Hyper-depreciation: what the statutory auditor actually certifies

Two attestations, two different subject matters

Under the hyper-depreciation rules introduced by Law No. 199 of 30 December 2025 (the 2026 Budget Law) and defined by the implementing decree of the Minister of Enterprises and Made in Italy, in concert with the Minister of Economy and Finance, of 7 May 2026, completing the investments requires two distinct documents: a sworn technical appraisal, issued by an engineer or industrial expert registered with their respective professional bodies or by an accredited certification body, and an accounting certification prepared by a statutory auditor or a statutory audit firm.

The two attestations are not interchangeable. The appraisal concerns the technical characteristics of the assets and their interconnection; the accounting certification concerns the actual incurrence of the eligible expenses and their correspondence with the company's accounting records. Anyone considering engaging F.D.R. S.r.l. for this assignment should start here: the subject matter of the work is accounting, not engineering.

The scope of the accounting certification

F.D.R. S.r.l.'s service page describes the accounting certification as the attestation of the actual incurrence of eligible expenses and of their correspondence with the accounting records prepared by the company. The examination covers, in line with the scope required by the measure, accounting entries, invoices, payments and other relevant elements.

In practice, the auditor reconstructs the path of each expense: from invoice to accounting entry, from entry to payment, verifying that what has been declared is borne out by the records and supporting documents. This is not an opinion on whether the investment is worthwhile, nor an assessment of the technical merits of the asset purchased.

This distinction is not a formality. The decree requires that the accounting certification be submitted together with the attestations from the technical appraisal; if the subject matter of the two documents overlapped, the framework would lose its logic of control on complementary levels. The auditor does not replace the technical expert, and the technical expert does not replace the auditor.

Documentation, traceability and the limits of the verification

The quality of the certification depends to a large extent on the documentation available. Well-ordered accounting records, with invoices referable to the declared investments and traceable payments, make it possible to reconstruct each expense in a straightforward way. The implementing decree requires, among other things, that the investment confirmation notice state the date and amount of the payment corresponding to at least 20% of the acquisition cost of each asset, with references to the relevant invoices: elements which, on the accounting side, must be consistent with the records.

The decree further provides that the company must retain the documentation and that failure to retain it may result in forfeiture of the benefit. From the perspective of the accounting verification, this translates into specific attention to how documents are kept and how readily they can be retrieved: it is not enough for the expense to exist; it must be demonstrable through the accounting trail.

The limits of the verification follow from its subject matter. The certification does not attest that the asset meets the technical requirements set out in the annexes to the law, nor that the investment was completed within the deadlines: these aspects are the subject of the appraisal and of the communications to the Energy Services Manager (GSE). The auditor attests to what the accounting records and documents show; information from sources other than the accounting records requires its own specific checks, defined in the engagement.

How the engagement is set up

F.D.R. S.r.l.'s service page states that the engagement is defined on the basis of the applicable rules and the documents available, clarifying from the outset which aspects fall within the accounting verification. This approach is consistent with the nature of the certification: the scope is not identical for every investment and every company, and must be defined before the work begins.

In practice, defining the scope should clarify which assets and which expenses are subject to certification, which documentation is made available, how information not originating from the accounting records is handled, and which responsibilities remain with the company. It is worth remembering that the accounting certification does not relieve the company of preparing the documentation or of being responsible for the declarations submitted.

A hypothetical example may help. Consider a company that purchases an interconnected machine and submits the invoice, the accounting entry and the payment. The auditor can verify that the expense is recorded in the accounting records and that the payment is traceable; within the accounting certification, the auditor cannot determine whether the machine has the technical characteristics required by Annexes IV and V to the law: that assessment belongs to the appraisal. If the accounting documentation is incomplete, the auditor reports the limitation and the engagement takes it into account.

The practical value for those who must submit the notice

For a company intending to access hyper-depreciation, the accounting certification performs a safeguarding function: it makes what is declared to the Energy Services Manager (GSE) verifiable through the accounting trail. The decree provides for checks and the possibility of forfeiture where requirements are absent, documentation is not retained or declarations are false; a well-constructed certification does not eliminate these risks, but it strengthens the documentary basis of the notice.

F.D.R. S.r.l., a statutory audit firm, carries out this activity as part of the accounting certification of eligible costs. The technical verification of the assets remains the subject of a separate appraisal, entrusted to different professionals or bodies. Anyone considering the service should therefore ask first of all whether their accounting documentation is well ordered and traceable, and only then which technical aspects must be covered by other attestations.

Conclusion

The accounting certification for hyper-depreciation is a delimited check: it attests to the actual incurrence of expenses and their correspondence with the accounting records. It is not a technical appraisal and does not replace one. Its usefulness depends on the clarity of the scope and the quality of the documentation available; this is where the difference lies between an attestation that stands up to scrutiny and a document that leaves questions open.

General information content. For assessments relating to your company, it is necessary to examine the specific case.