The number of companies in the programme rises to 221: 78 newly approved applications
While expected, the news is no less significant. The list of companies that have chosen to engage in a cooperative relationship, based on continuous and structured dialogue with the Revenue Agency, has been expanded by 78 new applications. Praise is certainly due to the company executives who have embarked on this path, to the advisers who have supported them, and to the Revenue Agency’s Cooperative Compliance team, which — even before welcoming the 350 new officials dedicated to the programme — managed to handle interactions with a record number of applicants. Overall, the pool of “compliant” large taxpayers is growing ever wider: more than 220 companieshave now chosen the path of proactive dialogue since 2015, the year in which Legislative Decree No. 128/2015 was published.
Attention now turns to certifiers, who are required by 30 September 2026 to verify that the tax control frameworks implemented by the newly admitted companies comply with the requirements set out in the decree and the Guidelines, providing reasonable assurance of the company’s informed, reliable and structured management of its tax risk.
The figure for new admissions is even more striking in light of recent trends: 19 admissions in 2023, 31 in 2024 and 78 in 2025. This marks significant growth, reflecting the gradual maturation and consolidation of a system which, over time, has gained greater stability and clearer rules. In light of the recent reduction in the turnover threshold for access to the regime — set at €500 million from 2026 — it is reasonable to expect that in the coming years many companies will be called upon to make significant strategic choices.
Joining the cooperative compliance regime does not merely entail a formal decision; rather, it requires a demanding process involving the design and implementation of an integrated and effective system for identifying, measuring, managing, and monitoring tax risk. This is a long-term choice, involving a profound shift in mindset across the entire organisation: the transition from a predominantly reactive approach to a preventive one, based on greater managerial accountability and on a view of taxation as a structural component of corporate governance. This is by no means a trivial challenge, especially given that a reduction in turnover is usually accompanied by a smaller organisational structure and, consequently, a more limited availability of internal resources and expertise to devote to the implementation and management of the TCF.
One further element completes the picture. From 2028, the turnover threshold for access to the cooperative compliance regime will be further reduced to €100 million, expanding the pool of potentially eligible companies to over 11,000 productive entities. This will mark the definitive transition of the programme from an “elite” regime, reserved for a few large taxpayers, to a genuine systemic lever.
The challenge concerns not only businesses, but also — and perhaps even more so — the Revenue Agency, which must demonstrate that the robustness of the regulatory framework and the proper functioning of the tools designed by the legislator are capable of supporting, in a concrete and effective manner, a model based on proactive dialogue, quality of relationships and mutual trust. From this perspective, the process should continue along the path of increasing standardisation and, in certain respects, simplification of the instruments — without, however, compromising their substance and function — bearing in mind that an effective tax system should not aim to be “friendly” but rather to be fair.
