Italy Supreme Court rules on INPS sanction reductions

The Italian Supreme Court's United Sections (Sezioni Unite) have clarified the requirements for reducing sanctions on social security contributions under Law 388/2000. According to ruling no. 12155 of 2026, the reduction of sanctions for contributions resulting from objective interpretative uncertainty is only applicable if the payment is made within the deadline set by the National Institute for Social Security (INPS).

Even if legal uncertainty regarding the obligation to pay persists, taxpayers must settle the debt within the prescribed timeframe to benefit from the reduced penalty regime. Those who delay payment lose the right to the reduction, regardless of the complexity of the legal interpretation involved. This ruling overturns a previous decision by the Court of Appeal of Bologna.