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Mandatory digital domicile for company directors: updates and deadlines

published on 11 November 2025 | reading time approx. 3 minutes

In recent months, there has been lively debate about the requirement for company directors to notify the Companies Register of their personal digital domicile (PEC). This obligation, introduced by the 2025 Italian Budget Law, created operational and interpretative uncertainties that required corrective measures.

How the regulation evolved

From 1 January 2025, under Article 1, paragraph 860 of Law 207/2024 (Budget Law 2025), Article 5 of Decree-Law 179/2012 was amended to extend the obligation of a digital domicile “to directors of companies incorporated in corporate form”, referring to what was already provided by Article 16, paragraph 6 of Decree-Law 185/2008.

The first ministerial note (No. 43836 of 12 March 2025) confirmed that the obligation to provide “one’s own digital domicile” applied to all companies incorporated in corporate form. However, this triggered further debate among professionals, Chambers of Commerce and the Ministry, due to inconsistent practices. A second note on 25 June 2025 confirmed the obligation and, to ease implementation difficulties, extended the deadline to 31 December 2025.

With Decree-Law 159/2025, Article 13, paragraph 3 (in force since 31 October 2025), the scope of the obligation was defined as follows: “The obligation [to indicate one’s own digital domicile] applies […] to the sole director or the managing director (amministratore delegato) or, failing that, the chairman of the board of directors of companies incorporated in corporate form. The digital domicile of these directors must not coincide with that of the company. Companies already registered with the Companies Register must communicate the digital domicile of these directors by 31 December 2025 and, in any case, at the time of appointment or renewal.”

The decree is already in force but must be converted into law by 30 December 2025, failing which it will lose its effectiveness ab initio. Amendments may therefore be introduced during the parliamentary process.

Current rules and deadlines

According to the latest provisions, the rules and deadlines are as follows:

Who must provide a PEC: sole director, managing director or chairman of the board;
Requirements: PEC registered to the director distinct from the company’s PEC;
Deadlines:

new appointments and renewals: at the time of registration;
companies already registered: by 31 December 2025.

Penalties:

suspension of the filing process in any case;
probably administrative fine doubled (between €206 and €2,064); if communication is made within 30 days of the deadline, the fine should be reduced to one-third.

Interpretative issues

Several uncertainties remain to be clarified during the conversion of the decree, including:

Multiple directors without a board structure: In partnerships (Snc, Sas) and limited liability companies (Srl), management may be joint or several, without a single top figure. It is unclear whether all directors must provide a PEC or only one designated person;
Liquidators: The first ministerial note included them in the obligation, but Decree-Law 159/2025 does not mention them, creating uncertainty;
Consequences of non-compliance: Reference to Article 16, paragraph 6-bis of Decree-Law 185/2008 suggests that for new registrations, applications will be suspended until a PEC is provided, while for existing companies, failure to comply by 31 December 2025 will result in the doubled fine under Article 2630 of the Civil Code and assignment of a PEC ex officio. It is unclear furthermore whether this applies to individual directors.

Recommendation

Pending further clarification, companies should check the position of their directors to ensure compliance with the new rules by the 31 December 2025 deadline.