Technical Analysis
Bill Decree 21/2026: How to modernize a plant in an industrial area without authorization
📅 May 2026
⏱ Reading time: 5 minutes
PVclick Strategy Team
Operational and commercial analysis for the Italian PV sector
What you will find in this article
- Which interventions fall within the scope of free activity according to Article 5 of Legislative Decree 21/2026?
- The operational decision on the incentive spread will be made by May 31, 2026.
- How to build an integrated offering: "HPBC 2.0 module revamp + BESS + incentive spreader"
- Three concrete actions to position yourself in the Conto Energia portfolio of your existing customers.
The regulatory framework: two innovations in a single provision
The two measures are complementary rather than alternative. The first opens the physical construction site (you can redo the system without permits), the second decides the financial coverage (you can extend the GSE agreement or terminate it early). Those selling repowering solutions to their existing Conto Energia customers have the widest window seen under Italian legislation in the last five years.
Revamping in free activity: what it means in concrete terms
Article 5 of the decree amends the Consolidated Renewable Energy Act by introducing a clear point: the complete overhaul of already authorized or certified photovoltaic systems located in industrial areas falls under the free activity regime, provided that after the intervention the system remains entirely within the same industrial area, regardless of the resulting overall power output.
Translated into construction site language: you can replace modules, inverters, structures, cables, and foundations of an existing system, even significantly increasing its power output, without requesting a new authorization and without going through PAS, DILA, or authorization procedures. This applies to systems in industrial areas, regardless of their intended size.
📊 The operational implication
The Italian photovoltaic park in industrial areas has a significant share of systems with technology dating back to before 2018. Replacing 270-300 W polycrystalline modules with 670 W LONGi Hi-MO X10 HPBC 2.0 back-contact modules allows for a 50-100% increase in installed power on the same footprint, without requiring authorization. This is the greatest repowering opportunity seen in Italian legislation in recent years.
Incentive Spreading: Strategic Decision by May 31, 2026
The options in detail:
The most notable detail is the last line: the early exit from the Energy Bill is conditional on a complete revamping to be carried out between 2028 and 2030. This means that those considering replacing their modules with HPBC 2.0 technology and adding storage have a two-track path: they exit the historical incentive with 90% of the NPV in their pocket and position themselves on the post-revamping free market. This is exactly the type of operation that the converted text has unlocked.
The three customer families on which to build the offering
1. C&I asset owner with plants in industrial areas and active Energy Account
This is the most advantageous combination. The asset owner must decide on the incentive spread by May 31, 2026, and has the option to renovate the system while it remains open for business. The winning commercial proposal is an integrated analysis, a financial simulation of the two incentive spread options versus early exit, sizing of the repowering with HPBC 2.0 modules, and BESS integration for evening self-consumption. Anyone who fails to submit this analysis by May 2026 will lose their customer when a competing energy consultant arrives.
2. Asset owners of utility-scale plants in industrial areas beyond the incentive period
For systems that have already opted out of the Conto Energia incentives (under the market regime), revamping into free-market operation is purely economic: it is undertaken if the new high-efficiency modules generate a revenue delta that repays the CAPEX within a reasonable timeframe. With the cannibalization of the PUN during solar hours (see the Terna 2026 table), the calculation must include storage, otherwise the revenue delta evaporates.
3. Industrial companies with old plants above their production site
Here, the selling point is covering the company’s energy needs: renovating the system with more efficient modules means covering a greater share of industrial consumption, reducing exposure to the PUN (Pun) (Punctual National Unit), and accessing Transition 5.0 for the newly installed portion. Free operation eliminates the main historical obstacle: the fear of lengthy and uncertain authorization procedures. The sales conversation can start with the CFO, not the technical manager.
How PVclick supports revamping
The relevant product lines for revamping in industrial areas are three: LONGi Solar modules with the Hi-MO X10 HPBC 2.0 range for high-efficiency replacement, metallic structures sized for new formats and static loads, BESS storage systems for those who want to uncouple their economic plan by compressing the PUN during solar hours. The logic is the same as always: shorten the supply chain, speak directly with the factory, secure the right lots at the right price, and avoid the markups of traditional distribution.
The three actions to close immediately
- Survey the historical customer portfolio with PV systems in industrial areas and active Energy Account, separating the candidates for incentive-spreading from the candidates for early exit + revamping
- Build the integrated proposal for incentive-spreading + repowering of HPBC 2.0 modules + BESS, with financial simulation closed over 25 years and not on the initial CAPEX
- Block the supply chain of modules, structures and storage for the 2026-2028 timeframe, before market pressure on Tier 1s raises price lists
Do you have clients with industrial facilities that need renovating?
We help you build your revamping offering with LONGi Hi-MO X10 HPBC 2.0 modules, dedicated metal structures, and BESS systems, directly from Tier 1 manufacturers, with quotes based on actual volumes and delivery times aligned with your construction site schedule.
Four-quadrant incentive-spreading decision matrix (Option A 15%/3 months, Option B 30%/6 months, No membership, Early exit + revamping 2028-2030).
