Transition 5.0: AiCARR reports critical issues in Legislative Decree no. 38 of March 27, 2026

The changes introduced by Legislative Decree No. 38 of March 27, 2026, regarding the Transition 5.0 measure are generating intense debate within the HVAC&R sector. AiCARR has expressed a clear position, highlighting how the measure retroactively affects investments already made, altering the economic conditions on which businesses and professionals had built their strategies.

The most critical point concerns the reassessment of the tax credit, now set at 35% of the original level. This revision not only reduces the incentive, but directly impacts the economic sustainability of projects already validated by the GSE. In other words, previously planned and approved interventions now need to be reconsidered in a completely different context, with immediate effects on business plans and expected returns.

Incentive cuts and exclusion of renewables: what's changing for HVAC projects?

In addition to the credit reduction, the decree introduces a factor that is particularly burdensome for the plant engineering sector: the exclusion from the recalculation of the benefit for investments related to renewable energy sources and energy efficiency.

This is far from a secondary step. In contemporary design, the integration of HVAC and renewable energy systems increasingly represents the foundation for building high-performance solutions. Limiting the scope of incentives therefore reduces the attractiveness of precisely those interventions that contribute most directly to decarbonization goals.

Added to this is a reduced overall ceiling and limited availability for 2026 , which makes access to incentives even more selective and increases uncertainty in investment planning.

Energy planning in the balance: when the regulatory framework compromises technical assessments

The consequences aren't limited to the financial level, but also affect the day-to-day work of professionals. AiCARR emphasizes how the changes directly impact the reliability of forecasting models used in energy design and consulting .

Diagnosis, feasibility studies, and technical validations were developed based on a regulatory framework that, in the space of a few months, has changed several times, leading to the current intervention. This requires a forced revision of projects and, in some cases, calls into question the coherence of plans already presented to clients.

The risk is twofold: on the one hand, it creates a concrete problem in project management, on the other, it generates reputational damage for professionals, who find themselves operating in an unstable and difficult to predict regulatory environment.

From planning to blocking: the effects along the entire energy efficiency value chain

The impact is rapidly spreading throughout the energy efficiency value chain . ESCos, technology manufacturers, and installers are finding themselves having to revise their programs and investments in a less favorable environment.

According to AiCARR, the most concrete risk is a slowdown in activity in the short and medium term , impacting the continuity of projects already underway and the market's ability to develop new solutions. The renewables sector, in particular, appears to be among the hardest hit, precisely due to the disappearance of a significant portion of incentives.

In this scenario, technological choices could also suffer a setback, favoring less advanced but more economically sustainable solutions.

Energy transition and regulatory instability: an increasingly fragile balance

Beyond the technical aspects, the topic raised by AiCARR is profoundly strategic. The HVAC&R sector represents one of the enabling elements of the energy transition, thanks to its ability to integrate technologies, control systems, and renewable sources into a single design logic.

However, without a stable regulatory framework, it becomes difficult to plan investments and support innovation. The constant changes to the Transition 5.0 measure risk compromising not only the competitiveness of businesses but also the relationship of trust between the production system and institutions.

AiCARR's requests: stability, protection and recognition of the plant's value

In view of the decree's conversion, AiCARR emphasizes the need to introduce corrective measures that can restore coherence and continuity. In particular, three fundamental needs emerge:

• ensure protection for investments already made
• ensure stability and clarity to incentive measures
• recognize the technical and systemic value of plant interventions

These are essential conditions to prevent the current period of uncertainty from translating into a structural slowdown in the market.

New rules, new challenges: what's changing for designers and installers?

For designers, installers, and companies in the HVAC&R supply chain, the changes to Transition 5.0 represent not just a regulatory update, but a concrete change in the way they approach the market.

It is becoming increasingly important to carefully evaluate the economic sustainability of interventions , review design strategies, and support the client in a constantly evolving context.

The decree's parliamentary passage will therefore be crucial to determining whether it will be possible to re-establish a balance between budgetary needs and industrial development. For the sector, the stakes are high: it's not just about incentives, but also about the ability to sustain a truly effective innovation and energy transition process over time.