After the FAQs of 2 and 15 September aimed at suppliers, on 25 September 2026 MIMIT (the Italian Ministry of Enterprises and Made in Italy) added a second section to the frequently asked questions on the Cloud and Cybersecurity Voucher, “Beneficiaries and access requirements”, with 36 answers in four parts: requirements, eligible expenses, choice of supplier, submission of the application, payout and reporting. Dates and amounts do not change: drafting from 12:00 on 20 October, submission from 12:00 on 10 November, closing at 12:00 on 20 January 2027, a 50% grant up to €20,000 on a minimum spend of €4,000. What changes is how precisely the application can be prepared. Here we collect what matters, FAQ by FAQ, for those deciding whether and how to apply.
Update of 17 October 2026. On 15 October the Ministry held the webinar on the platform and published the slides and Invitalia’s interactive guide, a demo desk with the sections of the real application: company information, investment plan (starting point and objectives up to 5,000 characters each, a single site, expenses by category with identification code), declarations and generation of the application. Three things to know: before drafting, the legal representative must register the company in Invitalia’s “Anagrafica e deleghe”, from where they can delegate a consultant with read or write access (the delegate drafts, does not sign); only items from the supplier’s published catalogue, with their code, can enter the spending plan; the application is submitted once, and another one can be filed only after a rejection. Invitalia’s contact centre answers on the toll-free number 800 775397, Monday to Friday from 9:00 to 18:00. The desk is Invitalia’s reserved area: Invitalia’s page on the incentive, published on 16 October, states that the application is drafted there from 12:00 on 20 October, while MIMIT’s page does not show the link yet.
Update of 9 October 2026. On 8 October the Ministry published the forms: the application template, the supplier offer template and a template declaration on catastrophe insurance. In the same update FAQ 35 was corrected: the offer attached to the application must be signed by the supplier, whereas the previous version said no signature was needed. On 15 October, from 10:00 to 12:00, MIMIT will hold a webinar on how the platform works, with online registration. Dates and amounts do not change; the link to the procedure has not been published yet. What the two templates contain is explained further down.
Update of 6 October 2026. On 1 October the Ministry reorganised the beneficiaries section into four subsections (eligible expenses, choice of supplier, submission of the application, payout and reporting) and expanded it to 42 answers. The existing FAQs were renumbered: in this article the references follow the new numbering. There are three new points: the catastrophe insurance obligation also covers rented, leased or loaned assets (FAQs 7-9); for subscriptions, the spending plan shows the sum of the fees for the first 24 months (FAQs 33-34); to request payout you must have incurred and paid at least 50% of the approved plan (FAQ 39). Dates and amounts do not change; the application form, the link to the procedure and the offer template have not been published yet.
Who is eligible and who is left out
The general rule does not change: micro, small and medium-sized enterprises under the European definition, and self-employed workers with a VAT number. FAQs 1-20 answer the borderline cases that were reaching the Ministry.
| Entity | Eligible? | What the Ministry says |
|---|---|---|
| Newly formed company | Yes | No filed accounts required; it must be incorporated, registered with the Business Register and active (FAQs 4-5). |
| Company that exceeded the SME thresholds in the last financial year | Yes, with a caveat | SME status is lost only after two consecutive years above the thresholds; if that happens, the grant is revoked (FAQ 3). |
| SME subject to NIS2 | Yes | Including for investments aimed at meeting NIS2 obligations (FAQ 14). |
| Associated professional practice | No | The individual professionals in the practice with their own VAT number can apply (FAQ 17). |
| Professional order or its foundation | No | Not among the beneficiaries identified by the measure (FAQ 16). |
| Agricultural business | It depends | Primary production is excluded; secondary activities (processing, agritourism) are eligible with an ATECO code already active and a spending plan attributable only to those (FAQ 15). |
| CAF, consortium, Confidi | Yes | If set up as a company and qualifying as an SME; no exclusion for the financial and insurance sector (FAQs 18-20). |
| Several companies in the same group | Yes, one application each | The one-application limit applies per legal entity, but the de minimis ceiling is calculated on the Single Undertaking (FAQ 13). |
Connectivity: fixed line only, and a declaration is enough
The 30 Mbps download requirement was the most debated point. FAQs 10-12 settle it in three steps.
- No data SIMs or mobile connections. Fibre, VDSL, FWA and satellite count, provided the contract guarantees the required minimum (FAQ 10). Anyone with only a mobile connection must activate a fixed line before applying.
