Exceeding 85,000 euros in the forfetario regime: what happens this year, next year and with the 100,000 threshold

In short: as of 23 October 2026 there are three bands. If you collect up to €85,000 you remain in the forfetario regime. If you exceed 85,000 euros without reaching €100,000, you remain forfetario until 31 December and move to the ordinary regime from the following year. If you exceed €100,000, you exit immediately and apply VAT from the collection that takes you over the limit. The €100,000 threshold for 2027 is still a press proposal.

What happens if you exceed 85,000 euros in the forfetario regime?

It depends on how much you exceed. If in the year you collect more than €85,000 of revenue or fees, but not more than €100,000, you remain forfetario for the whole year and leave it from the following 1 January. Above €100,000 the regime ends immediately, at the very moment of exceeding it. This is provided by art. 1, paragraph 71, of Law 190/2014 (Law 190 of 2014), as explained by circular 32/E of 2023.

The Revenue Agency circular no. 32/E of 5 December 2023 (§2.1) puts it this way: exceeding €85,000 while staying below €100,000 "does not affect the continuation in the forfetario regime in the year in which the excess occurs", but results in exit "from the following year, with consequent application of the ordinary regime". Exceeding €100,000, on the other hand, results in "the immediate cessation of the forfetario regime from the very moment of the excess".

For the threshold, do invoiced or collected revenue count?

Collected revenue. In the forfetario regime income is determined on a cash basis (art. 1, paragraph 64, L. 190/2014) and for the thresholds what you received during the year counts, not what you invoiced. An invoice issued in December and paid in January weighs on the year of collection: it is the collection, not the invoice, that takes you over the limit.

• 85,000-euro threshold: for those already in the forfetario regime, what is collected during the year counts, "even where the underlying transactions were carried out in earlier years", without counting what was invoiced but not collected (circular 32/E, §2.1).
• €100,000 threshold: "the collection of the same and not the issue of the related invoice" is relevant (circular 32/E, §3.1.1); the cash criterion applies to both VAT and IRPEF and withholdings (§3.2).
• Activity started during the year: the 85,000-euro threshold is pro-rated to the year, the €100,000 one is not. Exceeding €100,000 must be understood "in absolute terms", on the fees actually received (circular 32/E, §4.3).

What happens if you collect between 85,000 and 100,000 euros?

For the current year, nothing: you continue to invoice without VAT and pay the 15% substitute tax on forfetario income. From 1 January of the following year you move to the ordinary regime: progressive IRPEF with regional and municipal surcharges, VAT on invoices with periodic settlements and the annual return, and, for professionals, the withholding tax on fees.

Two less well-known consequences, both in circular 32/E:

• Adjustment of VAT not deducted. Moving to the ordinary regime, you can recover in one go the VAT paid and not deducted under the forfetario regime on goods and services not yet sold or used at 31 December of the year of exceeding, and on depreciable assets put into use less than four years earlier (ten years for buildings), under the conditions of art. 19-bis2 of the VAT decree. If you exceed 85,000 euros in year x, the adjustment goes into the VAT return for year x+1, to be filed in year x+2 (§2.2).
• Return. The ordinary regime is not for ever: if in the year spent in the ordinary regime you collect no more than 85,000 euros, and the other requirements remain, you can return to forfetario from the following year. The circular states this for those who had exited for exceeding €100,000 (§4.2), on the basis of the access threshold of paragraph 54.

You can see how much the move to the ordinary regime weighs in the example below, or in the guide forfetario or ordinary regime: which is better.

What happens if you exceed 100,000 euros during the year?

You leave the forfetario regime at the moment you collect the fee that takes you above €100,000. From that transaction onwards you apply VAT, keep the registers and make periodic settlements. The income for the whole year, including the part collected earlier, is calculated under the ordinary rules (progressive IRPEF), not with the substitute tax.

The obligations, point by point, according to circular 32/E:

• The invoice that takes you over the limit carries VAT on the full amount, without splitting it between the part up to and the part above €100,000 (§4.1). Example from the circular: with €90,000 already collected, a €20,000 transaction collected immediately must be invoiced with VAT on all €20,000.
• If the invoice had already been issued without VAT and the collection arrives later, you supplement it with an upward adjustment note through SDI (Exchange System) (art. 26 of the VAT decree), charging the VAT to the client (§3.1.1).
• Invoices issued before that collection remain without VAT, even if they are paid later (§3.1.1).
• From the moment of exceeding you set up the VAT registers (arts. 23, 24 and 25 of the VAT decree) and the accounting registers, make periodic settlements and file the annual VAT return; transactions from before the excess are recorded by the deadline of the return (§3.1.1 and §3.2).
• Withholding tax: if you are a professional, clients apply the 20% withholding (art. 25 of Presidential Decree 600/1973 (D.P.R. 600/1973)) from the fee that takes you over the limit onwards, including on invoices issued earlier but collected later; and you become the withholding agent on the fees you pay (§3.3).
• VAT on purchases: the adjustment of VAT not deducted on inventories and depreciable assets goes into the VAT return for the same year as the excess (§2.2 and §3.1.2).
• Taxes for the year: the balance is calculated under the TUIR (Consolidated Income Tax Act) rules for the whole tax period; advance payments follow the historical or forecast method (§3.2).

