The entry into force of the law of 18 July 2025, n. 105 (Published in the Gue n. 166 of 19 July 2025), which has converted with amendments on 21 May 2025, n. 73 – known as infrastructure decree 2025 – represents a regulatory intervention of strategic importance, intended to deeply affect the regulatory structure on public investments, strategic infrastructures and public contracts. The scope of the intervention is captured not only in the confirmation of certain urgent measures already contained in the decree-law, but also in the introduction of structural changes that aim to speed up the programming and execution of the works, to make the discipline more coherent with the operational needs of the contracting stations and to dissolve application nodes that emerged in the practice, in particular in the implementation of the PNRR.
One of the central chapters is dedicated to commissioner works, for which the legislator reiterates the need for a procedural acceleration, reaffirming the obligation of a territorial collective agreement for the construction of the bridge over the Strait of Messina, a symbol of the system of great strategic works. The commissioner system is also expanded with the provision of new extraordinary positions, including those for the works related to the Olympic and Paralympic games of Milan-Cortina 2026 and for the logistical center of Alessandria-sorting, the latter functional to the enhancement of the intermodal network and the integration of the freight flows from the ports of Savona and Genoa. The choice to resort to derogating powers and concentrated on the head of commissioner figures confirms the line of continuity of a legislator who, in the presence of strategic and urgent works, favors decision -making speed and the reduction of procedural overlaps.
On the level of administrative management, the conversion law confirms the changes regarding incentives for technical functions (art. 45 of Legislative Decree no. 36/2023), specifying the application of the new rules also to the ongoing procedures and started before the entry into force of the discipline. The rule thus responds to a concrete need for contracting stations and granting bodies: that of ensuring certainty to the criteria of allocation and recognition of incentives, reducing the risk of internal disputes and application disparities between administrations.
Ample space is reserved for custody in the urgency and emergency contracts (articles 140 and 140-bis of the contract code). The changes introduced point out the scope and limits of direct assignment, providing that the RUP or other technician in charge may order the immediate execution of works of up to 500,000 euros, or – if higher – within the limit strictly necessary to safeguard the public and private safety, always in compliance with the EU threshold. For civil protection interventions, the same roof is set, with an obligation of completion within 30 days, and with the prohibition to resort to the direct procedure for works above EU threshold and for services and supplies equal to or higher than triple this threshold. These clarifications, which affect a very delicate operational area, aim to avoid extensive interpretations and to circumscribe the use of derogations from the only necessary hypotheses, safeguarding the principle of competition and the transparency of the procedures.
A significant intervention is also recorded in the field of minimum environmental criteria (art. 57 of the Code), whose application to renovation interventions, including those of demolition and reconstruction, is now anchored to a criterion of reasonableness: the Cams must be adopted “as far as possible”, taking into account the type of intervention and location of the works. Thus the automatism deriving from the Mase ministerial decrees is overcome, opening the way to a more flexible and consistent application with the actual characteristics of the works, without sacrificing the objectives of environmental sustainability.
On the Civil Protection side (art. 46-bis of Legislative Decree no. 1/2018), the law merely consolidates the changes already introduced by the decree-law, reporting a substantial stability of the regulatory system in this sector, probably considered already adequate to respond to operational needs.
The reformulation of the rules on the price review rules (art. 60 of the code and art. 26 of the “aid” n. 50/2022) is of a strong practical impact. The law clarifies that the discipline of art. 60 also applies to contracts that do not fall within the hypotheses of the DL aid and limits the revision in decrease, provided for by art. 26, only the processes performed or accounted for in 2025. It is an intervention that aims to guarantee greater predictability to economic operators and contracting stations, avoiding criminal and uncertain retroactive applications.
Finally, in terms of certificate of execution of works (Cel) in subcontracting (articles 119 and 225-bis of the code), the law confirms the innovations already introduced by the decree-law, consolidating a mechanism aimed at making the certification of the services performed by subcontractors more linear and transparent.
Overall, law no. 105/2025 is not limited to extending or retouching existing provisions, but inserts targeted pieces in a regulatory mosaic that looks to two converging objectives: on the one hand, accelerating and making the implementation of strategic public works more efficient; on the other, stabilizing rules and criteria in sectors that have shown margins of application uncertainty. The expected effect is an improvement in the expense and realization of the works, while reducing the risks of litigation and guaranteeing a more coherent implementation of the PNRR and Post-Pnrr objectives.