Spending caps and automatic booking blocking
First of all, to avoid overbooking of resources and guarantee a balanced distribution among the admitted subjects, the GSE will carry out an estimate based on the sum of the annual incentives to be recognized, considering the amounts paid in the current and previous years, as well as the sums to be paid in the current and following years, based on a three-year average evaluation. The review of the mechanism is based on three parameters:
- upon reaching the threshold of 900 million in total and for the following 60 days, it will no longer be possible to insert booking requests, but only requests for direct access at the end of the works will be admitted;
- if only one of the types of entities admitted (Public Administrations, businesses, private individuals) saturates the quota of 600 million euros, for that specific category the obligation of only direct access will be triggered for the following 60 days;
- to guarantee continuity for all sectors, a minimum reserve of 300 million euros per year is secured for each macro-category of admitted entities.
New rules for PA bookings
The corrective decree then introduces limits for reservations by Public Administrations in general: the access procedure through reservation is reserved for a cumulative annual expenditure commitment not exceeding 50% of the overall amount foreseen for the sector.
Furthermore, for interventions related to energy diagnosis and certification, once 60 days have passed since cumulative expenditure of 20 million euros has passed, the possibility of submitting new requests is blocked (Article 3, paragraph 5).
Stop giving incentives to small municipalities
For municipalities with less than 15,000 inhabitants, for which the Thermal Account currently provides for the reimbursement of the total expense, there is a restriction on reimbursements. The 100% incentive is limited only to the first subsidized intervention. For all interventions subsequent to the first, the incentive drops to 80% of the eligible expenses, without prejudice to the limits per unit of power and surface area.
However, the right acquired for small municipalities that have already submitted a request for access (also through reservation) before the entry into force of the decree remains intact. There is then the possibility of obtaining the incentive in a single solution if the amount is up to 50,000 euros.
D/7 properties and new energy audit obligations are excluded from the benefits
The decree therefore excludes from now on incentives for the energy requalification of category D/7 properties. These are those for special purposes built or adapted to measure for the specific needs of an industrial or production activity, whose structure and internal systems are so integrated with the production cycle that they cannot be converted to a different use without undergoing radical building transformations.
Furthermore, the obligation to obtain an energy diagnosis is also established for the replacement of fixtures and the installation of solar shading.
GSE checks for undue recovery on the agent
Then comes the strengthening of the verification procedures: in the event that the GSE finds relevant violations for the purposes of the disbursement of the contributions, it will order not only the immediate rejection of the application or the forfeiture of the benefits, but the recovery actions of the sums already paid will be immediately initiated and the investigation will be reported to ARERA for the application of the financial sanctions. If the violation does not lead to total revocation but affects the correct quantification, the GSE will redefine the incentive by recovering the excess sums.
The rule also introduces a principle of co-responsibility which shifts the axis of risk onto professionals and ESCOs who act as agents and are therefore delegated to collect the sums. The new text of Article 10 in fact establishes that: “In cases in which the Responsible Party has given a mandate for collection, the GSE may proceed with the recovery of the sums unduly received and collected by the agent, or in any case subject to recovery pursuant to this article, also against the latter, as jointly and severally liable within the limits of the amounts collected in execution of the mandate.”
News for biomass, lighting, solar shading
From a technical point of view, then, Annex II is modified by introducing more stringent criteria for biomass-fueled generators. The incentive is remodulated with proportional reward coefficients (1 – 1.2 – 1.5) linked to the percentage of reduction in Primary Particulate emissions compared to the values of Ministerial Decree 186/2017 for 5 stars.
The rules for external solar screening and filtration also change: the requirements must comply with the gtot solar factor ranges indicated in Table 1 of paragraph 6 of UNI/TR 12003, calculated as the overall value between the glazed and filtering system according to the UNI EN 410:2011 standard. The evaluation parameters of the lighting systems have also been updated.
Summary table: changes to the Thermal Account
Let’s see all the new features summarized in this summary table. Below it is also possible to read and download the text of the corrective decree of the Ministry of the Environment and Energy Security.
|
Scope of Intervention |
Old orientation (original Ministerial Decree 7 August 2025) |
New Requirement and Mandatory Constraint |
|---|---|---|
|
Calculation of Spending Commitment |
Criteria not tied to actual cash flows |
Cash criterion based on the amounts actually paid and to be paid |
|
Limits and Reservations |
Access to booking conditioned only by the general ceiling |
Blocking of bookings upon reaching 900 million in total or 600 million in category. Only direct access allowed for 60 days |
|
Small Municipalities (≤ 15,000 inhabitants) |
Incentives spread without limitations on the number of practices of the institution |
100% of the costs for the first intervention only. Subsequent interventions limited to 80% |
|
Recovery of Sums |
Compensation action focused exclusively on the Responsible Party |
Joint liability of the collection agent (ESCO/Suppliers) for the repayment of undue payments |
|
Biomass plants |
Useful thermal efficiency greater than 85% required |
Correction coefficients (up to 1.5) based on the percentage reduction of primary particulate matter |
|
Solar Filtration Systems |
Parameters linked to class 3 or 4 of the UNI 14501 standard. |
GTOT solar factor requirements compliant with Table 1 of UNI/TR 12003 and overall calculation UNI EN 410. |
|
Lighting systems |
Standard checks of characteristics and CE marking |
Mandatory photometric checks at ISO/IEC 17025 accredited laboratories and effectiveness according to reg. EU 2024/1781 |
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