Ravvedimento operoso: who can use it and how far the penalty falls

Marco, a plumber with an Italian VAT number in Bergamo, realises halfway through the month that he never made a €2,400 tax payment that fell due twenty days earlier. He braces for a heavy fine. If he pays straight away on his own initiative, through ravvedimento operoso, he adds only €30.00 of reduced penalty and €2.10 of interest to the tax: €32.10 in all, provided he knows where those figures come from.

What putting things right means

Ravvedimento operoso lets a taxpayer who has missed a tax obligation fix it alone, before the administration notices. The Agenzia delle Entrate traces it to article 13 of Legislative Decree 472 of 1997 and states its purpose: regularising omitted or insufficient payments, and other irregularities, while benefiting from reduced penalties.

The mechanism rewards acting of one's own accord. Whoever waits to be caught risks the full penalty; whoever moves first pays a fraction of it, and the quicker the move, the smaller the fraction. For a payment made within a month the penalty drops to one tenth: a good reason to act the day the mistake comes to light.

For a forgotten payment there is nothing to correct apart from the debt itself: the regularisation consists entirely of paying. The Agenzia lists the three sums that make up that payment, and each one follows a rule of its own. Mixing them up, or leaving one out, is the most common mistake made by people who regularise on their own.

• the tax due, meaning the amount that was not paid on the deadline
• interest at the annual statutory rate, from the day the payment should have been made to the day it is actually made
• the penalty in reduced form, derived from the base penalty laid down for that breach

Who can use it, and until when

Ravvedimento is open to every taxpayer: individuals, professionals and companies alike. There is no income or business test to meet. What matters is time. For the taxes run by the Agenzia delle Entrate the route stays open until certain specific acts are served, and the Agenzia lists them.

They are settlement and assessment notices, including the letters that follow the automated check and the formal check of tax returns, notices contesting or imposing penalties, and recovery notices. Once one of these has been served, ravvedimento is no longer available for that breach.

An inspection that has only just begun is a different matter. Paying of one's own accord does not prevent visits, inspections or audits, nor their continuation; and an ongoing visit does not, by itself, close off ravvedimento. After an inspection report or a draft assessment, however, the reduction fractions become less generous, as the table further on shows.

Two regimes: the date of the breach decides

The rules changed recently. Article 3 of Legislative Decree 87 of 2024 amended the ravvedimento rules, with the stated aim of encouraging voluntary compliance, and the base penalties for payments changed too. The new levels apply to breaches committed from 1 September 2024 onwards.

The test is the date the breach was committed, not the date it is put right. A payment skipped in June 2024 follows the old levels even when regularised in 2026; one skipped in June 2025 follows the new ones. This module deals first with the new regime, then gives a short section to the earlier one.

The base penalty for a late payment

The reduction fractions work on a starting penalty. For taxes that were not paid, or paid late, it is the one in article 13 of Legislative Decree 471 of 1997, in the version in force when the breach occurred. For breaches from 1 September 2024 the Agenzia gives three levels, tied to the length of the delay.

Up to fifteen days late, the law asks for one fifteenth of 12.5 per cent per day; the Agenzia's page rounds it to 0.83 per cent. The penalty thus climbs to the middle level, then stays put until the ninetieth day. Beyond that it doubles: 25 per cent of the tax.

There is a subtlety on the fifteenth day. The wording of the page applies the daily rate to delays of no more than fifteen days, while the table on the same page puts the fifteenth day in the band that starts at 12.5 per cent. The ActioFin calculator follows the table: the gap is worth five hundredths of a point.

The reduction fractions, by timing

A reduction is applied to the base penalty, expressed as a fraction of the minimum. For an unpaid tax or a skipped instalment the first fraction is the most generous: one tenth, if the payment arrives within thirty days of the deadline. After that the fractions rise as time passes, or as the administration draws closer.

The last three rows carry extra conditions, linked to assessment by agreement and to accepting the inspection report, which the Agenzia sets out in full. The one-fifth reduction does not apply to unrecorded or misrecorded daily takings, nor to failing to install electronic tills. For a forgotten payment, the first four rows are almost always the ones that matter.

In the wording of the law, the one-ninth and one-eighth fractions are tied to the filing deadline when the tax has a periodic return. The Agenzia's table on late payments counts them in days instead: from 31 to 90 days, and from 91 days to one year. The two readings coincide for taxes that have no periodic return.

The calculator uses the reading in days and states so among its assumptions. For a tax with an annual return, such as IRPEF, it is worth checking which deadline is more favourable in the case at hand. Beyond one year, or beyond the filing deadline, the fraction rises to one seventh, which the tool does not compute.

Reading the Agenzia's table

The Agenzia's page offers a table giving, for each delay, the penalty already reduced as a percentage of the tax. Up to day fourteen it rises by about eight hundredths of a point a day; from 15 to 30 days it is 1.25 per cent, from 31 to 90 days 1.39, from 91 days to a year 3.12.

Those percentages are rounded to two decimals. 12.5 per cent divided by nine gives 1.3888…, and 25 per cent divided by eight gives 3.125: the table prints 1.39 and 3.12. On small sums the gap is a few cents. The calculator works on the exact fraction and rounds only the final result in euros.

The working always follows the same order: first the base penalty according to the days of delay, then the fraction according to when payment is made, and finally the interest. Interest is never reduced. The second module covers it in detail, together with filling in the F24 form used to pay everything.

The old regime, for breaches up to 31 August 2024

For a breach committed before 1 September 2024 the base penalty stays as it was then: 30 per cent if the payment is omitted or made more than ninety days late, 15 per cent within ninety days, 1 per cent per day within fifteen days. Someone paying within thirty days therefore pays 1.5 per cent of the tax.

The fractions also differed over the longer term. Under the old regime one seventh applied up to the filing deadline for the following year, or within two years, and one sixth beyond that. For more recent breaches, by contrast, one sixth and one quarter are tied to acts of the administration rather than to the mere passing of time.

What ravvedimento does not do

Ravvedimento does not cancel the debt or put it off: the tax is paid in full. It does not work against a notice already served, and in that case only the tools of the assessment stage remain, which this course does not cover. Nor does it happen by itself: until someone pays, the reduced penalty remains a mere possibility.

One last rule concerns people with several breaches. For those from 1 September 2024 the legal merger of penalties, which folds several penalties into one, was extended to ravvedimento. The Agenzia states, however, that it does not apply to payment obligations or to undue offsets: each missed payment is regularised on its own.

The rules described in this module are those in force in 2026, as read on the Agenzia delle Entrate's pages in September of that year. Several Italian tax texts are being reorganised into consolidated codes: before applying these measures to breaches in later years, check the current version of the Agenzia's page.