The Conto Termico 3.0[1], or new Conto Termico, incentivises small-scale interventions[2] for the increase of energy efficiency and for the production of thermal energy from renewable sources with a financial allocation of 900 million euros per annum, disbursed by way of capital grant up to a maximum of 65% (and a minimum of 40%) of the eligible expenses.
The financial allocation of EUR 900 million is divided into:
500 million euros for private parties, of which 150 million are allocated to companies.
400 million euros for Public Administrations (“PA”), of which 20 million are allocated to Energy Audits[3].
Compared to the Conto Termico 2.0, the new Conto Termico provides for:
the extension of the scope of PAs that may access the mechanism (by way of a new definition under Article 2, lett. c) of the Decree).
the expansion of eligible technologies (Articles 5 and 8 of the Decree).
the eligibility for efficiency interventions also to private parties on buildings belonging to the tertiary sector (Articles 4 and 7 of the Decree).
the advance payment for the preparation of the energy audit reserved for PAs and non-economic Third Sector Entities (“ETS”), equal to 50% of the expense to be incurred (Article 15).
the possibility of accessing the mechanism through Renewable Energy Communities or self-consumption groups of which PAs, ETS or private parties are members (Article 13).
the possibility of accessing the mechanism through a private party within the framework of a public-private partnership configuration, exclusively for PAs (Article 13).
the increase of the incentivised quota to 100% of the expense, for interventions carried out on buildings owned by Municipalities with a population of up to 15,000 inhabitants and used by them (Article 11).
the increase of the incentive for certain categories of energy efficiency interventions that use components exclusively produced in the EU or that provide for the installation of systems with photovoltaic modules registered in the “photovoltaic technology register”[4], without prejudice to compliance with the maximum incentive percentages of 65% or 100% mentioned above.
Types of Eligible Interventions
The types of interventions eligible for the benefits of the Conto Termico 3.0 are[5]:
1. Small-scale interventions for the increase of energy efficiency (Title II, Article 5, para. 1, lett. a)-h)), namely:
Thermal insulation of opaque surfaces delimiting the climatised volume.
Replacement of transparent closures including fixtures delimiting the climatised volume.
Installation of shading and/or shielding systems and/or external solar filtering systems for transparent closures with exposure from ESE to W, fixed or mobile, non-transportable.
Transformation of existing buildings into “nearly zero-energy buildings”[6];
Replacement of existing lighting systems for interiors and external appurtenances with efficient lighting systems.
Installation of automated management and control technologies (building automation) for thermal and electrical systems, including the installation of thermoregulation systems and heat accounting.
Installation of infrastructure elements for private charging of electric vehicles, at the building and its appurtenances, carried out in conjunction with the replacement of existing winter air-conditioning systems with winter air-conditioning systems equipped with electric heat pumps.
Installation of solar photovoltaic systems and related storage systems, at the building or in its appurtenances, carried out in conjunction with the replacement of existing winter air-conditioning systems with winter air-conditioning systems equipped with electric heat pumps.
2. Small-scale interventions for the production of thermal energy from renewable sources and high-efficiency systems (Title III, Article 8, para. 1, lett. a-g)), namely:
Replacement of existing winter air-conditioning systems with winter air-conditioning systems, also combined for the production of domestic hot water, equipped with electric or gas heat pumps, using aerothermal, geothermal or hydrothermal energy (with nominal useful thermal power up to 2 MW).
Replacement of existing winter air-conditioning systems with factory-made hybrid systems or bivalent heat pump systems (with nominal thermal power up to 2 MWt).
Replacement of existing winter air-conditioning systems or heating of greenhouses and existing rural buildings or for the production of thermal energy for production processes or input into district heating and cooling networks with biomass-fuelled heat generators, including factory-made hybrid systems or bivalent heat pump systems (with nominal thermal power up to 2 MWt).
Installation of solar thermal systems, also combined with solar cooling systems (with gross solar surface up to 2,500 m2).
