Regulations & Commercial Strategy
Energy Bill Decree 21/2026: 10 GW of Revamping, 3 Strategic Choices for Installers
📅 March 2026
⏱ Reading time: 8 minutes
Legislative Decree No. 21/2026 is not a simple tariff revision: it officially opens
the season of mass revamping, with a mandatory operational deadline of
September 30, 2026. Those who position themselves now gain a competitive
advantage that will last for years. Those who wait will cede territory to competitors.
PVclick Strategy Team
Operational and commercial analysis for the Italian PV sector
What you will find in this article
- The decree's three concrete options and their financial implications
- How to quantify the commercial pipeline generated by the potential 10 GW
- Technical requirements for modules: the critical 21.5% efficiency constraint
- The purchasing strategy to protect margins on revamping orders
The Context: Why This Decree Changes the Market
Legislative Decree 21/2026, published in the Official Journal on February 20, 2026, was created with a stated objective: to reduce the ASOS component in Italian companies’ bills. This acronym represents the portion of system charges allocated to finance the Energy Account incentives, still active on systems installed between 2009 and 2013.
The operating result for the photovoltaic sector is far from trivial. According to industry estimates, at least 10 GW of the Italian installed base is potentially eligible for revamping incentivized by the decree, with a timeline defined by law. For an installer or distributor with an efficient sales structure, this means a quantifiable pipeline starting as early as the second half of 2026.
Key data
In Italy, over 18.5 GW of photovoltaic systems were already more than 10 years old by 2024, over 22% of which had a capacity exceeding 1 MW. These systems, built using technologies from 2009-2013, currently produce at 15-25% lower efficiency than modern installations. Legislative Decree 21/2026 creates the regulatory instrument to unlock this latent market.
Source: Energmagazine.it, December 2025
Analysis of the Decree: 3 Options, 3 Commercial Implications
The decree is divided into three levels of choice, each with specific deadlines. Understanding which option drives your potential customers toward an intervention allows you to craft the right sales pitch for each segment.
Option A
Reduction to 85%
Tariff reduced to 85% of the nominal value for the two-year period 2026-2027, with a three-month extension of the agreement. Low economic impact, but no incentive for technological renewal. Limited commercial interest for installers.
Option B
70% Discount
70% discount for 2 years, with a 6-month extension. Significant sacrifice with no technological gain. Application deadline: May 31, 2026. Defensive option for those who don’t want to invest.
Option C
Early Exit + Revamping
Compensation equal to 90% of the residual NPV (3.5% interest rate), paid over 10 years starting in 2028. In exchange: complete renovation from 2028 to 2030. Application deadline: September 30, 2026.
1. Option C is the Commercial Engine of the Decree
The third option generates real work for installers and EPC contractors. The system owner receives compensation equal to 90% of the net present value of the residual cash flows, discounted at 3.5%, distributed in equal annual installments for 10 years starting in 2028. In exchange, they must complete a complete overhaul by December 31, 2030.
The deadline to submit an application to the GSE is September 30, 2026. You have less than seven months to position yourself as a trusted technical and commercial partner for these owners. Whoever comes in first with a solid offer and a competitive purchasing strategy wins the contract.
2. The Technical Constraint on Modules: The Real Market Filter
Access to early exit is subject to stringent technical requirements for new photovoltaic modules. Ignoring these requirements during the quotation phase results in unqualified offers. The decree requires:
- Certified modules produced in the European Union or the EEA (European Economic Area)
- Minimum module-level efficiency of 21.5%, in line with the ENEA Register category A
- Durability guarantees of at least 25 years documented by the manufacturer
- Increase in production capacity at least double compared to the remaining period for standard systems, or +40% for ground-mounted and agrivoltaic systems
The EU/EEA geographic constraint is the critical point. The 21.5% threshold effectively excludes most first-generation modules still on the market and steers the choice toward latest-generation TOPCon technologies, which in the highest-performing commercial models already achieve 22-23% efficiency. This isn’t a problem for those with direct access to Tier 1 producers: it’s a barrier to entry that filters out unstructured operators.
3. Virtual Saturation Unlocked: New Projects in Previously Closed Areas
In addition to the revamping, the decree contains an often overlooked measure: the requirement for TSOs and DSOs to revise the criteria for calculating available capacity, distinguishing between actual power flows and nominally committed capacity from projects that were never realized. The expected result is the unblocking of stalled connections in areas that are only “saturated” on paper.
