On 2 September 2026 MIMIT, the Ministry of Enterprises and Made in Italy, published its decree of 13 July 2026 amending Smart&Start Italia, Invitalia's zero-interest loan for innovative startups. The changes apply from the publication of an implementing circular that, as of 7 October, has not appeared; meanwhile the application window is open. Anyone who wants to fund a software product has to choose between applying now, under the rules Invitalia describes today, and waiting for the circular. Either way, the plan starts after the application.
What changes and what stays the same
The decree aligns the scheme with the definition of innovative startup in Law 193/2024. A notice appeared in the Official Gazette no. 213 of 14 September 2026.
| Item | Rule | With the decree |
|---|---|---|
| Companies | Innovative startups | Micro, small and medium (Invitalia: small only) |
| Insurance | Compliance with the natural-disaster obligation | Entry requirement added |
| Plan costs | From 100,000 euros to 1.5 million, excluding VAT | Unchanged |
| Loan | Zero interest, 80% (90% in set cases), up to 10 years | Unchanged |
| Tutoring | 10,000 euros, for companies incorporated up to 36 months ago | The limit was 12 months |
| Conversion into a grant | Up to 50% of the contribution, minimum 80,000 euros | Technology partners and non-EU investors with an Investor Visa join |
| Evaluation | In order of arrival, within 60 days | Simplified up to 250,000 euros, with the circular |
The 90% rate applies if, on the date of the application, the team is made up only of women and/or people aged up to 35 (Invitalia writes "under 36": it is the same threshold), or has an expert whose doctorate is no more than six years old and who has worked abroad in research or teaching for at least three years.
In the eight southern regions (Abruzzo, Basilicata, Calabria, Campania, Molise, Puglia, Sardinia and Sicily) only 70% of the loan for the plan's costs is repaid, working capital excluded; the rest is a grant. In one passage the MIMIT page writes "30% of eligible costs", but the consolidated text and Invitalia calculate the 30% on the loan.
Conversion applies in every region: with a cash contribution from third-party investors or individual shareholders, made after the grant and within five years, part of the loan becomes a grant, up to 50% of the contribution and at most 50% of the aid. Under the decree the investor must not already be a shareholder on the date of the deed or payment, nor have signed quasi-equity agreements before the application; the request is filed after the final balance is paid and within 60 days of the end of the five years.
The insurance obligation (Law 213/2023, article 1, paragraph 101) covers the assets listed in article 2424 of the Civil Code, item B-II, numbers 1, 2 and 3. The MIMIT page already lists it among the requirements for access and for disbursement, citing the decree of 18 June 2025: ask your accountant whether and how it applies to your startup.
What it covers for a software product
MIMIT lists these eligible costs: design, development, customisation and testing of IT solutions; technology consulting; incubator and accelerator services; marketing and web marketing; patents, trademarks and licences; staff and collaborators who meet the requirements for innovative startups, for the time they spend on the plan. Working capital, hosting and housing included, counts up to 20% of the other costs.
The loan is paid out in progress payments (at most five, each of at least 10% of the eligible costs); unpaid invoices count for up to 30% of the eligible costs, and payment is shown at the next stage.
The startup must hold innovative status (article 25 of Decree-Law 179/2012). Among the requirements MIMIT lists: a micro, small or medium enterprise under Recommendation 2003/361/EC, incorporated no more than five years ago, with no prevailing agency or consulting activity, meeting at least one of three innovation requirements (research and development, qualified staff, a patent or registered software). If the company lives on work done for clients, ask your accountant how its main activity will be read.
What it means for your spending plan
Take a plan with 150,000 euros of eligible costs, excluding VAT, to build an app and a backend, with testing and launch marketing. Assume a registered office outside the eight southern regions, a team that does not qualify for the 90% rate and no working capital. The loan would be 80%, or 120,000 euros at zero interest, and 30,000 euros would stay with the company [illustrative estimate, to be confirmed against your own project]. Repaid over 10 years, the maximum term, in constant half-yearly instalments, that is 20 instalments of 6,000 euros, starting from the twelfth month after the last disbursement and not tied to revenue [illustrative estimate, to be confirmed against your own project].
If, after the grant, a third-party investor came in with 100,000 euros in cash (the minimum is 80,000), at most 50,000 euros could be converted, 50% of the contribution; the cap of 50% of the aid, 60,000 euros on the loan alone, would not apply [illustrative estimate, to be confirmed against your own project].
What is not clear
- It is not clear from when the changes apply: article 2 of the decree ties them to the circular, which has not appeared as of 7 October; the MIMIT page already shows the new text, Invitalia's pages the previous rules. Ask Invitalia which rules it will apply to your application.
- The circular will have to define who is a qualified technology partner, who earns extra points by paying in cash at least 30% of the requested loan, and how the simplified evaluation and any simplified reporting will work.
- The MIMIT page mentions only 10 million euros of PNRR funds reserved for women-owned startups and does not say how much is left for the others; if the funds run out, the window closes early (article 7 of the 2014 decree).
Where we start
In a Smart&Start plan that funds a software product, the part that concerns us is the development line. If you hire us for it, we write the analysis first, then a quote and a roadmap that we agree with you before we begin; the work runs in phases with frequent releases, each a feature you can verify. For a plan like this we propose separate items by phase, each with its cost and delivery, and before the first invoice we ask for the application number and, after admission, the CUP, which Invitalia wants on the expense documents.
To estimate effort we have Metis, a software effort estimation engine: from a requirement and a little structural data it returns a median estimate, a calibrated 90% confidence interval and the most similar historical projects. It is in private pilot. In our view a spending plan holds up better when each figure has a range. We do not write the application to Invitalia and we do not assess eligibility: those are jobs for an accountant or a grants adviser. If you want us to look at the development lines of your plan, start from custom software or mobile app development, or get in touch.
Sources
- MIMIT: Decreto ministeriale 13 luglio 2026 - Smart&Start Italia. Sostegno alle startup innovative (2 September 2026)
- MIMIT: Decreto 13 luglio 2026, testo del decreto (PDF) (13 July 2026)
- Gazzetta Ufficiale: Comunicato relativo al decreto ministeriale 13 luglio 2026 (26A04801) (14 September 2026)
- MIMIT: Testo coordinato del Decreto ministeriale 24 settembre 2014 (PDF)
- MIMIT: Sostegno alle startup innovative (Smart & Start Italia)
- MIMIT: Startup innovative
- Invitalia: Smart&Start Italia
- Invitalia: Smart&Start Italia - Agevolazioni
- Invitalia: Smart&Start Italia - FAQ