Replacement of electric and gas water heaters with heat pump water heaters.
Replacement of winter air-conditioning systems with connection to efficient district heating systems (with nominal useful thermal power up to 2 MW).
Total or partial functional replacement of existing winter air-conditioning systems with micro-cogeneration units fuelled by renewable sources.
It is noted that the incentives are determined according to the eligible expenses envisaged for the implementation of the intervention, in compliance with the specific caps for: (i) unit of surface; (ii) unit of power; (iii) producibility of the systems (i.e., “physical dimension” of the property subject to intervention, surface of the property or of the roof, floor or wall subject to intervention or of the heat/energy production system) with the consequence that in order to maximise the incentive that can be received (with favourable economy of scale) it is necessary to focus on medium/large-scale interventions which are numerically limited.
Overview of PPP in the Context of the Conto Termico 3.0
PAs may access the incentives by availing themselves of a private party that assumes the capacity of Responsible Party[7], with whom a public-private partnership contract (so-called PPP) has been entered into pursuant to Article 174 et seq. of Legislative Decree No. 36 of 2023 (Public Contracts Code), excluding the social partnership. The private party that will act as Responsible Party must meet the subjective requirements indicated from time to time by the award procedure initiated by the PA pursuant to Legislative Decree 36/2023 and, in particular:
not to incur any of the grounds for exclusion referred to in Articles 94, 95 and 98 of Legislative Decree No. 36/2023.
to be in possession of the economic-financial and technical-professional capacity requirements proportionate to the subject matter and value of the contract, pursuant to Articles 100 et seq. of Legislative Decree No. 36/2023.
where the contract includes the execution of works, to be in possession of SOA certification in the relevant categories and classifications, where required by applicable law[8].
The determination of the incentives, in terms of intensity and cumulability, is carried out within the limits of the expenses attributable to the PA within the framework of the PPP contract, both in the case where the PA is directly configured as the Responsible Party and in the case where the private party is identified as the Responsible Party. All eligible expenses pursuant to the Decree that are envisaged by the executive project approved pursuant to Legislative Decree No. 36/2023 are attributable to the PA, even if falling wholly or partly within the private party's investment, or that are indicated by the Financial Economic Plan (FEP) certified by a third party.
At the stage of submission of the application for the granting of incentives, the Responsible Party must provide:
the PPP contract, duly signed by the parties and drafted pursuant to Article 174 et seq. of Legislative Decree 36/23, having the minimum requirements provided for by the implementing rules, namely:
the contractual relationship established between the public party and the private party must be long-term and aimed at satisfying a public interest, including in any case the energy refurbishment of the building subject to the intervention.
the coverage of the necessary financial needs must come to a significant extent from resources of the private party also by reason of the operational risk assumed.
the executive design, realisation and management of the project must be entrusted to the private party, whilst the public party is responsible for defining the objectives and verifying their implementation.
the construction and operational risk connected to the realisation and management of the project must fall predominantly on the private party.
a duration compatible with the achievement of the public interest underlying the award and, in any case, not less than the disbursement period of the incentive increased by five years, corresponding to the term for maintaining the requirements and preserving the documentation.
transfer of operational risk borne by the private party, on which the investment also falls in whole or in part, without prejudice to subsequent access to incentive mechanisms.
attribution to the private party of the task of realising and managing the work(s) subject to award, according to methods and requirements prescribed by the public party, which defines the objectives and verifies their implementation.
