D.Lgs. 43/2025: Complete Guide to Italy's Electricity Excise Reform 2026

Legislative Decree 14 March 2025, no. 43has fundamentally reformed the Testo Unico delle Accise (D.Lgs. 504/1995), Italy's consolidated excise tax code. For electricity workshop operators, the operational changes take effect from 1 January 2026 and were detailed by the DM 10 March 2026 (Official Gazette no. 66, 20/03/2026). In brief: AD-1 declarations shift from annual to semi-annual submission (deadlines: end of September for H1, end of March for H2); the fixed advance payment system is replaced by monthly payments on actual quantities consumed or invoiced in the prior month; the security bond is set at 15% of the estimated annual excise; a new status of Accredited Operator (SOAC) is introduced with bond reductions of up to 100%. The 20 kW exemption threshold for renewable-source production remains unchanged.

Update - DM 10 March 2026. The implementing decree was published on 20 March 2026 in Gazzetta Ufficialeno. 66. For an article-by-article walkthrough (plant declaration, monthly down-payments, semi-annual AD-1, 15% bond, monthly sellers' reports) see DM 10 March 2026: Italy's Electricity Excise Implementing Decree.

Why this reform matters

Reform 43/2025 is the most significant change to Italian electricity excise since 1995, when the TUA was first enacted. The temporal structure of obligations changes, the payment calculation mechanism changes, and the formal categories of obligated operators change. Anyone operating an electricity workshop - whether a commercial photovoltaic plant, a renewable energy community (CER) or a self-producer - must revise their internal processes before the first semi-annual deadline on 30 September 2026.

Change 1: Semi-annual instead of annual declarations

The AD-1 declaration was previously annual: one document covering the entire calendar year, due to the ADM by 31 March of the following year. From 2026, every electricity workshop files two declarations per year:

The volume of obligations doubles. The H1 deadline falls in mid-summer: operators without automated reminders risk missing it. In practice, a meter reading on 30 June is required each year to close the first half-year data - in addition to the standard year-end reading.

Change 2: Monthly payments on actual quantities

This is the most operationally significant change. Before the reform, obligated operators paid fixed monthly advance instalmentscalculated on the prior year's tax liability, with a final year-end adjustment. The new system is the reverse: each month, excise is paid on actual quantities from the prior month:

• Sellers: excise on quantities invoiced to end consumers in the prior calendar month, by supply territory.
• Self-consumers (electricity workshops with own-use consumption): excise on quantities consumed for own use in the prior month.
• Seller-self-consumers: sum of both above criteria.

Payment is due by the end of the reference month (no longer by the 16th). For January 2026 a transitional rule applies: the advance payment equals the December 2025 instalment calculated under the old method. In practice, Quadro P (advance payments) in the AD-1 form becomes obsolete: there are no longer advance payments to declare since the monthly payment is already based on real data.

Change 3: Bond equal to 15% of estimated annual excise

The security bond (guarantee to the ADM) is redefined by DM 10 March 2026 (Art. 10): it must equal 15% of the estimated annual excise, calculated on the basis of the data declared in the operating notice. It is then subject to quarterly recalculation.

For operators already active at 31 December 2025, the bond adjustment takes effect from 1 April 2026 (Art. 22(1) DM 10/03/2026). This may require renegotiating with your bank or insurance company if the existing bond was calculated under the old method.

Change 4: Accredited Operator status (SOAC)

D.Lgs. 43/2025 introduces, in Arts. 9-ter to 9-octies TUA, the status of Accredited Operator (SOAC): a trusted operator with simplified procedures and bond reductions. For electricity and natural gas, the designation is SOAC-GE. Three reliability tiers are provided:

The implementing decree regulating SOAC accreditation modalities (Art. 9-octies TUA) had not been published as of early 2026; until it enters into force, the SOAC system is not operational.

What stays unchanged

• Exemption threshold: 20 kW nominal power for renewable-source production. Photovoltaic, hydro and wind installations below this threshold, whose energy is consumed by the producer, remain exempt from excise and do not need to file an AD-1.
• Excise rates: National rates and the regional surcharge are not changed by the reform. Rates under Art. 52 TUA remain unchanged.
• Submission channels: S2S (System to System) and U2S (User to System) remain the two electronic submission channels to the ADM.
• Penalties: The penalty regime (Arts. 50-59 TUA) has no material changes. Failure to file the declaration is penalised at 100%-200% of the tax due, minimum €500.

Practical checklist for electricity workshop operators

The first semi-annual deadline is 30 September 2026 (H1 2026). Recommended steps:

1. Review your declarant figure under updated Arts. 52-54 TUA. Plant type, rated power, energy use and presence of storage (BESS) or RIU determine the mandatory AD-1 quadri.
2. Renegotiate the security bond with your bank or insurer and adjust to 15% of estimated annual excise (if not already done by April 2026).
3. Set up monthly consumption tracking: monthly payments require knowing monthly consumed (or invoiced) quantities. Annual meter reading is no longer sufficient.
4. Schedule a meter reading for 30 June 2026 to close the H1 data.
5. Update or replace your compliance software with a solution that supports the semi-annual structure, monthly payments and the new ADM technical specifications.
6. Set automatic reminders for the two recurring deadlines: 30 September (H1) and 31 March (H2).

Legal sources

• D.Lgs. 14 March 2025, no. 43 - Testo Unico Accise reform
• ADM Circular 13/2025 (13 June 2025) - first operational guidance
• ADM Circular 32/2025 (December 2025) - new use types, AD-1/AD-2 2025 guidance, 15% bond
• ADM Circular 34/2025 (December 2025) - 2025 declaration filing instructions
• DM 10 March 2026 - Official Gazette Series Generale no. 66, 20/03/2026 (Prot. 26A01335)
• Det. ADM 213396, 8 April 2026 - updated monthly report forms