Thermal Account 3.0 and building bonuses: are they cumulative? The clarification from the GSE

Thermal Account 3.0 and building bonuses: the principle to be respected

The general principle reiterated by the GSE is that of the prohibition of double financing of the same expenses. This means that the same intervention or the same cost item cannot be incentivized at the same time through multiple public support instruments.

According to the clarification provided by the GSE, the cumulation between Conto Termico and other benefits – including tax deductions for building and energy interventions (Ecobonus or Renovation Bonus) – is therefore not possible. The simultaneous use of two incentives would be possible only if the incentives do not concern the same expenses.

In fact, the ban only concerns double financing of the same cost. In other words, it is not permitted for the same expense to be incentivized both through the Thermal Account and through building bonuses, but different expenses can access different incentives.

When it is possible to take advantage of both incentives

It can therefore be deduced that the prohibition on cumulation does not prevent the use of multiple benefits within the same building project, provided that the expenses are distinct and independently identifiable. In practice, a redevelopment intervention can be financed with multiple instruments if each incentive concerns a specific component of the intervention.

For example, in an energy efficiency project it would be possible:

• use the Thermal Account 3.0 for interventions on systems or for technologies that can be incentivized by the mechanism managed by the GSE;
• use tax deductions (such as Ecobonus or Renovation Bonus) for other construction works or interventions on the building envelope.

The fundamental condition, also to avoid subsequent disputes, is that the expenses are separately accounted for and clearly documented.

The expected exceptions

The GSE clarification also reminds that some forms of public support do not fall within the cumulation ban, such as:

• guarantee funds,
• revolving funds,
• interest contributions.

These tools can complement energy incentives because they do not directly finance the same expenditure, but intervene with different methods of economic support.

Cumulation with incentives for energy sharing pursuant to the CACER decree is also permitted, without prejudice to the limits and exclusions provided for by the relevant specialist regulations.

With regard to interventions through ESCOs, CERs or self-consumption groups that operate as Responsible Entity on behalf of other entities, the cumulative limits established for the Admitted Entity for which these entities operate apply.

We remind you that, for the purposes of verifying compliance with the prohibition on cumulation of the same expenses, the Responsible Party must indicate on the Heat carrier the possible presence of other incentives or public funding, providing the requested information and, when required, the relevant codes registered in the National Register of State Aid (RNA).

Why clarification is important

The issue of the cumulative nature of incentives has once again become central in the construction sector after the progressive reduction of the most generous incentives of the Superbonus years. In this scenario, the Thermal Account 3.0 represents one of the most relevant tools to support energy efficiency interventions, but its integration with other bonuses requires careful management of expenses and documentation.