The rottamazione quinquies scheme introduced by the 2026 Budget Law allows debts owed to the Italian Tax Collection Agency (ADER) to be discharged by paying only the principal and statutory interest, without penalties or late-payment interest. The average effective reduction is 30–50% of the amount entered on the collection roll.
What is rottamazione quinquies?
It is the fifth edition of the preferential settlement scheme for debts referred to the Collection Agent. It applies to collection rolls referred between 1 January 2000 and 31 December 2023 (subject to amendments during conversion into law). Taxpayers who participate pay the principal and statutory interest and avoid penalties, late-payment interest and collection fees.
Who can participate?
- Individuals, professionals, sole traders and companies with debts entered on collection rolls during the eligible period.
- Those who participated in previous rottamazione schemes (including quater) and lost their entitlement through failure to pay instalments.
- Those who have lodged an appeal that is pending: participation entails abandoning the litigation.
Debts relating to the recovery of State aid, judgments of the Court of Auditors, criminal fines and penalties, customs duties and import VAT are excluded.
How much can actually be saved?
For a personal income tax (IRPEF) payment notice (cartella) of EUR 30,000 comprising EUR 20,000 in tax, EUR 6,000 in penalties and EUR 4,000 in late-payment interest, rottamazione quinquies reduces the amount payable to approximately EUR 21,000 (principal + statutory interest), giving an actual saving of approximately EUR 9,000 (30%).
For a tax payment notice (cartella) relating to INPS (Italian social security institute) contributions, where civil penalties account for a significant proportion, the reduction may exceed 50%.
Payment methods and instalment arrangements
The amount due may be paid:
- In a single payment by 31 July 2026 (indicative date, subject to confirmation in the implementing decree).
- In instalments spread over up to 10 annual payments (text awaiting final confirmation).
Failure to pay even one instalment results in loss of entitlement: the debt is reinstated in full, less any amounts already paid.
How to submit an application
Applications must be submitted exclusively online through the restricted-access area of the Italian Tax Collection Agency (ADER) website, or through an authorised intermediary (accountant, tax lawyer). Applicants must specify the debts they wish to settle: they may select only some of them.
When rottamazione is genuinely worthwhile
- It is worthwhile where the debt is certain, well documented, with no defects in service and no limitation defences that can be raised.
- It is worthwhile where the taxpayer intends to settle the matter definitively and has the necessary funds.
- It is not worthwhile where there are strong limitation defences or defects in service: an appeal may lead to cancellation in full.
- It is not worthwhile where the taxpayer cannot ensure that all instalments will be paid on time, because default results in loss of the benefit.
Differences from rottamazione quater
Compared with quater (DL 119/2018 and subsequent legislation), quinquies extends the period for eligible collection rolls to 2023, reopens the application window for those who lost their entitlement under previous rottamazione schemes, and changes the instalment plan. The reduction mechanism remains unchanged.
Frequently Asked Questions
Can I include tax payment notices (cartelle) already subject to instalment arrangements?
Yes. Participation in rottamazione ends the existing instalment arrangement and the new plan applies. Amounts already paid are not lost: they are credited against the outstanding debt.
What happens if I have a pending appeal?
Participation entails abandoning the litigation. This requires careful assessment: if the litigation position is strong, it may be worthwhile continuing the proceedings.
Can I participate if I lost my entitlement under rottamazione quater?
Yes. One of the new features of quinquies is precisely the reopening of applications for those who lost their entitlement under previous rottamazione schemes.
The Firm Marzo Associati offers a preliminary technical assessment to determine whether rottamazione quinquies is the right choice for your circumstances, weighing the reduction against possible limitation defences and defects in the tax payment notice (cartella). Request a consultation.
