Ecobonus and adequacy of expenses: how to certify the costs and not lose the deduction

Energy saving and certifications

The Ecobonus, as we know, is a tax deduction (from the IRPEF or IRES) created to reward interventions that improve the energy efficiency of existing buildings, reduce energy consumption and promote the use of renewable sources. The interventions carried out, therefore, must lead to an increase in energy efficiency and a reduction in the energy needs of the property involved in the works, and this requirement must be “demonstrable” with specific documentation to be sent to ENEA.

There are two modes:

• standard procedure with certification from the technician in charge in cases where the APE is also required for the purposes of the Ecobonus (redevelopment of the entire building, simultaneous replacement of fixtures and heating system), or when the system intervention exceeds specific dimensional power requirements of the heat generator or the building automation system (condominium interventions);
• simplified procedure with declaration from the supplier/installer certifying the conformity of the intervention with the technical energy efficiency requirements.

To put it briefly, for interventions on a single property, the need to include or not the APE in the Ecobonus application is the requirement that allows us to distinguish when it is possible to apply the simplified procedure (manufacturer/installer sheet) and when the technician’s certification is mandatory.

Starting from 2020, the obligation to document compliance with the technical requirements has also been joined by that relating to the adequacy of the expenditure and, in cases where the certification can be replaced by a declaration from the supplier/installer, the maximum amount of tax deductions is calculated on the basis of the specific cost ceilings for each type of intervention referred to in Annex I to Ministerial Decree 6.08.2020.

Congruity of expenses and maximum limits

The need to certify compliance with specific ceilings for energy saving interventions was therefore introduced by the Ministerial Decree of 6 August 2020, the so-called “Technical Requirements Decree” (in force from 6 October 2020), a provision closely linked to the Superbonus and the option for the transfer of credit, but which introduced rules that apply in all cases, therefore also for the direct deduction in the tax return.

Once the Superbonus is over, the obligation remains, and there are no exemptions relating to the amount of the expense but only with respect to the type of intervention carried out: when the intervention of the technician is necessary for the purposes of the ENEA practice, the certification of the adequacy of the expenses and the metric calculation are also needed.

When the simplified procedure can be followed, it is sufficient that the ministerial ceilings are respected, now set in Annex A of the MITE decree of 14 February 2022, which provided for an increase of approximately 20% compared to the previous ceilings to adapt them to the increases in raw material prices.

Today the reference ceilings for the main interventions are:

1. Heat pumps: €800/kW of useful thermal power in heating.
2. Hybrid systems: €1,860/kWt1.
3. Heat pump water heater: €1,600/unit for capacities up to 150 litres, €2,500/unit for higher capacities.
4. Solar thermal collectors: €700/m² of gross surface area for flat collectors, €850/m² for vacuum collectors.
5. Biomass generators: €300/kW for stoves and inserts, €700/kW for boilers.
6. Windows and doors and windows: vary from €450/m² to €700/m² depending on type and performance, with surcharges for integrated darkening systems.
7. Solar shading including automatic adjustment mechanisms: €276/m².
8. Building automation technologies: €60/m².

The costs in Annex A are net of VAT, professional services, installation and labour. For heating systems with renovation of the emission system, €180/m² is added for underfloor heating or €60/m² for other systems.

In the case of goods whose cost exceeds these figures, the deduction is only valid for the part indicated as the maximum ceiling. Since this is a ministerial act, in cases where the simplified procedure is envisaged it is therefore not necessary to attach other documents to the supplier/installer declaration. In fact, in the event of an overrun, ENEA will directly bring the benefit back within the established limits, communicating the data to the Revenue Agency.

Asseveration with metric calculation

For all interventions not included among those admitted to the simplified procedure, however, complete certification by a qualified technician is always mandatory. As seen, all complex interventions fall into this category: external insulation, combined casing-system interventions, interventions involving the installation of systems above 100 kW, condominium building automation systems. The Ministerial Decree “Technical Requirements” defines a qualified technician as “a person authorized to design buildings and systems within the scope of the skills attributed to him by current legislation and registered with specific professional orders and colleges”.

The technician’s declaration on the adequacy of the expenses must contain:

1. Congruity according to price lists: the costs of goods by type of intervention must be verified by referring to the average prices reported in the price lists prepared by the regions and autonomous provinces or to the prices of the DEI guides. They must be below or not above these.
2. Detailed metric calculation: analytical description of expense items with quantification of materials, workmanship and professional services.

In summary, therefore, for interventions on individual properties, villas or apartments, when it comes to the simple purchase and installation of goods, the certification is not necessary. If a construction site is opened or condominium interventions are involved, however, it is mandatory.

Summary table

Here is a summary table item by item:

FAQ

To clarify further, let’s look at some concrete examples/cases:

1. I replace the independent boiler in my apartment with a 12 kW heat pump, what is the reference ceiling? For autonomous systems serving individual real estate units in Annex I, a ceiling of €720/kW is envisaged, therefore €8,640 for the supply of the appliance alone.
2. I change the windows of my house for 15,000 euros. Can I avoid the sworn statement? Yes, just replacing windows in individual real estate units does not require certification, regardless of the amount spent. The supplier’s declaration certifying compliance with the technical requirements on transmittance is sufficient.
3. The technician certified costs of 10,000 euros, but Annex A provides for a maximum of 8,000 euros. How much do I calculate the ecobonus on? The ecobonus is calculated only on the 8,000 euros provided for in Annex A of the MITE decree. The excess 2,000 euros do not give the right to deduction, even if actually spent and documented.
4. The statement contains a calculation error. How is it corrected? The technician must cancel the protocol already sent to ENEA and send a new correct certification. It is not possible to integrate or correct documents that have already been registered.
5. I install 30 m2 solar thermal panels. Is a sworn statement necessary? Yes, for solar surfaces exceeding 20 m2 the technical certification is mandatory with verification of the adequacy of the expenses according to the DEI/regional price lists.
6. I carry out a building automation intervention on an autonomous 25 kW system. Is a sworn statement necessary? Building automation systems require technical certification depending on the power of the heating system. So in this specific case it is not necessary.
7. Can the technician attest to fairness using prices from another region? Yes, when the regional price list does not provide for the specific type of intervention, the use of price lists from neighboring regions or from the Chambers of Commerce is permitted, as clarified by the Revenue Agency.
8. I change both the boiler and the windows of a condominium apartment. Is the technician’s certification necessary or not because these are separate interventions? If the intervention is carried out at the same time as the replacement of the windows, it falls within the scope of the insulation interventions for which the APE is required. Therefore, the technician’s certification with adequacy of expenses and metric calculation is also required.
9. I replace an electric water heater with a heat pump one. What documentation is needed? The supplier’s declaration or the documentation accompanying the product certifying the COP >2.6 is sufficient. The applicable ceiling is 1,200-1,500 euros depending on capacity, for the supply of the appliance alone.
10. Is it true that it is necessary to refer separately to the power of the boiler and that of the heat pump in the case of a hybrid system to check whether the technician’s certification is needed? No. Even in the case of a hybrid system, the requirement for useful thermal power is already defined. If less than or equal to 100 kW, the certification can be replaced by a supplier’s declaration. The applicable ceiling set by Annex A in this case varies between 420 and 540 €/kWt depending on the power.