The formalities: EAS notice, separate accounts and the Redditi ENC return

A social club founded in Perugia in February fails to send the EAS notice within 60 days. In October its chairman finds out that, without that notice, the fees paid by its 200 members may lose their favourable treatment. He can still put things right before the tax return is due, by paying a minimum penalty of €250.

The EAS notice: the filing that protects membership fees

The favourable treatment of fees and of certain charges is not automatic. The Agency's page on the EAS notice explains that, to keep membership fees, contributions and, for certain activities, charges received out of tax, private membership bodies must send the Agency the information relevant for tax purposes electronically.

The form is called EAS, for enti associativi, membership bodies, and stems from Article 30 of Decree-Law no. 185 of 29 November 2008. It is a notice, not an income tax return: it describes the body, its structure and its activities, and lets the Agency know who is claiming the tax breaks reserved for associations.

The practical consequence is direct. Without the EAS notice, members' fees and the charges that paragraph 3 of Article 148 keeps out of income lose that protection, even when the articles contain every required clause. For a small association living on its fees, it is the formality that matters most.

Third Sector bodies neither fill in nor send the EAS notice. The Agency refers to the specific exemption in Article 94, paragraph 4, of the Third Sector Code: for them, the obligation under the 2008 decree simply does not apply. This course deals with associations that are not Third Sector bodies.

Who is exempt and who uses the simplified form

Besides Third Sector bodies, the page lists other bodies that do not have to send the notice. For some of them the exemption depends on a precise condition, such as carrying on no commercial activity, so the list is worth reading carefully before concluding that nothing needs to be sent.

• Amateur sports bodies on the CONI register that carry on no commercial activity
• Local tourist associations that opted for the Law 398/1991 regime, with proceeds below €250,000 in the previous year
• Voluntary organisations on the regional registers carrying on only marginal commercial activities
• Welfare offices that do not carry out the institutional activities of their sponsoring trade unions in their place
• ONLUS non-profit organisations under Legislative Decree 460 of 1997
• Bodies with their own specific tax rules, such as pension funds

A second list covers the bodies that file a simplified version of the form. It includes, among others, amateur sports associations and companies recognised by CONI that are not exempt, social promotion associations on the Law 383/2000 registers, voluntary organisations that are not exempt, and associations with legal personality.

The same list covers recognised religious associations, political movements and parties meeting certain conditions, trade unions and trade associations represented in the CNEL, ANCI, associations recognised for scientific research, veterans' and armed forces associations, and national sports federations. Every other body fills in the full form.

How the notice is sent

The EAS form and its instructions can be downloaded from the dedicated section of the Agency's website, together with the software for filling it in. Filing is always electronic: through the body's own Fisconline or Entratel access, or through an intermediary authorised on Entratel who files on the body's behalf.

Fisconline users can also use direct submission. The Agency describes it as uploading the file into your own reserved area, with no need to install the desktop filing application or set up a security environment. It is open to individuals and legal entities; for a body, a manager or an appointed operator can also carry out the upload.

The file can be prepared with the Agency's software or with a commercial program, as long as it is first run through the checking procedure the Agency distributes. For a small association without an adviser, the simplest route remains the official software followed by direct submission.

Three deadlines and a remedy

The form must be sent within 60 days of the body's formation, either directly through Fisconline or Entratel or through an authorised intermediary. It is not a one-off filing: the page names two further moments when the body has to report again.

A body that missed the deadline has not necessarily lost everything. The page refers to Decree-Law no. 16 of 2012, which allows access to optional regimes that depend on a prior notice even when that notice was not sent on time, under precise conditions.

• The breach must not already have been detected, and no visits, inspections or audits known to the body may have begun
• The body must meet the substantive requirements at the normal deadline
• The notice must be sent by the deadline for filing the first tax return due
• The minimum penalty of €250 must be paid at the same time, without offsetting

Separate accounts and shared costs

A non-commercial body that also carries on a commercial activity must keep it apart from everything else. Article 144, paragraph 2, in the version applicable to 2026, requires separate accounts for the commercial activity. The only exemption is for bodies subject to public accounting rules that follow those rules.

Paragraph 1 of the same article explains how income is determined: each category separately, adding up the results of all the sources that fall within it, under the general rules of the income tax code. The association's business income is thus worked out as for any business, but only for its commercial side.

The practical difficulty is shared expenses: rent for the premises, utilities and telephone used for both institutional and commercial activity. Paragraph 4 makes them deductible for the share corresponding to the ratio between commercial revenue and proceeds and the total of all the body's revenue and proceeds.

The Redditi ENC return and the tax

The body's income tax return is filed on the Redditi ENC form, for non-commercial and equivalent bodies. The Agency's page lists who must file it: resident non-commercial bodies, ONLUS other than cooperatives, non-resident companies and non-commercial bodies with income produced in Italy, and some administrators of unclaimed estates.

For non-resident bodies, the obligation arises when they produced certain income in Italy during the year: business income through a permanent establishment, income from buildings and land, capital income, miscellaneous income, self-employment income from activities in Italy, and income from holdings in partnerships or in tax-transparent companies.

The 2026 form and its instructions were approved by a Revenue Agency order of 27 February 2026, which also set the technical specifications for electronic filing. The general part of the instructions is shared by the Redditi SC, SP and ENC forms, so anyone who knows a company's return will find the same structure.

The deadline follows the general rule: from 15 April of the following year, if the tax period matches the calendar year, and by the last day of the tenth month after the period closes. For 2025 the deadline falls on 2 November 2026, because 31 October 2026 is a Saturday.

The return is prepared with the RedditiOnLine ENC software and filed electronically, directly or through an authorised intermediary. Among those who file directly, the page lists bodies that must also file a VAT return, a withholding agent's return or an IRAP return, alongside authorised intermediaries.

The body pays IRES on its total income. The standard rate is the same one that applies to companies, as worked out by the IRES calculator on this site. Some categories of body may benefit from reductions under other rules, which this course does not cover; they need checking case by case before being applied.

The calculation always starts from the income categories, never from total receipts. An association that takes €100,000, almost all in fees and occasional collections, may have very little total income; one with smaller receipts but a profitable commercial activity may pay more. The annual accounts help rebuild this distinction.

If the commercial activity requires a VAT number, the body handles it like any other trader for the commercial side only: invoices, periodic settlements, annual VAT return. The VAT treatment of fees and institutional activities follows the rules of the VAT decree instead, which this course does not examine.

An association's calendar

Put in order, the deadlines covered in this module make a simple calendar. It is worth recording them in the minutes of the first general meeting and repeating them each time the board is renewed, because handovers between treasurers are exactly when a notice gets forgotten.