There is a moment, in Italy’s 2026 Budget Law, that marks a cultural shift even before a fiscal one. The reintroduction of super depreciation for the digital domain – replacing the current Industry 4.0 and 5.0 tax credits – is not just a change in accounting leverage.
It reflects a clear recognition: industrial value no longer lies solely in the steel of machinery, but in the lines of code that control it. At last, the legislator acknowledges that industrial software is productive infrastructure – not an add-on, not a support tool, but the very nervous system of the enterprise.
For years, we’ve described Industry 4.0 as the era of collaborative robots, interconnected machines and IoT sensors.
All true.
But real integration – the kind that drives efficiency, scalability and data control – doesn’t come from mechanics. It comes from application architecture.
From ERP systems that communicate in real time with MES in production, with WMS and TMS in logistics, and with corporate management systems. From platforms that orchestrate workflows, algorithms that optimise predictive maintenance, and AI applications that turn raw data into actionable insights for operational decision-making.
The new super depreciation framework reflects this reality. Eligible investments include ERP systems integrated with MES, WMS and TMS, WFA solutions for managing field operations, supply chain workflow automation platforms, and AI applications embedded in business processes.
But the key point isn’t the type of software purchased – it’s how it’s used.
The incentive rewards solutions that are interconnected, integrated into processes, and actively embedded in day-to-day operations. Not decorative tools, but core digital infrastructure.
The difference is substantial. In recent years, we’ve seen a rush to access incentives—purchases often driven more by tax windows than by genuine organisational transformation.
Today, the regulation introduces a clear responsibility: software must “run the business every day.” It must be interconnected, traceable and measurable.
In other words, it must generate structural productivity.
From a technical and tax perspective, the measure is highly impactful.
The acquisition cost—used to calculate depreciation charges and lease payments—is increased for investments made between 1 January 2026 and 30 September 2028, according to progressive tiers.
The uplift is 180% for investments up to €2.5 million, with an estimated tax benefit of 43.2% (based on a 24% IRES rate).
For the portion between €2.5 million and €10 million, the uplift is 100%, with an estimated benefit of 24%.
For the range between €10 million and €20 million, the uplift is 50%, with an estimated benefit of 12%.
The rates are significantly higher than in recent years, although the depreciation mechanism will result in a longer timeframe to realise the benefit compared to tax credits.
This is a deliberate shift – encouraging planned investments rather than one-off actions. It favours long-term industrial strategies over opportunistic moves.
Another key element is the “return” of Industry 4.0 software, which had been excluded from incentives in 2025.
That exclusion raised widespread concerns across the IT sector: there was a real risk of funding hardware without supporting the intangible layer that enables it to deliver real value.
Today, the legislator corrects that distortion – at a crucial moment for the country’s competitiveness.
Because the issue is not only fiscal – it is geopolitical and economic.
Italian companies, especially SMEs that form the backbone of our industrial fabric, are competing in markets dominated by global digital platforms.
US tech giants have built their competitive advantage on proprietary software infrastructures, integrated ecosystems, and the ability to leverage data at a global scale – supported by a particularly favourable tax environment.
The real challenge now lies in the ability to turn information into efficiency, into service, and into margin.
If Italy wants to protect and revitalise its manufacturing base, it cannot limit itself to incentivising the purchase of machinery.
It must strengthen its technological supply chain. It must enable Italian IT companies to develop advanced, integrable solutions that can compete with international players. And it must foster a qualified domestic demand – capable of absorbing innovation – within a self-reinforcing virtuous cycle.
The new super depreciation scheme moves in this direction. Incentivising integrated ERP systems, automation platforms and AI applications means stimulating a domestic market for industrial software. It means supporting system integrators, software vendors and technology consultants.
Ultimately, it means building culture and capabilities.
This is no small detail. Competing with US tech giants is not about matching their financial scale. It’s about specialisation, process alignment, the ability to customise, and local presence.
Italian IT companies have often proven their ability to deliver tailored solutions, perfectly embedded in SME production processes. But without adequate strategic support from industrial policy, competing with Big Tech remains a challenge.
As a result, digital transformation is too often perceived as a recurring cost – rather than a strategic asset.
A crucial question remains: companies’ ability to design coherent investment plans.
As always, the risk is that the measure is interpreted purely as a tax lever. But integrated software can only deliver its full potential if it is accompanied by process redesign, staff training and strong data governance. Installing an advanced ERP is not enough if the organisation continues to operate as before.
Super depreciation becomes a real driver of transformation when it is supported by a clear strategy and solid execution. It requires mapping information flows, defining measurable KPIs, and integrating sales, production, logistics, distribution and finance. Above all, it requires investment in digital capabilities.
Without data analysts, IT project managers, and professionals capable of orchestrating system integration, the incentive risks remaining on paper.
The good news is that the timeframe – until 30 September 2028 – provides a sufficient horizon for planning.
From a macroeconomic perspective, the potential impact is significant. Every euro invested in industrial software generates multiplier effects in terms of productivity, error reduction, inventory optimisation and faster cash cycles. In a country characterised by compressed margins and increasing international competition, operational efficiency becomes a decisive factor.
There is also a question of attractiveness. A digitised industrial system is more appealing to foreign investors, tech talent and international partnerships. Italy still lags behind the European average in ICT investment – closing this gap is essential to avoid progressive marginalisation.
But the real challenge will be execution.
Companies will need to prove they can turn the incentive into real transformation. Italian software vendors must seize the opportunity to raise the bar on innovation: cloud-native architectures, interoperability, security by design, and explainable AI.
If the economic system responds, 2026 could mark the beginning of a new phase.
No longer Industry 4.0 as a label, but as a pervasive infrastructure – an ecosystem where data flows across departments, maintenance is predictive, the supply chain is visible end-to-end, and human – machine interfaces become conversational, in natural language.
Ultimately, competitiveness is not an abstract concept. It is the ability to produce better, faster, with less waste. It is the ability to deliver integrated digital services to customers, personalise the offer, and respond to external shocks with agility.
For too long, digital innovation has been treated as a separate chapter – almost an add-on to the “real” business.
Italy’s 2026 Budget Law reminds us that business today is inherently digital. And without strong, integrated and intelligent software infrastructures, Italian manufacturing risks losing ground.
The game is open. The State has made its move – now it’s up to companies.
To invest not just for a tax benefit, but to build a lasting competitive advantage. Because, when competing with US tech giants, we may not match their scale – but we can play to our strengths: deep integration between technology and industrial know-how, agility, and the ability to adapt quickly.
And perhaps, this will be the first step towards true digital sovereignty – built not on declarations, but on continuously improving the processes that keep our businesses running every day.
