Italian Electricity Workshop: Declarant Figures, ADM Licences and Filing Obligations

7 min read

In Italy, every operator who produces, distributes or consumes electricity above the 20 kW threshold must register an officina elettrica (electricity workshop) with the ADM and file periodic AD-1 consumption declarations. The specific obligations - which ADM licence is required, which quadri of the AD-1 form must be completed, and whether excise tax is due - depend on the operator's declarant figure (figura dichiarante) under Arts. 52-54 of the Testo Unico delle Accise (TUA).

This guide covers the 8 declarant figures recognised by the ADM, the corresponding licence types, and the AD-1 quadri each figure must complete.

The 8 declarant figures at a glance

FigureDescriptionExcise due?Key quadri
1Exempt renewable producer (PV/wind/hydro, own use, ≤20 kW)NoNone (no AD-1 required)
2Exempt renewable producer (>20 kW, feeds grid, no own use)NoA, H
3Excise-liable producer (any source, own use or sales)YesA, B, E
4Purchaser for own use (buys from grid, self-consumes)YesB, C, E
5Purchaser for resale / distributorYes (on sales)C, G, E
6Mixed-use purchaser (own use + resale)YesB, C, G, E
7BESS operator (storage system)Depends on useI, B or G, E
8RIU operator (internal distribution network)YesL, B, E

Figure 1 - Exempt small renewable producer

Photovoltaic, wind or hydroelectric plants with nominal power at or below 20 kW, whose entire production is self-consumed by the producer (no grid injection beyond net metering), are fully exempt from electricity excise under Art. 52(3) TUA. No electricity workshop registration is required and no AD-1 must be filed.

This is the most common situation for domestic rooftop solar installations in Italy. The 20 kW threshold refers to nominal (nameplate) power, not actual production.

Figure 2 - Exempt larger renewable producer (grid injection)

Renewable producers above 20 kW whose electricity is entirely (or predominantly) fed into the national grid and not consumed on site. The production is exempt from excise because no taxable consumption occurs at the plant. However, an electricity workshop licence is required and AD-1 quadri A (production) and H (exempt quantities injected) must be filed.

Figure 3 - Excise-liable producer

Any electricity producer above 20 kW who consumes part or all of their own production on site, or sells it directly without going through a licensed distributor. This covers:

  • Commercial photovoltaic plants with self-consumption
  • Cogeneration (CHP) units
  • Diesel generators used as primary or backup power
  • Renewable energy communities (CER) producing for member consumption

Required quadri: A (production), B (own consumption by use type), E (excise calculation). An ADM production licence (licenza di officina) is required.

Figure 4 - Purchaser for own use

An operator who purchases electricity from the grid (via a licensed supplier) and consumes it entirely for their own use, without reselling to third parties. This is typical for large industrial consumers who purchase directly from the wholesale market or through interruptible supply contracts.

Required quadri: B (consumption), C (purchases), E (excise). An ADM consumption licence (licenza di utenza) is required.

Figure 5 - Purchaser for resale (distributor)

Electricity distributors and resellers who purchase from the grid or a producer and sell to end consumers. The excise obligation falls on the final sale to the end consumer - the distributor collects and remits excise on behalf of their customers.

Required quadri: C (purchases), G (sales by use type and territory), E (excise). An ADM distribution licence is required.

Figure 6 - Mixed-use purchaser

An operator who both consumes electricity for their own use and resells a portion to other parties (e.g., an industrial site that also supplies electricity to tenant businesses within the same premises). Both own-use and resale components must be declared separately.

Required quadri: B, C, G, E. This is the most complex figure and often requires careful metering to separate own-use from resale flows.

Figure 7 - BESS operator

Battery energy storage system (BESS) operators face a specific treatment under D.Lgs. 43/2025: electricity charged into the battery is not taxable at the point of charge, but is taxable when discharged for consumption or sale. The net charge/discharge balance over the declaration period determines excise liability.

Required quadri: I (storage data), plus B or G depending on whether the discharged electricity is self-consumed or sold, plus E (excise calculation).

Figure 8 - RIU operator

Operators of reti interne di utenza (RIU - internal user networks): private electricity distribution networks within industrial sites, business parks or similar enclosed areas that supply multiple users from a single connection point. The RIU operator is responsible for the excise on all electricity consumed within the network.

Required quadri: L (network data), B (consumption), E (excise). RIU operators require a specific ADM registration and are subject to additional metering obligations to track consumption by individual user within the network.

Identifying your declarant figure

The correct declarant figure is determined by the combination of:

  1. Plant type: production, distribution, storage, network
  2. Nominal power: above or below 20 kW threshold
  3. Energy source: renewable vs. non-renewable (affects exemption eligibility)
  4. End use: own consumption, resale to third parties, or mixed
  5. Grid injection: whether surplus is fed into the national grid

If your plant characteristics changed during the reference period (e.g., you added a BESS or began selling surplus energy), you may need to file under a different or combined figure. Deklara's wizard guides you through figure selection based on your answers and automatically loads the correct set of quadri for your AD-1.

Share


The 2026 semi-annual declarations are approaching.

Built for the 2026 reform.Privacy policy
  • GDPR Art. 28 compliant
  • D.Lgs. 43/2025 2026 deadlines
  • AES-256 encrypted at rest