“termination clauses” which, in the event of early termination of the contract for reasons attributable to the private party, guarantee the restitution to GSE of the incentives already disbursed or the waiver of incentives not yet received;
the contract must be signed on a date prior to that of submission of the application for access to the incentives (in the case of interventions with direct access);
the contract must be effective, at the latest, on the date of acceptance of the application for access to the incentives.
the executive project verified and approved pursuant to Legislative Decree 36/2023 with the indication of the eligible expenses for the purposes of the Conto Termico referred to in Articles 6 and 9 of the Decree, VAT and revenues including the Conto Termico incentive and finally the expected profit;
the Financial Economic Plan (FEP) certified by a third party containing the total amount of expenses incurred for the realisation of the intervention by way of public-private partnership, with the indication of the eligible expenses for the purposes of the Conto Termico referred to in Articles 6 and 9 of the Decree, VAT and revenues including the Conto Termico incentive and finally the expected profit;
the payment schedule envisaged by the contract;
declaration containing the breakdown of eligible and non-eligible expenses, signed by the PA and the Private Party, drafted according to Model 10. The value of the eligible expenses indicated must correspond to that reported on the Portaltermico;
in the case of multi-building contracts, allocation of costs for each individual building subject to the intervention, signed by both parties.
In order for an EPC to enable the ESCO to access, on behalf of the Eligible Party, the support mechanism of the Conto Termico 3.0, it must comply with the minimum requirements provided for in Annex 8 of Legislative Decree 102/2014 and must be consistent with the provisions of the Decree. In particular, the contract:
must present the requirements referred to in Annex 8 of Legislative Decree No. 102 of 2014;
must comply with the provisions of standard UNI CEI EN 17669:2023;
must comply with the provisions of Article 2, paragraph 2, lett. n), of Legislative Decree No. 102 of 2014 and, therefore, be founded on guaranteed energy savings and not exclusively on economic effects;
must provide for clear and consistent procedures for the determination of the energy baselines and for the identification of the normalisation methods of the boundary parameters;
must provide for a measurement system that is clear and consistent with the algorithms of the savings to be determined and guaranteed;
must refer to a single building or property unit on which the interventions are carried out, except for the exception provided for PAs (for which multi-building EPC is permitted);
must provide for a contract duration compatible with the provisions of Article 13, paragraph 6, lett. a) of the Decree, (i.e., incentive period + five years following the disbursement period of the incentives);
must be drafted in such a way that the link established between the parties is not fictitious, but must materialise with a periodic recognition of a fee, for the entire contractual duration, in consideration of a service/function to be maintained until the end of the contract;
must provide for a clear and consistent indication of expenses, revenues and profit, in line with the provisions of Article 13, paragraph 6, letter b) of Ministerial Decree of 7 August 2025.
Although project financing (currently governed by Article 193 of Legislative Decree 36/2023), one of the methods of selecting the private partner in contractual PPPs, has been the subject of a recent ruling by the Court of Justice of the European Union which established the incompatibility of the right of pre-emption recognised as guarantor to the promoter, provided for by the previous Legislative Decree No. 50/2016[9] (but still reproduced in the current Legislative Decree No. 36/2023), and is (also in other respects) the subject of examination in an infringement procedure initiated by the European Commission on 8 October 2025, the conclusion of EPCs with public administrations is configured as an option which, whilst requiring careful planning and solid contractual structuring, appears destined to assume an increasingly central role in the coming years, alongside other instruments (such as, for example, the Energy Service Plus).
Indeed, the use of EPCs for the energy refurbishment of public buildings represents a significant economic driver for the supply chain of companies involved and, considering the extent of public real estate assets, an equally significant environmental driver, in terms of reduction of climate-altering emissions consequent to the achievable energy savings, as recently highlighted also by ENEA.
It must in fact be considered that Legislative Decree No. 36/2023 dedicates a specific provision to EPCs (Article 200), laying down detailed rules regarding certain contractual obligations and related methods of execution[10].
Moreover, access to the PPP instrument for the purposes of admission to the Conto Termico constitutes a further element of attractiveness, also in light of the joint preparation, by the National Anti-Corruption Authority, the State General Accounting Office and ENEA, of a standard energy performance contract or energy performance contract (EPC) for public buildings, pursuant to Article 200 of Legislative Decree No. 36/2023 and the related annexes (including the technical specification and the risk matrix).
