Italian courts set rules for condominium debt recovery and private pool approvals

Italian legal rulings clarify that a contractor seeking unpaid fees from a condominium must first obtain an enforceable title against the condominium as a whole before pursuing individual owners. The Napoli Court, in decision 7492/2026, rejected attempts to bypass this two‑step procedure, confirming the administrator’s role as the building’s representative.

Separate judgments concerning private pools in exclusive garden areas hold that an assembly may authorize such works only when the project is properly listed on the agenda, complies with decoro and the condominium’s bylaws, and receives any required architectural committee approval. Recent rulings from the Tribunale di Savona (sentenza 254/2026) and the Tribunale di Tempio Pausania (sentenza 249/2026) outline these conditions.