Italy Revenue Department has locked in a significant delay in releasing crucial tax compliance software by embedding the postponement directly into legislation—a move that has infuriated professional tax advisers and raised fresh questions about whether the government is respecting its own taxpayer protection rules.
The software used to calculate Indici Sintetici di Affidabilità fiscale (ISA) scores—a system that assesses the tax reliability of businesses and self-employed individuals—was made available on May 13, nearly two weeks after the traditional April 30 deadline. Rather than extend payment deadlines to compensate for the delay, authorities inserted a provision into a fiscal decree that simply redefined compliance: for 2026, software must be available by May 15.
Why This Matters
• Commercialisti under pressure: Tax advisers have less than six weeks to process ISA data, integrate third-party tools, and finalize returns before the June 30 payment deadline.
• Statutory breach alleged: Italy's Taxpayer Rights Statute (Law 212/2000) mandates a 60-day buffer between the publication of new compliance tools and the related filing or payment obligations.
• Proroga requested: The National Association of Accountants (ANC) is demanding that the payment window shift from June 30 to at least July 15, with the surcharge deadline moving to mid-August.
Legal Framework Meets Operational Reality
The Taxpayer Rights Statute, enacted in 2000 and strengthened by Legislative Decree 219 in December 2023, serves as the constitutional backbone of taxpayer protections in Italy. Among its core provisions: no compliance requirement can take effect fewer than 60 days after the publication of enabling rules or tools. The statute also bars retroactive tax laws and requires the Agenzia delle Entrate to act in good faith, avoiding penalties when delays or errors originate from the administration itself.
Marco Cuchel, president of the ANC, argues that the fiscal decree essentially bypassed that safeguard. "They thought of almost everything except respecting the Statute and the 60-day latency period," Cuchel said in a statement this week. "We need to factor in the time required for commercial software houses to update their own platforms before practitioners can even begin processing client data."
The dispute centers on timing. While the May 15 legal deadline was technically met, it came at the tail end of a development cycle that began only after the Ministry of Economy and Finance (MEF) approved updated ISA indices on March 31, with publication in the Official Gazette following on April 16. A subsequent Agenzia delle Entrate ruling on April 22 established the benefit structure for high-scoring taxpayers. Conjunctural corrections—adjustments for geopolitical tensions, energy prices, and interest rates—were issued on April 15.
Then came the software itself: version 1.0.0 on May 13, and an updated 1.0.1 release on May 20, after the conversion into law of Fiscal Decree 38/2026 altered the calculation methodology for the Concordato Preventivo Biennale (CPB)—a two-year advance tax agreement option that hinges on ISA scores.
Cascade Effect on Professionals
The compressed timeline has created a bottleneck at the start of tax season 2026. Commercialisti must now absorb ISA data for the 2025 tax year, advise clients on whether to accept CPB proposals for 2026–2027, prepare and file Redditi returns by November 2 (October 31 falls on a Saturday), and ensure payment compliance by June 30—all while waiting for third-party software vendors to complete integration and testing.
The ANC represents thousands of tax professionals whose work calendars are now severely compressed. The association has called for "a duly communicated postponement well ahead of the deadline, not at the eleventh hour, as is customary," to allow for rational organization of workload and personal life.
Beyond accountants, the delay affects small and medium enterprises subject to ISA evaluations across 85 economic activity codes—a system that determines eligibility for reduced audit scrutiny, accelerated VAT refunds, and other administrative benefits. Trade groups including CNA, Confartigianato, Casartigiani, Confcommercio, and Confesercenti have joined the ANC in formally requesting an extension.
What This Means for Taxpayers and Intermediaries
As of May 22, no official extension has been published, though Deputy Economy Minister Maurizio Leo has indicated publicly that a postponement to July 20 for standard payments and August 20 for payments with a 0.4% surcharge is under consideration. That proposed relief would cover not only ISA-eligible taxpayers but also partners in transparent entities and likely those operating under the regime forfettario (flat-rate scheme) who fall within the ISA perimeter.
For now, however, the statutory deadline remains June 30, with a fallback payment window through late July carrying an extra charge. The situation places fiscal intermediaries in the uncomfortable position of advising clients to prepare for the existing deadline while hoping for an eleventh-hour reprieve.
The ANC emphasizes that the delay violates the spirit and letter of the Taxpayer Statute's Article on advance notice, which forbids imposing obligations within 60 days of making the necessary compliance tools available. The association has also invoked the statute's good faith principle, which shields taxpayers from penalties when administrative delays or errors create compliance difficulties.
Broader Context: CPB Integration Complicates Rollout
The 2026 ISA software is more complex than prior versions because it integrates the Concordato Preventivo Biennale mechanism, a voluntary advance-agreement system introduced to reduce disputes and stabilize tax collection. Under CPB, eligible taxpayers receive a two-year revenue and income projection from the Agenzia delle Entrate based on their ISA score and historical data. Accepting the proposal locks in tax liabilities for 2026 and 2027, regardless of actual performance, offering predictability in exchange for upfront commitment.
The CPB proposal submission deadline is September 30, with the option to file using only the cover page of the Redditi forms, or to revoke a prior acceptance. But the ISA score itself—the foundation of the CPB offer—can only be finalized using the software released this month, creating a domino effect: delayed software, delayed score calculation, delayed CPB evaluation, and compressed decision windows for businesses.
The MEF's April 15 conjunctural corrections—designed to account for macroeconomic shocks including energy volatility and interest rate hikes—added another layer of complexity, requiring recalibration of scoring algorithms that third-party vendors must now reverse-engineer and replicate.
Professional Sector's Call for Structural Reform
Beyond the immediate call for a payment extension, the ANC's statement reflects frustration with a recurring pattern: administrative delays followed by last-minute adjustments that disrupt planning. Cuchel's reference to the "new era of tax-contributor relations" inaugurated by the Agenzia delle Entrate carries pointed irony; the association is testing whether recent promises of collaboration and transparency will translate into concrete policy changes.
The Taxpayer Rights Statute reforms of 2023, which expanded mandatory pre-assessment hearings (contradictory proceedings) and broadened the agency's obligation to self-correct manifest errors, were intended to signal a shift toward cooperative compliance. Yet this episode—embedding a delay into law rather than adjusting deadlines accordingly—suggests old habits persist.
The ANC has made clear it expects the Agenzia delle Entrate to issue a formal postponement "consistent with the mandate of the Taxpayer Statute" and communicated "with adequate lead time," not in the final days of June when professionals and businesses are already scrambling.
As Italy's tax year progresses and the September CPB deadline approaches, the question remains whether policymakers will honor the statutory guardrails designed to prevent exactly this kind of compressed compliance crunch—or whether expediency will once again take precedence over procedural fairness.