- A self-declaration is enough in the application. The contract is submitted at the payout stage, but it must already be in place on the application date, confirming what was declared (FAQ 11).
- The contract may be in a third party’s name, for example the owner of the premises or another group company, provided there is a demonstrable relationship, the connection refers to the site stated in the application and the contract holder declares that it is made available to the beneficiary (FAQ 12).
Expenses: new or improved, and only after submission
FAQs 21-25 restate the five categories and put in writing what is not fundable: solutions with performance similar to those already in use, licence extensions, increases in seats or users, version upgrades without a substantial improvement, maintenance-only work. Solutions with artificial intelligence are eligible when they fall within the subsidised services, for example a SaaS that integrates AI functions supporting business processes (FAQ 24). Platforms for delivering training fall into category D, excluding the training content itself.
Do not activate anything before submitting the application. FAQ 25 is explicit: only expenses incurred after submission are eligible, so from 10 November onwards. Anyone signing a contract in October to “get ahead” pays for it in full.
On the choice of supplier (FAQs 26-28): buying from a related supplier or one in the same network contract is not automatically excluded, provided the two entities are legally distinct and the transaction is genuine. An approved supplier may include in its offer services for which it is not accredited, if they are provided by another accredited supplier: the offer must state the original supplier, its service code and its name, and the application must carry that code even if the invoice is issued by the system integrator you signed with. It is the model we work with when we integrate third-party hardware or storage into a project.
The application: what you need, who fills it in, who signs
FAQ 30 lists what is needed: SPID, CIE or CNS, a digital signature, an active PEC, a description of the initial technological situation and the expected improvement, suppliers’ offers with identification codes and cost details, the requirements of the measure including connectivity and, for SMEs, the declaration on the catastrophe insurance policy. The checklist on our landing page is updated to this list.
On the catastrophe insurance policy, FAQs 7-9 of 1 October settle a frequent doubt: the obligation under Law 213/2023 covers the assets used in the business even when they are not owned by the company, i.e. rented, leased or on loan. If the owner has already insured the building with a compliant policy it need not be duplicated, but plant, machinery and equipment that are not covered must be insured. It is worth checking with your insurer before 10 November, because the declaration is required in the application.
- 1Delegation is possible to a consultant, a professional or an employee, through the platform’s “Anagrafica e Deleghe” function: the company is registered, the delegate’s details and authorisations are entered, the form is generated and signed digitally (FAQ 31).
- 2The signature stays with the legal representative, or the self-employed person applying for themselves. The delegate fills in and submits, but does not sign: the only exception is a special attorney registered in the system (FAQ 32).
- 3The offer must be signed by the supplier (FAQ 35, corrected on 8 October) and must identify supplier, products and services, supplier register codes, cost items and the starting point with the guaranteed improvement, or the unavailability of the service at the time of application. Who declares what is explained in our news on the starting point.
The templates of 8 October
The application template runs to four pages: details of the applicant, the signatory and the project contact; starting point, objectives and duration of the programme; investment site; list of products and services with identification code, supplier tax code, category, type and purchase mode; taxable amount and aid requested, up to €20,000. Then come the sworn declarations, including the truthfulness of the starting point and the fact that the programme has not already started: for the form, it has started even with a single contract or order confirmation, an invoice or a payment, deposits included. The offers and the catastrophe insurance declaration are attached, and the form is signed digitally.
The supplier offer template is not mandatory, but the information it contains is: a header with the supplier’s identifier; the list of products and services with the register codes (for a resold service, the code and name of the accredited supplier, while the invoice stays with whoever makes the offer); starting point and expected improvement; a financial table with the purchase mode for each item (direct, subscription or mixed), frequency and amount of the instalments, and a minimum term of 24 months for subscriptions; date, stamp and signature of the supplier. The template declaration on catastrophe insurance provides for three cases: obligation met, with policy number and insurer; deadline for your company size not yet passed; obligation not met although the deadline has passed.
Payout and deadlines: when the money arrives
The grant is a reimbursement: you pay the supplier in full, then request payout attaching invoices and proof of payment (FAQs 37-38). It can be requested in two instalments, the first after incurring at least 50% of the expenses and the second at the end of the plan, or in a single payment. Invoices must show the CUP of the application and the identification code of the service or product. For subscriptions, advance payment of one or more years is allowed, provided the contract lasts at least 24 months and the expenses relate to the first 24 (FAQ 40). The project is considered complete when the expenses are invoiced and paid, without waiting for the end of the subscription (FAQ 41).
