The Superbonus was supposed to be a closed chapter. For Giorgia Meloni, however, it risks turning into a much more complicated problem than public finances: a question of the State’s credibility towards banks and businesses. The government has in fact decided to postpone for almost a decade the use of 18.5 billion euros of tax credits which, according to the previous rules, should have been compensated in 2027. A choice that allows the Treasury to immediately lighten its financial needs, but which risks passing on billions of costs to economic operators. And above all it opens a clash on the possibility that the State unilaterally changes the commitments undertaken towards those who purchased those credits.
The Italian Banking Association raised the case in the hearing on the 2027 budget law presented to the Budget commissions of the Chamber and Senate. The ABI uses a particularly harsh expression: the measure “would appear to be like a forced restructuring of a state debt”. In other words, according to the banks, the government is changing the conditions of a commitment already made, forcing creditors to wait many more years to recover what they are owed.
To understand the scope of the issue we must start from an apparently technical arrangement of the maneuver. Article 37 of the budget bill intervenes on Superbonus tax credits relating to expenses incurred in 2023 and transferred through the transfer of credit or the discount on the invoice. Under the original rules, these credits could be used in four annual installments, from 2024 to 2027. The first three years are not affected. The government instead wants to divide the last tranche, the one scheduled for 2027, into ten equal installments, usable until 2036. Credits for which the previous ten-year distribution option had already been exercised are excluded.
Let’s take an example. A bank that had purchased Superbonus credits expecting to offset 10 million euros in 2027 could only use one million with the new rules. The other nine million would be recovered, one million per year, between 2028 and 2036. The nominal value of the credit does not change, but the economic one changes radically: being able to use ten million immediately does not equate to recovering it over ten years, especially considering inflation and the cost of money.
Financial effects of 20 billion from the Superbonus
The overall figures explain why the government chose this path. According to the technical report on the maneuver, the credits involved amount to 20.537 billion euros. Of these, only 2.054 billion can be used in 2027. The other 18.483 billion are postponed to subsequent years. The result is also certified by the Chamber’s research services dossier: the provision determines lower expenses of 18.483 billion in 2027 in terms of net balance to be financed and requirements, offset by higher expenses of approximately 2.054 billion per year from 2028 to 2036.
For the State it means having to find less liquidity in 2027. For banks and businesses it means exactly the opposite: resources on which they had built their balance sheets and financial programs will no longer be available within the expected timescales. And this is the point on which the Abi attack focuses. The credit institutions purchased the Superbonus tax credits by applying prices that took into account the deadlines established by law. By advancing money to businesses and other entities, they acquired the right to use those credits to pay less taxes in subsequent years. If the calendar is changed after the purchase, the economic balance of the operation is also altered.
Access to credit is more difficult for businesses
The banking association warns that the measure would cause “significant negative effects on the income statements, on assets, on liquidity which is associated with a further cost associated with inflation”. The problem does not only concern banks. Even companies that hold tax credits may find themselves having to finance their business with other resources. The Abi also reports a possible worsening of their creditworthiness, with consequences on the possibility of obtaining financing.
But there is a second problem, potentially even more delicate for Palazzo Chigi. The ABI disputes the retroactive modification of the economic conditions on which the operators had relied. And it recalls ruling 111 of 2024 of the Constitutional Court, which in a different tax dispute had censured the distorting effects of a regulation capable of affecting “now and then” the economic calculations of companies. There is thus a risk of opening a dispute that goes beyond the fate of the Superbonus. If the State can recognize a tax credit, allow its transfer and subsequently change its deadlines, those who purchase other public credits in the future will also have to take into account the risk of a change in the rules.
Furthermore, the protest comes as the government asks the banks for a new contribution to finance the measure. According to ABI calculations, the fiscal measures introduced with previous budget laws have already led to an overall increase in taxes of almost 15 billion euros. The bill for 2027 would add another 7 billion over the three-year period, including higher definitive taxes and tax deferrals. The total bill indicated by the association thus reaches 22 billion.