This initiative assumes particular systematic importance: on the one hand, it promotes the homogeneity and standardisation of contractual clauses, reducing application uncertainties and structuring times for operations; on the other hand, it strengthens the bankability of projects, thanks to a clearer allocation of risks between the contracting administration and the economic operator, in consistency with the principles proper to PPP and provides a more stable and predictable regulatory framework for investors.
In order to make the structure and logic of PPP and EPCs consistent in the context of the Conto Termico 3.0, built on a logic of incentive referring to the individual intervention understood in the strict sense, it is necessary to adopt a different paradigm. In particular, it is necessary to enhance interventions, understood in the broad sense, of wider scope, which provide for a plurality of works and/or systems, and which are founded on an overall improvement of the energy performance of the system subject to intervention. Such performance, if realised in accordance with the contractual provisions and with equal cost of the energy vector, is capable of generating a measurable and advantageous saving both for the public administration and for the private partner.
In conclusion, the integration between the discipline of PPPs, the standard EPC scheme and the incentive mechanisms of the Conto Termico appears capable of promoting a wider dissemination of energy refurbishment interventions of public assets, with positive effects both on the financial and on the environmental level.
Terms of Payment of Incentives
Based on the Implementing Rules (Point 4.3), the incentive amounts are disbursed by the last day of the month following that of the end of the two-month period in which falls the date of completion of the Contract-Form[11], which coincides with the date of the communication by GSE to the Responsible Party of the provision for admission to the incentives referred to in the Decree.
For amounts up to EUR 15,000, the Decree provides for the disbursement of the incentive in a single instalment. Amounts exceeding this threshold are disbursed in constant annual instalments for the duration defined in Table 1 referred to in Article 11, paragraph 3 of the Decree (i.e., between 2 and 5 years)[12].
Pursuant to Article 11, paragraph 6 of the Decree, in relation to interventions carried out by the PA and Third Sector Entities (“ETS”), also through ESCOs or other authorised parties, disbursement in a single instalment is also provided for incentives of amounts exceeding EUR 15,000 when they opt for the direct access procedure (i.e., upon completion of the works) and not in the case of reservation (i.e., for works yet to be started or in the course of realisation, reserved for PAs and ETS).
For interventions carried out by economic ETS, also through ESCOs or other authorised parties, disbursement in a single instalment also for incentives of amounts exceeding EUR 15,000 is possible exclusively for Title III interventions[13].
Upon acceptance of reservation applications, GSE commits in favour of the requesting Responsible Party the sum corresponding to the maximum recognisable incentive. This amount is to be understood as a maximum estimated amount. The act of confirmation of the reservation issued by GSE represents a commitment to the disbursement of resources, without prejudice, in any case, to compliance with the eligibility conditions and the requirements provided for by the Decree.
The amount of the reserved incentive represents a maximum and may be subject to remodulation by GSE as a result of the investigative activities conducted on the declarations and documentation submitted by the Responsible Party for the purposes of the disbursement of the incentive.
In the case of access to incentives by way of reservation, also through an ESCO or other authorised party referred to in Article 13 of the Decree, where requested, the disbursement of the incentive may take place by way of:
a down payment instalment[14], requested by the Responsible Party with the communication of the commencement of works.
a possible intermediate instalment[15], which may be requested upon reaching 50% of the amount of the eligible expenses envisaged for the realisation of the intervention subject to the reservation.
a final balance instalment, requested by the Responsible Party upon completion of the intervention, following the submission of the direct access application for accounting (so-called post-reservation).
The disbursement of the aforesaid instalments is carried out by the last day of the month following that of the end of the two-month period in which falls the date of activation of the contract, to be understood as the date of dispatch of the provision for admission to the incentives.
