Conto Termico 3.0: booking confirmed, also for third-sector entities

Who counts as a third-sector entity for the Conto Termico

DM 7 August 2025 (art. 2, paragraph 1, letter n) considers as third-sector entities those defined by art. 4 of Legislative Decree 117/2017 and registered in the RUNTS: voluntary organisations, social promotion associations, philanthropic bodies, social enterprises, foundations and the other registered entities. An association not registered in the RUNTS cannot apply as a third-sector entity; it can, however, be the third party using a municipal building for which the Municipality submits the application.

Non-economic and economic entities

• Entity not carrying out economic activities: treated as a public administration for eligible measures, access, payment, intensity of the incentive and cumulation (art. 4, paragraph 2, of the DM and section 3.3 of the implementing rules). It is the only one that can reach 100%.
• Entity carrying out economic activities: treated as a public administration only for access and payment; otherwise the rules for businesses apply (Title V of the DM), with the preliminary application before the works start and the corresponding incentive intensities.

The nature of the activity is determined by the RUNTS registration; in the application the entity declares which of the two groups it belongs to, and the GSE can verify it.

Booking for third-sector entities

Booking is allowed for both non-economic and economic entities. The entity can apply on its own, as responsible party, also for a building it does not own but has at its disposal, or through an ESCO with an energy performance contract. The documents are those required of public administrations: instead of the administrative act, a resolution of the body competent under the statutes (members’ meeting, board of directors, steering committee) is required, committing the entity to carry out at least one of the measures in the energy audit; if the booking is based on the award of the works, an act of the same body certifying the handover to the contractor is required.

Since 13 April 2026 the Portaltermico accepts only direct-access applications. The corrective decree confirms booking and regulates its resources: with its adoption the booking window is expected to reopen shortly. Details are on the page dedicated to public administrations.

When the incentive reaches 100%

For a non-economic entity the incentive normally covers up to 65% of eligible costs. It reaches 100%, within the caps, in two cases (art. 11, paragraph 2, of the DM and sections 4.2 and 12.11 of the implementing rules):

• building owned by a Municipality with up to 15.000 inhabitants, used by the entity for public and social activities or services of collective interest assigned to the local authority, such as sports facilities, theatres, museums, libraries, schools, nurseries and social services. The application must include the declaration on the population threshold, the cadastral record of the municipal building and the title under which the entity uses it (concession, management agreement, lease), showing its use for services of general interest to the community;
• public building used as a school or public healthcare facility of the National Health Service, used by the non-economic entity, with an intended use that is unambiguously one of these functions (art. 48-ter of DL 104/2020); universities are excluded.

With the corrective decree, for buildings of Municipalities with up to 15.000 inhabitants 100% will remain for the first intervention only and fall to 80% for subsequent ones; the final text will have to clarify whether the first intervention is counted per Municipality or per building. For schools and public healthcare facilities 100% is confirmed.

Mind the duration of the title

The GSE can carry out checks throughout the payment period and up to five years after the last instalment, and the documents proving the requirements must be kept for the same period (section 11.1 of the implementing rules). The concession or free loan under which the entity uses the building should therefore cover an adequate period: losing the requirements can lead to forfeiture of the incentive.

Other changes in the corrective decree

• With direct access the incentive is paid in a single instalment only up to 50.000 euros; above that it is paid in annual instalments. For payment, third-sector entities follow the rules for public administrations.
• The GSE will be able to recover sums unduly received also from the collection agent, jointly liable with the beneficiary within the amounts collected.
• In bookings based on an audit and a commitment resolution it is no longer necessary to attach the standard EPC contract template.
• Energy audit and APE: the energy audit before the intervention and the energy performance certificate (APE) after it become mandatory also for window replacement and solar shading; today these measures require them only on buildings with heating systems of at least 200 kW.
• Some technical requirements change for biomass generators, solar shading and lighting.

How to prepare

Before setting up the application it is worth checking the RUNTS registration and how the entity’s activity is recorded there, the title of use of the building and its duration, and preparing the energy audit with the resolution of the competent body. VEE S.r.l. supports entities in these checks, in the energy audit and in the application to the GSE.