Is the Transition 5.0 tax credit still open?

Not for new applications. MIMIT says the window is closed and points to the new hyper-depreciation scheme. Firms with technically admissible filings on the old plan follow GSE/MIMIT notices (including the recognised share of the original credit). It is not a second window to “buy AI and deduct it”.

Does ChatGPT Business fall under Transition 5.0?

Usually no. ChatGPT Business is a service subscription. The new plan covers new instrumental assets, tangible or intangible, listed in Annexes IV and V to Law 199/2025 and interconnected with the production system or supply network. A monthly seat is not that kind of investment. Confirm with your accountant on the facts, not with an AI vendor.

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Implementation

Transition 5.0 in 2026: does company AI qualify? (hyper-depreciation)

Q: What is Transition 5.0 in 2026?

Two different schemes under the same GSE portal name. The 2024–2025 tax credit (Art. 38 of Decree-Law 19/2024) is closed to new applications. For investments from 1 January 2026 to 30 September 2028, MIMIT’s New Transition 5.0 Plan is hyper-depreciation, not an F24-offsettable credit.

Q: Can a custom AI agent be subsidised?

Only if the software is an Annex V intangible, capitalised (not a SaaS fee to be checked separately), interconnected, with a sworn technical report and GSE filings. An agent on invoices, HR or office documents almost never qualifies. The project must stand on the process, not on the incentive. 2026 market bands: €15,000–€35,000 setup for a production agent.

Q: Does Zendata file the GSE application?

No. We are not accountants or energy managers. We can tell you whether the case is plant/Industry 4.0 software or an office agent — and in the second case the incentive is not the lever. The GSE filing stays with you, your accountant and the expert.

26 Aug 20266 min read

Transition 5.0 in 2026: does company AI qualify? (hyper-depreciation)

In August 2026 a search for “Transition 5.0” hits two different schemes. The 2024–2025 tax credit is closed to new applications. For investments from 1 January 2026 to 30 September 2028, MIMIT opened the New Transition 5.0 Plan: hyper-depreciation, not an F24-offsettable credit. ChatGPT Business, seat-based Copilot and an admin agent usually do not qualify. Plant software listed in the legal annex and interconnected might: your accountant and a sworn report decide that, not an AI vendor.

General information, not tax advice. Dates, rates and annexes must be checked on MIMIT/GSE and with a qualified professional.

Two schemes, one name on the GSE portal

MIMIT keeps both the original-plan page and the new-plan page online. Mixing them up is the fastest way to buy the wrong AI “because there is a subsidy”.

	Transition 5.0 credit (closed)	New Plan 5.0 — hyper-depreciation
Legal basis	Art. 38 Decree-Law 19/2024	Art. 1(427)–(436) Law 199/2025 (2026 budget)
Investments	1 January 2024 – 31 December 2025	1 January 2026 – 30 September 2028
Mechanism	Tax credit offset on F24	Uplift of cost only for depreciation / lease charges. Not an F24 credit
Typical condition	Energy cut: ≥3% plant or ≥5% process	New assets in Annexes IV and V, interconnected with production or the supply network; plus self-production plants
New applications	Closed (MIMIT points to the new plan)	Booking on the GSE platform (live from 12 June 2026)

For old-credit filings already found technically admissible, MIMIT’s 29 April 2026 notice sets a contribution of 89.77% of the original amount, within a €1,302.3 million cap, usable on F24 (tax code 7079) by 31 December 2026. That is a tail of the closed plan, not a new window for someone starting today.

What hyper-depreciation covers (MIMIT figures)

The official new-plan page is clear: taxable-income reduction, not a bonus to “claim” like a 4.0 F24 credit.

For tangible assets (Annex IV) and self-production plants, MIMIT publishes these cost uplifts:

Investment tranche	Cost uplift
up to €2.5 million	180%
over €2.5 million up to €10 million	100%
over €10 million up to €20 million	50%

Intangibles (software, systems, platforms) sit in Annex V of the same law, with an interconnection duty. Software rates and the ownership vs licence vs cloud tests are in the implementing decree of 7 May 2026: we do not invent them here. Your accountant reads the text, not an AI vendor post.

Access: filings on the GSE portal (booking, 20% down-payment confirmation, completion), plus a sworn technical report and an accounting certificate.

Does company AI qualify? Almost never in that sense

Usually no, if by “AI” you mean:

a ChatGPT Business or Microsoft Copilot subscription;
a website chatbot;
an agent that reads invoices, mail, CVs or an office ERP.

That is a service or an admin-process project. The new plan is about new instrumental assets interconnected with production or the supply network — the same family as the old Industry 4.0 Annexes A and B, updated. A ~€21/month seat is not that asset.

It can qualify if you already have (or are buying) a real 4.0 piece: MES, plant energy monitoring, line software, an interconnected platform. There, AI that sits in Annex V and in the sworn report is a module of the digital machine, not “we put ChatGPT in admin”. Same split as agent vs chatbot and connecting an agent to the ERP: writing into a production ERP is not opening a chat.

When the old 5.0 window was open, it also covered energy-dashboarding software and, if bought with it, certain enterprise-management packages — always inside a project with certified energy savings. That track is closed to new applications. It is not a precedent to copy onto an HR agent in 2026.

The project must stand without the incentive

2026 market bands for a custom AI agent in production remain €15,000–€35,000 setup (a PoC often €3,000–€8,000; with ERP actions toward €35,000–€60,000). Not a Zendata price list.

If hyper-depreciation does not apply, the number does not change: either the process is worth that money in hours, errors and cycle time, or you do not do it. Using the incentive as the only justification is the classic way to buy software you will not use. Metrics: AI ROI.

Zendata builds operational agents. We do not file GSE applications and we do not certify energy savings. If your case is a plant, we will say so and point you to whoever does the sworn report. If it is an office, we will say that too: the project may still make sense; the incentive does not.

What to do this week

Old 5.0 filings: accountant + GSE customer area only. Not an AI vendor.
Do not buy AI “because Transition 5.0 exists”. First: do you have a plant and 4.0 assets, or an office process?
If it is office (invoices, HR, documents, customer care): judge ChatGPT Business vs an agent on the merits. The incentive leaves the table.
If it is production: accountant and expert before the software quote. Then see whether an agent or AI module sits in Annex V.

FAQ

What is Transition 5.0 in 2026?
Two schemes. 2024–2025 credit: applications closed. New plan: 2026–2028 hyper-depreciation on the GSE portal, not an F24 credit.

Is the tax credit still open?
Not for someone starting today. Tails on already-admissible filings: MIMIT/GSE notices, not a new call.

Does ChatGPT Business qualify?
Usually no: it is a subscription, not an interconnected Annex IV/V asset.

Can a custom AI agent be subsidised?
Only if it is Annex V software, capitalised, interconnected, with a sworn report. An invoice or HR agent almost never. ROI must stand alone.

Does Zendata file the GSE application?
No. We tell you whether the case is plant or office. The filing stays yours.

Sources

Dig deeper in the series

Write us two lines: (1) do you have a plant / 4.0 assets or an office process? (2) which process do you want to automate? We will say whether the incentive is even in the room — and, either way, whether an agent makes sense without it. info@zendata.it

Pietro Ciattaglia, CEO of Zendata AI, Rome