The recovery plan in detail
The control strategies have been put in black and white in the MEF Plan to combat tax evasion. Here we read in particular that cadastral checks will be strengthened not only to find ghost properties, and for the updating of cadastral values for properties subjected to energy efficiency and/or structural improvement interventions, financed in whole or in part by public funds from 2019, but also to strengthen actions aimed at ascertaining the existence of credits declared by taxpayers.
In essence, a series of cross-checks that will use the data present in the land register to identify the right to have the benefits with the methods applied by the individual owners, while also verifying all the expense documentation and the credit request methods.
Splits in the crosshairs
In general, with regards to cadastral changes, the checks – as expressly provided for by the 2024 Budget Law which dictated the mechanism – are carried out after having drawn up a specific list of properties on which to carry out further checks. First, checks began on properties with zero income, then we moved on to those with a very low income compared to the amount of work carried out, and so on.
Now the campaign for the recovery of non-updated cadastral income interfaces with that relating to the right to have the bonuses in question, also focusing on the cadastral history of the property itself. In fact, several problems had emerged – and had been the subject of questions to the Agency – in reference to the possibility of splitting the real estate units in order to create both a mini condominium and also to be able to consider multiple real estate units as functionally independent even if owned by the same owner.
For example, the possibility of having a double concession for two units that would have independent access only at the end of the works was mooted. An option rejected by the Revenue, who had specified that for the purposes of the Superbonus, as with all other bonuses for building interventions, only the situation existing at the beginning of the works should be valorised and not the one resulting at the end of the same.
Punctual checks
And what about those who had split up before the start of the works? In circular 23/2022, the Agency had given the green light to this possibility, specifying however that specific checks would be carried out on this.
In fact, the text states that also for the purposes of applying the Superbonus, reference must be made to the number of properties existing at the start of the works. Therefore, in the absence of an express regulatory provision in this regard, it is possible to benefit from the Superbonus even in the event that, before the start of the works, the taxpayer divides a single residential unit into several properties. For example, the sole owner of a building can, before starting work, divide it into several distinctly stacked real estate units in order to benefit from a higher spending limit. A green light conditional, however, on the actual situation of the property. In fact, two lines below we read that “The possible concrete assessment of a distorted use of the benefit in question remains unaffected”.
Apparently, therefore, the new controls on the right to take advantage of the Superbonus are focusing precisely on these situations. In essence, thanks also to the massive use of AI, which allows for speeding up the cross-referencing of data, the Agency is going back to the cadastral history of individual properties in order to highlight any opaque situations, i.e., those of a functional split exclusively for the use of an increased ceiling to take advantage of the Superbonus.
Obviously in this case it is always possible to open a dispute to demonstrate that it was, however, an operation absolutely in line with the law and no abuse of rights occurred.
Half of the verified properties still to be regularized
The crackdown initiated by the Revenue has already revealed a situation of widespread irregularities regarding the lack of change in cadastral income. In fact, those who have benefited from the Superbonus have always carried out structural interventions such as to make it necessary to review the income, considering the obligation to carry out key interventions such as those on the casing, in order to be able to take advantage of the maxi deduction even on minor interventions such as the simple replacement of the heating system.
Well, from the data of the 2026 Public Finance Document it appears that as of 31 December 2025 around 1,050 properties out of 3,500 subject to compliance letters had been regularised, while around 1,550 still needed to be regularised. This year, another 20,000 letters have already been sent to those who have not reviewed their income. But overall between this year and next, at least 200,000 land registry checks are scheduled.
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