Where expressly provided for in certain of the contractual cases referred to in Article 14, paragraph 2, letter b) no. i., iii., iv.), namely: (i) presence of an energy audit and of a provision or other administrative act certifying the commitment to the execution of at least one of the interventions included therein; (ii) presence of an energy performance contract or another integrated supply contract for the energy refurbishment of the systems concerned; (iii) presence of a provision or other administrative act certifying the award of the works subject to the application-form, together with the minutes of delivery of the works drawn up by the works supervisor, the PA or the ETS may request that the sums reserved in its own favour be disbursed, also partially, by GSE to the ESCO signatory of the contract, under its own responsibility regarding the correct execution of the works and the quantification requested (subject to formal joint and several obligation between the parties).
It is noted that (i) a private party selected by the PA within the framework of public-private partnership forms that submits an application for a contribution under the Conto Termico - qualifying as the Responsible Party - on behalf of a PA, as well as (ii) an ESCO that submits an application for a contribution under the Conto Termico - qualifying as the Responsible Party on behalf of another party, through the signing of an EPC contract or Energy Service contract, cannot avail itself of the irrevocable collection mandate (Point 12.12.3.2. of the Implementing Rules).
It is specified, in fact, that the irrevocable collection mandate is an instrument by which payment for a good is effected, like a bank transfer receipt. In cases where the ESCO is configured as the Responsible Party, in fact, invoices and related bank transfer receipts must not be transmitted to GSE, and consequently the instrument of the irrevocable collection mandate cannot be adopted (Point 12.12.4 of the Implementing Rules).
The incentive will therefore be paid to the PA which will share it - if and to the extent agreed - with the ESCO but thereby rendering less attractive for financing entities such a type of financial structure.
On the other hand, the assignment of credit is permissible, exclusively for applications submitted in direct access mode and with instalment payment of the incentive and must relate to the totality of credits, present and future, held by the assignor against GSE by virtue of the Convention in force between the parties, until the expiry thereof or possible retrocession (Point 12.3.3. of the Implementing Rules). Furthermore:
the credits must be assigned to a single assignee;
the application for admission to the incentive must be made exclusively in Direct Access mode;
the disbursement of credits must be in instalments;
it is necessary that the deed of assignment of credits be:
drafted on the basis of the standard GSE model in the form of a notarial deed or private deed authenticated by a notary and executed on a date subsequent to the acceptance provision issued by GSE.
complete with the Convention as an integral part of the deed of assignment of credits.
expressly accepted by GSE following notification, by registered letter with return receipt or certified email, to the principal and the agent.
The assignment of credit is valid until the acceptance, by GSE, of any deed of retrocession of the credit. The retrocession of the entire residual credit to the original assignor must take place in the same form, complying with the same conditions set out above, with which the deed of assignment of credits to which it refers was executed.
GSE will pay the residual credits to the original credit holder from the second month following the acceptance of the retrocession. GSE is not liable in the event of non-receipt, erroneous and/or delayed receipt of the deed.
The acceptance, both of the assignment and of the retrocession of credits, does not prejudice the power of GSE to oppose to the assignee the set-off that it could have opposed to the assignor.
[1] Pursuant to the Decree of the Ministry of the Environment and Energy Security of 7 August 2025 (“Ministerial Decree of 7 August 2025” or “Decree”) in force from 25 December 2025 (i.e., 90 days from publication in the Official Gazette). On 5 December 2025, GSE published the related implementing rules (the “Implementing Rules”).
[2] Insofar as they present technical, economic and procedural characteristics such as to justify a simplified authorisation and incentive regime, alternative to structural instruments (for large centralised production network energy infrastructures, complex industrial programmes) or complex incentives.
[3] Audits and preparation of the energy performance certificate are incentivised to the extent of 100% of the expense incurred by the public administration or by the ESCO that performs the intervention on its behalf, excluding housing cooperatives and social cooperatives.
[4] Referred to in Article 12 of Decree-Law 9 December 2023, No. 181, and in particular 5% for systems with photovoltaic modules produced in Member States of the European Union (“MS”) with module-level efficiency of at least 21.5% (lett. a); 10% for systems with photovoltaic modules with cells, both produced in MS, with cell-level efficiency of at least 23.5% (lett. b); 15% for systems with photovoltaic modules produced in MS, composed of bifacial silicon heterojunction or tandem cells produced in the EU with cell efficiency of at least 24.0% (lett. c).
