Italy shifts R&D tax credit system to ministerial certification

Disputes between Italian companies and the Agenzia delle Entrate over research and development (R&D) tax credits have intensified, with thousands of firms forced to repay amounts up to three times the original credit. In 2023, R&D investments reached €29.4 billion, a 7.7 % rise from the previous year, but the self‑certification model proved inadequate.

A new preventive ministerial certification, operational since 2023, replaces company self‑declarations with third‑party verification by accredited bodies. Certified projects rose to a record 6,577 in 2025, of which 2,600 were already certified, indicating strong corporate confidence. Riccardo Petricca, an accredited MIMIT certifier, explained that the system now “structures projects with defined questions and continuous interaction between certifier and company.”

The reforms coincide with the EU AI Act’s 2024 rollout and the NIS2 cybersecurity directive, which together raise compliance and governance demands for Italian firms.