Skip to main content
    Legislation29 July 2026 · 7 min read

    Italy repealed the forfettario and re-enacted it unchanged

    Look up the forfettario on Italy's official law database today and thirty-six commi come back marked COMMA ABROGATO. The decree that strikes them out, published in July, also re-enacts the regime as articles 232 to 243 of a new income-tax code. Both take effect on 1 January 2027.

    In short
    • D.Lgs. 117/2026 repeals L. 190/2014 art. 1, commi 54–89 and re-enacts the regime as artt. 232–243 of the Testo unico delle imposte sui redditi. Both take effect on 1 January 2027.
    • Thirty-four of the thirty-six repealed commi are reproduced. The two that are not are 2015 switchover rules for taxpayers who were in the pre-2015 regimes.
    • All eighteen operative numbers — the €85,000 ceiling, the 15% and 5% rates, the €20,000, €30,000 and €100,000 limits, the five-year window, the three-year look-back, the 75% non-resident test and the nine coefficienti — carry the same value on both sides.
    • The coefficient table moves from Allegato 4 to Allegato D, still headed “Codici attività ATECO 2007”, and a separate 2025 decree that keeps the ATECO 2007 reading is folded in with it.
    • In folding that rule in, the new text addresses it to “i soggetti di cui all’articolo 276, comma 1” — an article about accounting-standard changes, not about forfettario taxpayers.

    Look up the flat-rate regime on Normattiva, Italy’s official database of law in force, and thirty-six consecutive commi come back reading COMMA ABROGATO DAL D.LGS. 19 GIUGNO 2026, N. 117.2 Repealed by a decree of 19 June 2026 — every rule of the regime, from the €85,000 ceiling to the contribution discount, struck through in the same line.

    The decree doing the striking is the Testo unico delle imposte sui redditi — a consolidation of Italy’s income-tax legislation into a single act, published in the Gazzetta Ufficiale on 3 July 2026 under the reorganisation mandate in the 2023 tax-reform delegation.13 The same act re-enacts the regime twelve articles later, as its Capo XXI. That is what a consolidation does, and it is why the strike-through is not the news it looks like.

    What is worth knowing is whether anything changed on the way across. Both texts are public, so the question has an answer rather than an opinion: of the eighteen numbers that decide what a forfettario pays, eighteen carry the same value in the text that replaces them.6

    What was actually repealed

    Article 376 of the new code lists the provisions it repeals, in a lettered run that reaches qqqq) before it gets to the flat tax: articolo 1, commi da 54 a 89 e 622, della legge 23 dicembre 2014, n. 190. The repeal takes effect dalla data di cui all’articolo 377, and article 377 sets that date once for the whole code: Le disposizioni del presente testo unico si applicano a decorrere dal 1° gennaio 2027.1

    Until then the 2014 commi are the law. The reason the database looks alarming is that it is already showing the later version: the article header on that page reads Testo in vigore dal: 1-1-2027, so a reader arriving today sees next year’s text unless they ask for a specific date. Both readings were used here — the 2027 text carries the repeal; the commi below are read at an explicit July 2026 date, while they are still in force.

    Where each comma went

    Each article of the new chapter prints, under its heading and in brackets, the provisions it reproduces. That makes the concordance a matter of reading rather than of judgement, and it accounts for thirty-four of the thirty-six repealed commi.5

    Figure 1Capo XXI of the testo unico, and the commi each article replaces
    New articleReplaces commiWhat it covers
    art. 23254–56Who can use the regime
    art. 23357Who cannot
    art. 23458–63VAT consequences
    art. 23564–68Taxable income and the tax on it
    art. 23669Bookkeeping and withholding relief
    art. 23770Opting into the ordinary regime
    art. 23871–72Leaving the regime
    art. 23973Reporting duties
    art. 24074–75Coordination with other rules
    art. 24176–84The contribution discount
    art. 24285, 88Older regimes that stay repealed
    art. 24389Implementing decrees

    Source notes printed under each article's rubric in D.Lgs. 117/2026, artt. 232–243, read from the consolidated text on Normattiva on 29 July 2026. Headings are summarised in English; the Italian rubriche are in the dataset.15

    The regime keeps its shape in the move. Access, exclusions, VAT, the taxable base, the paperwork relief, the contribution discount and the exit rules each become an article of their own, in the order the commi already ran. Six commi of VAT cross-references collapse into one article; nine commi of contribution rules collapse into another.

    The numbers that decide what you pay

    A concordance says the words moved. It does not say the values survived, and the values are the part a reader has money riding on. Nine thresholds, rates and periods run through the chapter, and the profitability coefficient — the share of revenue the regime taxes as though it were profit — is set by a nine-row table annexed to the act.

