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Catania, Italy · Working across Italy

Free activity, PAS or single authorisation: how to read the Italian Renewables Consolidated Act

By the Amato Consulting team

Engineer at a table with project drawings and a tablet

In brief

  • The Consolidated Act (Legislative Decree 190/2024), in force since 30 December 2024, provides for three regimes: free activity, PAS and single authorisation.
  • The regime depends on technology, capacity, area and constraints, according to Annexes A, B and C.
  • The text has already been amended by corrective Legislative Decree 178/2025 and Decree-Law 175/2025: it must be read in its current version.

The Consolidated Act gathered into a single decree rules that were previously scattered across many sources. For those developing plants, though, the first step remains the same: understanding which route applies to the individual project, because timing, documents and counterparts depend on it.

The three regimes

RegimeHow it worksWatch out for
Free activityWorks listed in Annex A, with notification where requiredConstraints and consents may still be required
PASSimplified authorisation procedure at the Municipality, for the works in Annex BCompleteness of the documents and consents to be obtained
Single authorisationSingle procedure with a services conference, for the works in Annex CCoordination with the environmental assessment and grid works

Environmental impact assessment follows its own rules (Legislative Decree 152/2006): a plant can fall under a simplified regime and still need an environmental check, or the reverse. The two readings must be done together.

What determines the regime

  • Technology and capacity, including the thresholds in the annexes.
  • Area: suitability, acceleration zones, zoning.
  • Constraints: landscape, cultural, natural, hydrogeological.
  • Type of work: new plant, modification or upgrade of an existing one.
  • Associated works, starting with the connection, which may fall under the same permit as the plant.

The amendments to keep in mind

Corrective Legislative Decree 178/2025, in force since 11 December 2025, changed among other things definitions, storage and the digitalisation of procedures through the SUER platform. Decree-Law 175/2025, converted by Law 4/2026, added the rules on suitable areas to the Consolidated Act. For procedures started before the Consolidated Act there are transitional rules, with the option for the applicant to choose the new rules.

Before filing

  1. Place the works within the annexes, in the current version of the text.
  2. Map the constraints and the authorities that will need to give an opinion.
  3. Check any environmental procedure at the same time.
  4. Align layout, capacity and connection point across the design, the connection quote and the application.
  5. If the procedure is already under way, assess the transitional rules.

An application that is consistent from filing reduces requests for additional information, which often weigh on timing more than the formal length of the procedure.

Information text, updated to the date of publication: it does not replace legal advice on the individual case.

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