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.
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 1-17 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 11). |
| Associated professional practice | No | The individual professionals in the practice with their own VAT number can apply (FAQ 14). |
| Professional order or its foundation | No | Not among the beneficiaries identified by the measure (FAQ 13). |
| 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 12). |
| CAF, consortium, Confidi | Yes | If set up as a company and qualifying as an SME; no exclusion for the financial and insurance sector (FAQs 15-17). |
| 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 10). |
Connectivity: fixed line only, and a declaration is enough
The 30 Mbps download requirement was the most debated point. FAQs 6-9 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 7). 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 8).
- 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 9).
Expenses: new or improved, and only after submission
FAQs 18-22 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 21). Platforms for delivering training fall into category D, excluding the training content itself.
Do not activate anything before submitting the application. FAQ 22 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 23-25): 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 27 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.
- 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 28).
- 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 29).
- 3The quote need not be signed, but the attached offer 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. The Ministry announces an offer template to be published shortly (FAQ 30). Who declares what is explained in our news on the starting point.
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 32-33). 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 34). The project is considered complete when the expenses are invoiced and paid, without waiting for the end of the subscription (FAQ 35).
| 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 in the three weeks 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. Do not sign anything with suppliers before submission. Prepare the description of the starting point and ask suppliers for offers already in the required format, pending the ministerial template. Decide who fills in the application and activate the delegation in time, knowing that the signature stays with the legal representative. The application form and the link to the procedure have not been published yet: we will update the voucher landing page as soon as they are out.
Frequently asked questions
Answers to the most common questions on the beneficiaries section of the MIMIT FAQs of 25 September 2026.
No. FAQ 14 of 25 September 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 13).
No. FAQ 7 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.
No. FAQ 30 clarifies that neither the supplier’s nor the applicant’s signature is required, but the offer for the goods and services in the spending plan must be attached, identifying 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. The Ministry will shortly publish an offer template for suppliers.
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 22 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”, update of 25 September 2026 (FAQs 1-36)
- 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