    Each of those eighteen was located on both sides by the wording around it rather than by its position, because the cross-references were all renumbered: where the 2014 commi point at the 1972 VAT decree and the 1986 income-tax code, the new articles point at the 2026 codes that replaced them.21 All eighteen match.

    Figure 2The regime's operative numbers, either side of the recodification
    ParameterL. 190/2014D.Lgs. 117/2026
    Revenue ceiling for access€85,000€85,000
    Limit on staff and accessory-work costs€20,000€20,000
    Employment income that bars access€30,000€30,000
    Revenue that ends the regime the same year€100,000€100,000
    Substitute tax rate15%15%
    Start-up rate5%5%
    Years at the start-up ratethe first, plus fourthe first, plus four
    Look-back on previous activitythree yearsthree years
    Italian-source income required of a non-resident75%75%

    Each value read from L. 190/2014 commi 54–89 as in force on 29 July 2026, and from D.Lgs. 117/2026 artt. 232–243. The nine coefficienti di redditività, compared separately against Allegato 4 and Allegato D, are the other nine rows of the dataset.6

    The coefficient table moves from Allegato 4 of the 2014 law to Allegato D of the code, and all nine groups keep both their percentage and the activity codes that reach them: 40% for food manufacture, trade and hospitality, 54% for street trade in non-food goods, 62% for trade intermediaries, 67% for the residual band, 78% for the professions, 86% for construction and real estate. The two annexes are typeset differently — the lines break in other places, and one separating hyphen is missing from the ninth group — so the code lists were compared as the sets of division numbers they name rather than as strings. On that basis they are the same table. Its column is still headed Codici attività ATECO 2007.

    The two rules left behind

    Two commi are reproduced nowhere: 86 and 87. Both open the same way — taxpayers who, in the tax period running at 31 December 2014, were using one of the schemes the forfettario replaced. Comma 86 moved them into the new regime; comma 87 let them use the 5% start-up rate for whatever remained of their five-year run. A five-year run that began no later than 2014 ended no later than 2019.2

    Comma 88 addresses the same population and is kept, as article 242. It lets those taxpayers stay in the old regime di vantaggio for the rest of their five years e comunque fino al compimento del trentacinquesimo anno di età — and until they turn thirty-five. Someone who was in their twenties in 2014 can still be inside that window. The one transitional rule the code carries forward is the one whose clock has not necessarily run out.

    One sentence points somewhere else

    One rule in the new chapter has no counterpart among the repealed commi. Since April 2025 Italian businesses carry ATECO 2025 activity codes, while the coefficient table names ATECO 2007 ones, and a corrective decree of June 2025 addressed the gap directly: until new coefficients are drawn up on the 2025 classification, the coefficient is found using il codice corrispondente all’attività esercitata under the 2007 one.4 The code folds that decree in as article 235, comma 6.

    The 2025 decree says who it is talking to: i soggetti di cui all’articolo 1, comma 54, della legge 23 dicembre 2014, n. 190 — the people who qualify for the regime. Comma 54 is now article 232, which is what article 235 cites in its own first comma. The consolidated sentence instead reads i soggetti di cui all’articolo 276, comma 1.1

    Article 276 of the code is headed Disciplina delle divergenze tra i valori contabili e fiscali emerse in sede di cambiamento dei principi contabili, and its first comma lists the cases it covers: first adoption of IAS/IFRS, changes to those standards, a move back to Italian standards, a company outgrowing its reporting bracket. None of them is a person with a partita IVA choosing a flat rate. As printed, the sentence that tells forfettari which classification to read their coefficient on identifies them by a provision about company accounts.

    What this does not settle

    This compares two texts. It does not describe practice: nothing here is a statement about how the Agenzia delle Entrate will apply the code, or about what happens to a filing that straddles the change of act.

    The comparison also stops at the chapter. Plenty of what a forfettario actually experiences sits outside it — the contribution rules the chapter only refers to, VAT, and above all the annual budget law, which has amended these numbers repeatedly and can amend them again for 2027 before the code ever applies them. A consolidation freezes the wording, not the policy.

    And the concordance rests in part on the source notes the code prints about itself. They are the drafter’s account of provenance; here they were checked against the text on both sides, and the commi they leave out were matched against every new article by word overlap before being called dropped. The full mapping and the parameter comparison are below, so the reading can be disagreed with on the evidence.

    Download the concordance (CSV, 36 rows)Every repealed comma of L. 190/2014 art. 1, the article of D.Lgs. 117/2026 that reproduces it, how the link was established, and its opening words.Download the parameter comparison (CSV, 18 rows)The nine thresholds, rates and periods plus the nine statutory coefficienti, each read off both texts and compared value by value.
    More research
    All research

    Get this answered for your exact situation

    Build a free, source-backed setup plan in minutes — the right regime, ATECO code, INPS scheme and real numbers for you. Or ask the AI a specific question, every answer cited to the law.