Conto Termico 3.0: Outlook and Updates

Author: Alessandro Pirrone

In recent years, the European Union has set ambitious goals that require a genuine transition toward a more efficient and sustainable energy system. Member states have responded by implementing various tax incentive programs that promote the energy retrofitting of buildings and the adoption of technologies for generating energy from renewable sources.

Among these, in Italy, there is also the so-called “Conto Termico, ” a measure introduced by Ministerial Decree of December 28, 2012, last updated by Ministerial Decree of February 16, 2016, and which is expected to be revised in light of the most recent European and national regulations.

The new “Conto Termico 3.0,” the draft of which was proposed in March 2024 and underwent public consultation through May 2024, aims to update the regulations governing incentives for small-scale projects. A separate measure aimed at incentivizing large-scale projects is expected to be defined at a later date, in accordance with the provisions of Article 10, paragraph 1, subparagraph (a) of Legislative Decree No. 199/2021.

The Changes Introduced by the Conto Termico 3.0 Program

With regard to the projects eligible under the Conto Termico 3.0 program, the following renovation projects aimed at improving the energy efficiency of existing buildings are worth noting:

• The specification states that “building automation” projects include the installation of temperature control and heat metering systems;
• The installation of infrastructure for private electric vehicle charging, including facilities open to the public, provided that the project is carried out in conjunction with the replacement of existing winter heating and cooling systems with systems equipped with electric heat pumps;
• The installation of solar photovoltaic systems and related storage systems under the same conditions as those described above.

Among small-scale projects for the production of thermal energy from renewable sources, the following are also mentioned:

• Combining “solar cooling” systems with solar thermal systems for domestic hot water production and/or to supplement winter air conditioning systems for production processes or for feeding into district heating and cooling networks;
• Projects to replace winter heating and cooling systems with connections to district heating systems powered by renewable energy sources, even if these systems also provide summer cooling;
• Replacement of existing winter heating and cooling systems with winter heating and cooling systems that use micro-cogeneration units powered by renewable energy sources.

Work involving the replacement of winter heating systems also includes work that entails disconnecting from a district heating network, provided that the network in question does not qualify as an efficient district heating network.

In particular, projects involving heat pumps must comply with the European Ecodesign Regulation, which establishes efficiency requirements based on the seasonal coefficient of performance (SCOP); therefore, only heat pumps that meet these requirements will be eligible for the incentives offered by Conto Termico 3.0.

With regard to eligible applicants and the procedures for accessing the incentive, please note that:

• Public Administrations (PA) may access all of the measures described above either directly or through ESCOs (Energy Service Companies), but the new development is that access can also be obtained through other public entities responsible for managing the buildings subject to the measures or those tasked, under current legislation, with implementing such measures, and these entities act as the responsible party. The use of public-private partnership ( PPP) contracts is permitted, and in such cases, public administrations may also access the incentives through private entities.
• The option to access all measures has now been extended to include collective self-consumption arrangements and Renewable Energy Communities, which may apply for the thermal account directly or, like ESCOs, through the designated representatives of such arrangements, including cases where the majority of the communities’ control powers are vested in public administrations.
• Third-sector entities in the residential sector are eligible only for small-scale projects, while in the nonresidential sector they are eligible for all the projects described above, either directly or through ESCOs.
• For private individuals, the same applies as for third-sector organizations.

The text specifies that ESCOs may only undertake projects that exceed a certain size (i.e., replacement of winter heating and cooling systems with new systems having a total capacity exceeding 70 kW, or installation of solar thermal systems larger than 20 square meters).

Maximum Eligible Costs and the maximum incentive amounts as established by the Ministerial Decree of February 16, 2016, for energy efficiency measures, were revalued in light of current market costs, defined based on data collected from the Applications for Incentives under the Conto Termico program submitted in the last two years, and in line with the maximum eligible costs specified from Annex I of the Ministerial Decree of August 6, 2020, which establishes the technical requirements for accessing “Ecobonus”-type tax credits, and by the Ministerial Decree of February 14, 2022, which specifies the maximum eligible costs for certain types of assets under the tax credits for buildings.

The monitoring activities provided for in Article 48 of Legislative Decree 199/2021 are always the responsibility of the GSE (Energy Services Operator), which must provide a report on the effects resulting from the implementation of this decree, with particular attention to the market prices of technologies and raw materials.

As for the timeline, in the case of direct access to the incentive, an application must be submitted to the GSE within 60 days of the project’s completion date. For public administrations, an advance grant is also available to cover the costs of preparing the energy audit, and there is the option to access the incentives through a reservation process, subject to specific conditions.

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