With the recent registration of the appointment of the Special Commissioner by the Italian Court of Auditors, the simplified regulatory framework aimed at ensuring the construction and completion of the works necessary and functional to the staging of the final phase of the UEFA EURO 2032 European Football Championship has finally been unlocked.
Under Article 9-ter of Decree-Law No. 96/2025, converted into Law No. 119/2025, the Italian legislator established the role of Special Commissioner for these works, structurally redesigning the rules applicable to the construction and modernisation of sports infrastructure of national strategic interest.
In particular, the Commissioner is required to define one or more action plans, as well as the activities supporting them, based on the initiatives of private promoters and taking into account the operational solutions defined by the Inter-institutional Committee for Italy’s bid to host UEFA EURO 2032. The plans must be approved by decree of the Prime Minister or the political authority responsible for sport, in consultation with the Minister of Economy and Finance and the Minister of Infrastructure and Transport.
It is clear from the new regulatory framework that stadium projects falling within the aforementioned plans may follow the special procedure governed by Article 9-ter, whilst for other sports facilities the provisions of Article 4 of Legislative Decree No. 38 of 28 February 2021, albeit simplified, continue to apply.
As regards powers, the Special Commissioner may issue an order, after consulting the competent authorities (which will have fifteen days to respond, failing which the mechanism of tacit consent will apply), in derogation from any provision of law other than criminal law, subject to compliance with anti-mafia legislation and the mandatory requirements arising from membership of the European Union. The Mayor of the municipality concerned may be appointed Deputy Commissioner, making use of municipal offices to carry out their duties.
The core of the entire regulatory framework is the procedure for issuing the single authorisation. Such authorisation, which brings together all acts of concession, authorisation, consent, agreement, opinion and clearance, however named, is issued by the Special Commissioner following a specific conference of services, convened in accordance with Articles 14-bis et seq. of Law No. 241/1990, in which all the competent authorities participate, including those responsible for environmental protection, landscape and territorial planning, cultural heritage, health and public safety. The single authorisation replaces, for all purposes, all other measures, however named, and constitutes a variation to existing urban planning instruments. It is equivalent to a declaration of public utility, non-deferrability and urgency of the works, and also serves as authorisation for the siting of the works and for the imposition of an expropriation restriction.
The purpose of the provision is clear: to establish a procedure aimed at accelerating the approval of projects relating to infrastructure of national strategic interest, in response to Italy’s widening gap vis-à-vis countries with lower sporting rankings, as Italy does not rank among the top ten European nations in terms of the number of stadiums built or modernised between 2007 and 2024. The regulatory framework grants the Commissioner special powers covering all administrative procedures relating to the approval of infrastructure projects, with a view to maximum simplification.
The powers of the Special Commissioner do not, however, appear to be limited to the stadiums already nominated for Euro 2032, but may extend to all works deemed necessary and strictly functional to the staging of the tournament, based on the initiatives of private promoters and the operational solutions of the Inter-institutional Committee for the Euro 2032 bid.
As regards financial support, the legislator has provided for the establishment of the “Italian Sports Fund”, with the stated aim of supporting the promotion, hosting and organisation of major international sporting events and optimising investment in sports facilities, entrusting its management to the Institute for Sports and Cultural Credit S.p.A. (ICSC). The measure has a particularly broad scope: the Fund is intended not only to provide guarantees in respect of loans granted by banks or financial intermediaries, but also to provide direct or indirect financing, subscribe for equity instruments and award non-repayable grants. The operation of the Fund and the procedures for accessing its resources are governed by one or more Prime Minister’s Decrees, adopted in consultation with the Minister of Economy and Finance, upon proposal by the ICSC. By express provision of the law, the Fund may also provide financial support for private promoters in connection with public-private partnership transactions, pursuant to paragraph 5 of Article 9-ter of Decree-Law No 96/2025.
In conclusion, the legislator proceeds on the assumption that the revitalisation of sports infrastructure – and the associated urban regeneration – cannot be achieved without a decisive shift in the administrative procedures governing the approval of the relevant projects, capable of attracting private investment, including through public financial support.
