Data centres in Italy: what to attach to the single authorisation application

On 21 July 2026 Italy’s Ministry of the Environment and Energy Security registered six pages, signed the day before by its two department heads, that anyone preparing a data-centre application should read before printing anything. The document — “Single procedure for granting authorisations to data centre projects (PUCD) — First operational guidance”, protocol 0155457 of 21 July — appeared on the environmental assessment portal that same day and on the Ministry website on the 22nd. It introduces no new rules: it answers the questions that arrived after the energy bills decree. But it settles three things that change the checklist: what you pay, what you attach, and where the authorisation perimeter ends.

What kind of act this is

It is neither a decree nor a circular published in the Official Journal: it is a note jointly signed by the heads of the Sustainable Development and Energy Departments, ten numbered points, with no amendment to Article 8 of Decree-Law No. 21 of 20 February 2026, converted with amendments by Law No. 49 of 10 April 2026. The procedure, the ten-month maximum and the halving of environmental impact assessment deadlines we covered when the PUCD was announced: what matters here is what the document adds.

Article 8, paragraph 1 refers to numbers 1), 2) and 3) of Article 2 of Delegated Regulation (EU) 2024/1364 — the definitions of enterprise, colocation and co-hosting data centre. The reference is to the definitions, not to the 500 kW installed IT power threshold with which Article 1 of that regulation delimits the reporting obligations.

The fee: two transfers, at filing

Point 2 opens with four words: “The PUCD is chargeable.” At filing, the developer must attach proof of the payments due for the environmental impact assessment (VIA) and the integrated environmental permit (AIA), plus receipts for the fees charged by the authorities competent for the further consents. VIA and AIA need two separate bank transfers, with different IBANs, both payable to the Central Treasury in Rome.

The tariffs are cited, not set. For the VIA: interministerial decree No. 1 of 4 January 2018, whose Article 2 sets them at 0.5 per thousand of the value of the works to be built and at 0.25 per thousand capped at €10,000 for screening alone; and directorial decree No. 47 of 2 February 2018 on payment arrangements, with the payment reference worded as in circular 20/2025 of the State General Accounting Department. For the AIA, interministerial decree No. 58 of 6 March 2017 applies. For scale: on works worth €500 million, 0.5 per thousand is €250,000, due at filing and not at conclusion; the fees for the other consents add to that.

What goes into the file

Point 4 asks for something easy to underestimate: alongside the application the developer must submit the list of every further consent to be obtained beyond VIA and AIA, with the technical documentation each requires under its sectoral rules. Building permits sit inside the single procedure (point 7), so the design must be complete with all the drawings needed to obtain them. The application remains a party application: responsibility for the declarations and commitments stays with the applicant.

While the online channel is under development, submission follows the transitional regime: certified email to va@pec.mase.gov.it where the documentation stays under 50 MB, in a single zip file organised to the portal technical specifications; above 50 MB, hand delivery on a hard disk or other medium, with a printout of the application sent by certified email. The application template and dedicated technical specifications were announced “in the coming days”: as at the date of this article the portal page “Technical specifications and forms” does not yet carry one for the PUCD.

Planning conformity: a precondition, not an effect

The clarification is blunt. Article 8, paragraph 3 lists among the attachments “the verification of planning conformity with municipal plans”; the guidance concludes that this is “a necessary precondition prior to the start of the PUCD”, and adds that the single authorisation “does not in itself constitute a variation to the planning instruments in force”. The opposite applies on the other track: where a project is declared of paramount national strategic interest, paragraph 7 of the same Article 8 refers to paragraphs 5 and 6 of Article 13 of Decree-Law 104/2023, under which the single authorisation does operate as a planning variation. Two routes, two regimes: on the ordinary PUCD the site must already be compatible.

Where the authorisation stops

Point 8 draws the boundary. The single authorisation covers the facility and its user connection networks “at any voltage”: user grid works, ducts included, are assessed and authorised inside the procedure. It does not cover what Terna or the distributor, in the connection solution, classify as grid works. Paragraph 1-bis allows the design to indicate a temporary medium-voltage connection; the document gives the example of a facility above 10 MW, with two outcomes: integrating the definitive connection during the assessment — a longer procedure, a complete authorisation — or closing on the temporary solution and later seeking a variation for the definitive user works.

Where the clock restarts

The ten months run from the notice certifying completeness (point 5), not from the filing stamp.
Design changes during the assessment are handled inside the single procedure, but depending on how material they are the guidance provides that “the deadlines be restarted”, with fresh publication, public consultation and assessment where needed (point 9).
Variations after the authorisation is granted, extensions included, require the single authorisation procedure to be reactivated (point 10).

To these add a deadline that sits in the law, not in the guidance: Article 8, paragraph 6 provides that where a project goes through screening and comes out subject to a full environmental impact assessment, the application must be filed within a peremptory ninety days, after which “the applicant is deemed to have withdrawn the single authorisation application and the procedure is closed”.

The bottom line

The PUCD is not a lighter procedure: it is a shorter one, and everything that used to arrive at different times must now arrive together, on day one. Anyone turning up with an incomplete list of consents, planning conformity unchecked or the transfers still to be made does not lose a week: they lose the completeness check, and with it the date from which the ten months run. The same holds for our part of the work: user connection networks and ducts are design deliverables, not details to settle on site, and the connectivity of a data centre — entries, routes, redundancy, installation classes — has to be described with the same rigour as the power supply, because it goes into the same file. That is the work we follow from site survey through to certification, across our data-centre projects.

Are you assembling the file for a data centre, or do you need to document cabling and entries for an application already under way? Talk to an engineer: an initial discussion helps establish which deliverables are needed, and in what form.