How much does it change, in euro, if you collect 92,000 euros?

For a professional in separate management who collects 92,000 euros, with the 2026 parameters, tax and contributions are €26,665.66 in the year of exceeding and €33,720.26 the following year, under the ordinary regime, with the same collections. With the €100,000 threshold proposal you would remain at €26,665.66: €7,054.60 less.

The steps, calculated by the same engine as the simulator:

1. Forfetario income: €92,000 × 78% (coefficient for professional activities) = €71,760.00.
2. Contributions in separate management: €71,760.00 × 26.07% = €18,707.83, deducted from income: taxable amount €53,052.17.
3. Year of exceeding, forfetario: €53,052.17 × 15% = €7,957.83 of substitute tax. With contributions: €26,665.66.
4. Following year, ordinary regime: the simulator assumes real costs equal to 22% of revenue, that is what the forfetario regime presumes (€20,240.00), so income €71,760.00, contributions €18,707.83, taxable amount €53,052.17. Progressive IRPEF (23% up to €28,000, 33% up to €50,000, 43% above): €15,012.43; deduction for self-employment €0.00, because income exceeds €50,000. With contributions: €33,720.26.
5. 2027 proposal: you would remain forfetario also the following year, with the same calculation as point 3: €26,665.66. Difference: €7,054.60 a year.

What is left out of the calculation: the regional and municipal IRPEF surcharges of the ordinary regime (they vary by area), deductions other than the one for self-employment, your real costs if they differ from the presumed ones, and VAT, which under the proposal reported by the press would in any case be on invoices above 85,000 euros. Change activity group, cash basis or costs in the simulator, in the grey zone section.

What would change if the threshold rose to 100,000 euros?

The band between 85,000 and 100,000 euros would remain under the substitute tax also the following year, instead of moving to progressive IRPEF. But it would not go back to being without VAT: according to press leaks, above 85,000 euros VAT would go on invoices, because the VAT exemption is set by the European directive and a Member State cannot raise it alone.

What the press reports, which remain proposals:

• Sky TG24, 13 October 2026: it is being studied to "raise from 85 thousand to 100 thousand euros the threshold of revenue and fees" of the 15% flat tax; the extension would also require changes to the VAT rules and a discussion with the European Commission.
• Alanews, 20 October 2026: those in the additional band would remain under the substitute tax on income but would apply VAT with the related obligations; those who exceed the new ceiling would exit the regime immediately; the proposal still has to find funding.

From which collection VAT would start during the year, and under which deduction rules, no official text says yet. Why VAT stops at 85,000 euros and what it would mean on invoices is explained in the guide forfetario at €100,000 but VAT from 85,000 euros.

What is certain and what is still a proposal?

The three current bands are certain, because they are law: up to 85,000 euros, between 85,000 and 100,000 euros with exit from the following year, above 100,000 euros with immediate exit and VAT. The €100,000 threshold for 2027 is a proposal: as of 23 October 2026 the draft budget law has not yet passed the Council of Ministers.

• Certain: art. 1, paragraphs 54 and 71, of Law 190/2014, text in force; Revenue Agency circular 32/E of 5 December 2023; cash criterion for the thresholds.
• Certain: the Council of Ministers of 13 October 2026 (press release no. 192) approved only the Documento programmatico di bilancio (budget programming document), which does not mention the forfetario regime. For the budget law to take effect from 1 January 2027, Parliament must approve it by 31 December 2026.
• Proposal: forfetario up to €100,000 with VAT from €85,000 (Sky TG24 13/10/2026, Alanews 20/10/2026). The text may change until the final vote.

The milestones and dates are in the guide 2027 budget law and flat tax: the milestones; the full picture in the 2027 flat tax for VAT-registered freelancers hub. If you are close to the threshold, the moment you collect an invoice can change the year of exceeding: it is a choice to make with your accountant, on your own figures.

Sources

• L. 23 December 2014 no. 190, art. 1 paragraphs 54-89 (forfetario regime, text in force on Normattiva), accessed on 23/10/2026
• Agenzia delle Entrate, circular 32/E of 5 December 2023 (§2.1, §2.2, §3.1, §3.2, §3.3, §4.1, §4.2, §4.3), accessed on 23/10/2026
• Agenzia delle Entrate, "Regime forfetario" page, accessed on 23/10/2026
• Council Directive (EU) 2020/285 of 18 February 2020 (new art. 284 of Directive 2006/112/EC), accessed on 23/10/2026
• Government, Council of Ministers press release no. 192 of 13 October 2026, accessed on 23/10/2026
• Sky TG24, 13 October 2026 (press proposal), accessed on 23/10/2026
• Alanews, 20 October 2026 (press proposal), accessed on 23/10/2026