deadline is annual: March 31, 2027.
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 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.