Provision of 23 October 2026: voluntary correction (ravvedimento) 2020-2023 for those who renew the biennial preventive tax agreement (CPB)

In brief: with the provision of the Director of 23 October 2026 (prot. no. 296141/2026) the Agenzia delle Entrate (Italian Revenue Agency) sets out the methods and deadlines for the voluntary correction of the tax years from 2020 to 2023 provided for by art. 29 of Legislative Decree 148/2026, for those who, having joined the biennial preventive tax agreement (concordato preventivo biennale, CPB) for 2024-2025, renew it for 2026-2027. The option is exercised tax year by tax year with the F24 form for the single or first instalment of the substitute taxes, between 1 January and 15 March 2027, with a maximum of ten monthly instalments.

Who can make the voluntary correction?

Only those who joined the CPB for the two-year period 2024-2025 and renew, within the legal deadlines, their adhesion for the two-year period 2026-2027. Those who join the tax agreement for the first time for 2026-2027 cannot correct the earlier years, and any payment made for that purpose has no effect (points 2.4 and 4.2).

Moreover, in each tax year subject to correction the taxpayer must:

• have applied the ISA;
• or have declared one of the grounds for exclusion from the ISA linked to the COVID-19 pandemic (introduced by the implementing decrees of art. 9-bis, para. 7, of d.l. 50/2017 and of art. 148 of d.l. 34/2020);
• or have declared a condition of non-normal performance of the activity (art. 9-bis, para. 6, letter a, of d.l. 50/2017);
• or have declared exclusion from the ISA for carrying on two or more business activities that do not fall within the same ISA, where the revenues from activities other than the main one exceed 30% of total declared revenues.

A taxpayer who in the same year had both business income and self-employment income may correct only if they exercise the option for both categories (point 2.3).

How is the option exercised?

By payment. For each tax year the option is exercised by submitting the F24 form for the single or first instalment of the substitute taxes (on income taxes and surcharges, and on IRAP), indicating in the field "Reference year" the tax year, the total number of instalments and the tax codes, which will be established by a subsequent resolution (point 3.1).

For companies and associations under art. 5 of the TUIR (Income Tax Consolidated Act) and for companies under arts. 115 and 116 of the TUIR (transparency regime), the option is considered exercised only with the submission of all the F24 forms for the single or first instalment: that of the IRAP substitute tax by the company or association, and those of the income-tax substitute taxes by the partners or members, or instead by the company or association, as allowed by art. 29, para. 11, of Legislative Decree 148/2026 (point 3.2).

What are the deadlines and instalments?

Terms of the 2020-2023 voluntary correction for those renewing the CPB (provision of 23/10/2026)

Element	Rule	Point
Window for the F24 for the single or first instalment	From 1 January 2027 to 15 March 2027	4.1
Instalments	Maximum of ten equal monthly instalments, with interest at the legal rate from 16 March 2027	4.3
When it is perfected, if paid in instalments	Upon payment of all the instalments, tax year by tax year	3.3
Instalment paid late	Does not cause loss of the instalment plan if it is not the first instalment and is paid by the due date of the following instalment	3.3
When it is not perfected	If the single or first instalment is paid after notification of a processo verbale di constatazione (tax audit report), of a draft assessment (art. 6-bis, law 212/2000) or of a recovery order for non-existent credits	3.4

On which data is the tax base calculated?

On the data of the returns filed, including for ISA purposes, as at the date of entry into force of Legislative Decree 148/2026, that is 12 August 2026 (point 2.2). Annex 1 indicates the relevant lines for each form: for example, for individuals, line RE25 of the RE section, the sum of lines RF101 and RF98 of the RF section and of lines RG36 and RG33 of the RG section; for IRAP, line IC76 for capital companies, IP74 for partnerships, IE61 for non-commercial entities and IQ68 for individuals (present up to 2021).

The annex warns that it does not cover cases of persons who, in the same period, carried on both a business and a self-employed activity and determined the value of production using the flat-rate methods of arts. 9 and 17, para. 2, of Legislative Decree 446/1997.

To help with the calculation, the Agency makes available in the tax drawer (cassetto fiscale), for each tax year and where available, the elements in its possession based on the data in Annex 1. They are visible to the taxpayer and to the delegated intermediary (points 5.1 and 5.2).

What to do in the practice, client by client

• Filter clients: only those who joined the CPB for 2024-2025 and renew for 2026-2027. Those who join for the first time are out.
• Check the tax years: for each year from 2020 to 2023, check in the return whether the client applied the ISA or declared one of the admitted grounds for exclusion.
• Business and self-employment income together: the option must be made for both categories, or not at all.
• Transparent companies: coordinate the company and the partners, because the option is exercised only with all the F24 forms for the first instalment; assess whether the company should pay in place of the partners.
• Ongoing audits: if the client may be served with a PVC (tax audit report), a draft assessment or a recovery order for non-existent credits, the first payment should be made beforehand.
• Calendar: F24 between 1 January and 15 March 2027, tax codes to be awaited from the announced resolution, calculation elements in the tax drawer with the delegation.

Assessing the convenience of the correction and managing the instalments is tax advisory work, one of the services for which the CNDCEC Technical Rules require anti-money-laundering due diligence on the client. With the free due diligence checklist using the CNDCEC method you calculate the risk and the measure due for the service, and print the record to keep in the file. On the CPB for associated professional practices, see also the ruling 191/2026 on the associated professional.

Sources

• Agenzia delle Entrate, provision of the Director of 23 October 2026, prot. no. 296141/2026 (methods and terms for communicating the options for the 2020-2023 substitute tax of those renewing the CPB 2026-2027), with Annex 1, read on 24/10/2026
• Legislative Decree of 7 August 2026, no. 148, art. 29, paras. 11 and 18, as cited in the provision
• Legislative Decree of 12 February 2024, no. 13, arts. 10-22 (biennial preventive tax agreement), on Normattiva