The Italian Revenue Agency released Circular No. 6/E on 6 August 2026, setting out detailed rules on the reformed collaborative compliance regime under Legislative Decree No. 221 of 30 December 2023, including mandatory Tax Control Framework certification, phased revenue thresholds, and a restructured penalty protection framework.
The Italian Revenue Agency has announced the release of Circular No. 6/E of 6 August 2026, providing the first comprehensive guidance on collaborative compliance after sweeping reforms introduced by Legislative Decree No. 221 of 30 December 2023. The overhaul transforms a tool once reserved for multinational giants into a centrepiece of Italy’s tax administration strategy.
The regime, initially created by Legislative Decree No. 128/2015 and now reformed through the enabling legislation in Law No. 111 of 2023, shifts the tax authority’s approach from enforcement to dialogue.
The core shift is that companies that build transparent tax risk management systems now get real protections. They avoid administrative and criminal penalties, see audit windows shrink, and can disclose prior-year risks within a 120-day window while keeping those years off-limits for enforcement.
Revenue thresholds drop in stages
Entry to the program was always defined by company size. The new structure phases in lower revenue requirements:
- EUR 750 million from 2024
- EUR 500 million from 2026
- EUR 100 million from 2028
Crucially, smaller firms can now participate if they’re part of a group where at least one member clears the threshold. The 2024 corrective decree broadened this further to include any civil law group structure, not just consolidated tax groups.
Certification becomes mandatory
Rather than letting companies design their own risk frameworks, Italy now requires third-party certification from independent lawyers or chartered accountants. This certification covers what’s called the Tax Control Framework (TCF)—the system for detecting, measuring, managing, and controlling tax risks. Companies already running frameworks under Law No. 262/2005 (accounting controls) or Sarbanes-Oxley can fold those into their tax framework, avoiding duplicate work.
What participation actually gives companies
Participating companies get a two-tier benefit structure. Full exemption from administrative and criminal penalties applies when risks are disclosed upfront, communications are complete, and reported behaviour matches actual conduct. For mapped compliance risks that don’t require specific disclosure, penalties fall to 50% of standard amounts.
The audit calendar shrinks by two years for participants with a certified TCF. Qualified tax certification adds another year off the statute of limitations.
New point of contact
On 1 April 2026, the Revenue Agency created the Specialist Directorate for Collaborative Compliance with offices in Rome and Milan. This unit replaced the previous Cooperative Compliance Office and now serves as the sole contact point for all participating companies. Before the Agency rejects any request or risk communication, it must send a draft response and wait at least 30 days for the company to reply—a mandatory consultation that marks a clear break from traditional adversarial audit practice.
SMEs in an optional TCF regime can participate and get penalty exemptions for disclosed risks, but they don’t receive the full audit-window reduction that larger participants do.