[5] It is specified that the interventions referred to in points 1 and 2 must necessarily be carried out in existing buildings, parts thereof or existing property units.
[6] The nearly zero-energy building (nZEB) is defined as “a building with very high energy performance in which the very low or almost zero energy requirement is covered to a significant extent by energy from renewable sources, produced on site” by the EPBD Directive (2010/31/EU).
[7] Pursuant to Article 2, paragraph 1, letter tt) of the Decree, the Responsible Party (SR) is “the party that has incurred the expenses for the execution of the interventions referred to in this Decree and that is entitled to the incentive and enters into the contract with GSE. For the completion of the application-form and for the management of contractual relations with GSE, it may operate through a delegated party”.
[8] For the purposes of access to the incentives referred to in the Decree, where the PPP contract also provides for the management of energy savings on the building subject to the intervention, the party must be in possession of UNI CEI 11352 certification, issued by an accredited body, valid at the date of submission of the application to GSE. The certification must be maintained for the entire incentive period and for the five years following the disbursement by GSE of the incentive or of any last instalment of the recognised incentive. In the case of a temporary grouping of enterprises, consortium or special purpose company pursuant to Article 194 of Legislative Decree No. 36/2023, the provisions already specified for the ESCO apply with respect to the enterprise that must be in possession of UNI CEI 13352 certification.
[9] By judgment of 5 February 2026, the Court of Justice of the European Union declared, in Case C-810/24, the incompatibility of the right of pre-emption recognised to the promoter within the framework of the project financing procedure referred to in Article 183, paragraph 15, of the previous Public Contracts Code (Legislative Decree No. 50/2016) with European Union law and, in particular, with Directive 2014/23/EU on the award of concession contracts. Indeed, the censured right of pre-emption attributed to the promoter not awarded the procedure initiated by the contracting administration the power to adapt its own offer to that of the successful tenderer or, in the event of failure to exercise the pre-emption, to obtain reimbursement of the expenses incurred for the preparation of the proposal.
[10] In particular, Article 200 of Legislative Decree No. 36/2023 provides that in energy performance contracts or energy performance contracts (i) the management revenues of the economic operator are determined and paid according to the level of improvement of energy efficiency or other energy performance criteria established by contract, provided they are quantifiable in relation to consumption; (ii) the measure of improvement of energy efficiency, calculated according to the standards regarding certification of the energy performance of buildings and other energy-intensive infrastructures, is made available to the contracting entity by the economic operator; (iii) the measure referred to in the preceding point must be verified and monitored during the entire duration of the contract, also availing itself of appropriate IT platforms designed for the collection, organisation, management, processing, evaluation and monitoring of energy consumption.
[11] Contractual document to be executed between the Implementing Party and GSE and containing the contractual clauses that regulate the relationship between the parties in the incentive period relating to the interventions subject to the application for the granting of incentives referred to in the Decree.
[12] In the case of multi-intervention, the number of instalments is identified as the maximum value among the instalment values of the individual interventions referred to in the aforesaid Table 1, distributing equally among them the sum of the total incentive due.
[13] For such parties, where multi-interventions are carried out with a combination of Title II interventions (on buildings falling within the tertiary sector) and Title III interventions, the disbursement of incentives of amounts exceeding EUR 15,000 is carried out in multiple instalments and standardised to the maximum duration provided for by Title II interventions.
[14] The amount of the down payment instalment is equal to 50% of the benefit overall recognised, if the duration of the incentive is 2 years, it is equal to two-fifths of the benefit overall recognised, if the duration of the incentive is 5 years, in reference to the years indicated in Table 12.
[15] The amount of any intermediate instalment is quantified according to the maximum reserved incentive, with deduction of the down payment disbursed and distributing uniformly the remaining quota due, to the extent of 50%, between the intermediate instalment and the balance to be accounted for at the end of the works.
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