Two clarifications of 1 October. In the spending plan, a subscription is entered with a taxable amount equal to the sum of the fees for the first 24 months shown in the offer, even if the contract runs longer (FAQs 33-34). And to submit any payout request you must have incurred and paid at least 50% of the approved plan: even those requesting everything as a single final payment must carry out at least half of the plan, and only expenses actually paid and eligible are recognised (FAQ 39).
| Mode | When to incur the expenses | Final report |
|---|---|---|
| Direct purchase | After the application and within 12 months of the grant decision | Within 30 days of completion |
| Subscription | Contract signed after the application and within 30 days of the decision; the expenses of the first 24 months from signing count | Within 30 days of completion |
| Mixed | Direct purchases within 12 months of the decision, subscription within 24 months of signing; maximum duration 24 months from signing the subscription | Single, within 30 days of completion |
What to do before 20 October
Check that you are among the beneficiaries with the table above, or with our free requirements check tool updated to the 25 September FAQs. Check that the connection is fixed and already under contract. Check the catastrophe insurance, including on assets you do not own, and prepare the related declaration on the Ministry’s template. Do not sign contracts or orders with suppliers before submission. Prepare the description of the starting point and ask suppliers for signed offers with the contents of the ministerial template. Decide who fills in the application and activate the delegation in time, knowing that the signature stays with the legal representative. Review the materials of the MIMIT webinar of 15 October. The application is drafted in Invitalia’s reserved area from 12:00 on 20 October: the steps are on the voucher landing page.
Frequently asked questions
Answers to the most common questions on the beneficiaries section of the MIMIT FAQs (25 September, 1 and 8 October 2026).
No. FAQ 17 (numbering of 1 October 2026) excludes associated professional practices, because the beneficiaries are SMEs registered with the Business Register and self-employed workers. The individual professionals in the practice who have their own VAT number and meet the other requirements can, however, apply. Professional orders and their foundations are also excluded (FAQ 16).
No. FAQ 10 excludes connectivity services on mobile networks. Fibre, VDSL, FWA and satellite connections count, provided the contract guarantees at least 30 Mbps download. In the application a self-declaration is enough; the contract, already in place on the application date, is submitted at the payout stage and may be in a third party’s name, with their declaration that the service is made available to the beneficiary.
It depends on what is already insured. FAQs 7 and 8 of 1 October 2026 clarify that the obligation covers all assets used in the business (land, buildings, plant, machinery, equipment), even if rented, leased or on loan. If the owner already has a compliant catastrophe policy on the building, it need not be duplicated; the company’s assets that are not insured still have to be covered. In the application, SMEs declare that they comply with the obligation.
Yes. With the update of 8 October 2026, FAQ 35 was corrected: the offer for the goods and services in the spending plan, to be attached to the application, must be signed by the supplier. It must identify the supplier, the products and services requested, the supplier register codes, the cost items and the starting point with the guaranteed improvement, or the unavailability of the service at the time of application. On the same day the Ministry published the supplier offer template: using it is not mandatory, but the information it contains is.
As a reimbursement of expenses paid to the supplier, in two instalments (the first after at least 50% of the expenses, the second at the end of the plan) or in a single payment, with invoices showing the CUP and the service code. For direct purchases, expenses must be incurred within 12 months of the decision; for subscriptions, the contract must be signed within 30 days of the decision and the expenses of the first 24 months count, even if paid in advance; the final report must be submitted within 30 days of completion, which coincides with payment of the expenses.
No. FAQ 25 is clear: only expenses incurred after the application is submitted are eligible, so from 10 November 2026 onwards. Expenses incurred before cannot be subsidised. Subscription contracts, too, must be signed after the application is submitted and within 30 days of the grant decision.
Sources
- MIMIT, FAQ “Sostegno alla domanda di servizi di cloud computing e cyber security”, section 2 “Beneficiari e requisiti di accesso”, updates of 25 September, 1 and 8 October 2026 (FAQs 1-42)
- MIMIT, forms for the Cloud and Cybersecurity Voucher published on 8 October 2026: template “Richiesta del contributo”, template “Offerta del fornitore”, self-declaration on catastrophe insurance
- MIMIT, Directorial Decree of 4 August 2026, terms and procedures for submitting applications
- MIMIT, Ministerial Decree of 18 July 2025, establishing the measure
- Regulation (EU) 2023/2831 on de minimis aid and Recommendation 2003/361/EC on the definition of SMEs