For installers and distributors operating in the C&I segment, this translates into concrete opportunities in geographic areas where, until recently, projects were stuck in the authorization phase. Monitoring communications from Terna and local DSOs in the coming months is part of the commercial strategy, not an ancillary activity.
4. PPAs with the Single Buyer Noticeboard: Expand the Post-Installation Offering
The decree promotes long-term negotiation through a PPA platform managed by the Single Buyer, with a 15% bonus mechanism on the difference between the market price and the contractual price. Plants exiting the Conto Energia scheme and those undergoing revamping will be able to access this tool.
For a distributor or installer with business clients, this opens the possibility of expanding their offering to include post-installation energy consulting services. The energy component sold at a fixed price for years is a solid business case, especially for industrial SMEs with stable consumption profiles.
Analysis of the Decree: 3 Options, 3 Commercial Implications
Moving from the norm to commercial data is the step that separates a theoretical analysis from a concrete strategy. The overall maximum capacity allowed for early phase-out is set at 10 GW. Not all plants will participate, but even a 30-40% penetration rate generates a market of 3-4 GW of installations between 2028 and 2030, with planning, procurement, and pre-sales to begin as early as 2026.
Market Opportunities
With an average value of €0.40-0.55/Wp for direct imports of TOPCon modules in batches of 500 kW+, a 3 GW market represents a critical purchasing mass in the order of one billion euros for modules alone. Whoever controls the supply chain at this stage controls the margins. Buyers on the spot market will pay the delay premium.
The eligible systems are primarily those from the 2nd and 3rd Conto Energia (2008-2011) programs, which currently feature module efficiency levels around 13-15%, centralized inverters with 95-96% conversion, and structures often not optimized for current bifacial technologies. The production gap between the old and new systems is real, measurable, and marketable as an ROI argument to the owner.
For the segment of plants on industrial sites, the decree introduces an additional advantage: complete renovations in industrial areas are classified as free regime under the Consolidated FER Act (Legislative Decree 190/2024), eliminating a significant portion of the permit burden. This reduces design and construction progress times, which translates directly into a commercial advantage for owners.
How PVclick Responds to This Structural Transformation
The DL Bollette 21/2026 creates qualified demand for high-efficiency modules with stringent technical requirements and defined operating deadlines. This is exactly the type of market where direct imports, without intermediaries, make the difference between a solid margin and a contract lost due to price.
PVclick’s Factory Connect service connects you directly to certified Tier 1 manufacturers, with access to TOPCon and HJT modules that meet the efficiency requirements set by the decree, with bankable guarantees lasting twenty years or more. The dedicated Italian team manages logistics, customs documentation, regulatory compliance, and pre- and post-sales technical support, eliminating unnecessary steps.
For large-volume revamping projects, the All Inclusive service consolidates everything into a single package: product, transportation, customs clearance, and technical support. No surprise costs, no middlemen to erode your margins. Shortening the supply chain during a period of growing demand is the most direct lever for protecting the profitability of orders.
- TOPCon Tier 1 modules with efficiency >22%, certified for the Italian and European markets
- Lockable prices on scheduled orders: zero exposure to spot market volatility 2026-2028
- Italian technical support for sizing, GSE documentation, and regulatory compliance
- Scalable supplies from single batches up to multi-MW volumes with scheduled delivery
Analysis of the Decree: 3 Options, 3 Commercial Implications
Legislative Decree 21/2026 isn’t a regulation to be passively monitored: it’s a time window with a specific closing date. Three concrete actions to maximize the commercial ROI of this opportunity:
01
Map your area
Identify systems >20 kW within the 2nd-3rd Energy Accounts within your geographic area. The GSE portal and regional databases allow you to build a list of qualified prospects within weeks.
02
Build the technical offer
Prepare a standard ROI analysis for 50, 200, and 500 kW systems using the decree’s parameters. Having the simulation ready for the first meeting radically changes the quality of the sales conversation.
03
Block the supply chain
Agree now on module availability for 2028-2030 supplies. Aggregate demand of 10 GW will weaken the bargaining power of late buyers. Zero intermediaries, stable and competitive prices.
The Italian photovoltaic revamping market has been dormant for years. Legislative Decree 21/2026 has made it urgent, with legal deadlines that are putting pressure on system owners to make decisions. Market leadership at this stage is not built with the best product, but with whoever arrives first with the right proposal.
Do you have any revamping jobs to plan?
Request a free consultation on your procurement strategy for systems>20 kW. We’ll help you develop a technical offering and secure supplies at the right conditions, before demand drives up prices.
