Italy

Public consultation quality

The responsible unit within the Ministry of the Environment and Energy Security has shown openness to dialogue and a willingness to consider proposals from civil society organisations (CSOs) in the drafting of the plan. 

Nonetheless, the consultation process was only launched in March, very close to the 30 June deadline, which significantly limited the time available for structured engagement and genuinely effective participation. Initially, the Ministry organized two stakeholder consultations in the form of a written survey and an online meeting. However, these served primarily to present the Social Climate Fund framework to stakeholders, rather than to collect meaningful input. Following these initial steps, the Ministry invited stakeholders to submit proposals for measures to be included in the plan by mid-April. 

An informal group of environmental CSOs that was formed after the first stage of the consultation contributed, but this information was only shared with a limited group of stakeholders (those that joined the first stage of the process) via email. The third and final stage of the consultation involved feedback on the final draft, published at the end of May, with comments accepted until 16 June. However, the current version cannot be considered a true draft, as it consists only of summary sheets and presentation slides, lacking a comprehensive analytical framework.

Cross-ministerial coordination & participation of social ministries

The entire process was coordinated by the Ministry of the Environment and Energy Security. The responsible unit within the Ministry claimed multiple times that they were collaborating with other ministries (including the Ministry of Social Affairs), although CSOs never had any direct interaction with them, neither during the stakeholder webinars nor in our meetings.

Stakeholder consultation scope

The consultation process was opened in March 2025, with the first draft of the measures made available at the end of May. This provided an opportunity to submit input to the Ministry prior to the publication of the final measures. 

Consultation timing

CSOs were informed in early March 2025 about the first phase of the consultation. In April, CSOs were given only a few weeks to provide input through the submission of voluntary proposal sheets. Regarding the third and final stage of the consultation, CSOs were granted just over two weeks to provide feedback on the draft measures.

Stakeholder representation

According to the presentation recently released by the Italian government to describe the consultation process, "NGOs and environmental associations were consulted". CSOs participated in the consultation, but it's not straightforward to say that the authorities made an effort to reach vulnerable or underrepresented groups. 

The interests of such groups were only represented by the informal group of green and social NGOs that was formed during the consultation process.

Stakeholder feedback integration

The government was consistently open to feedback from CSOs. However, key stakeholder feedback that was submitted during the consultation process was not fully incorporated into the final draft of the plan. For example, there were specific recommendations around the inclusion of energy communities but this was not included in the final draft. 

Overall, it's difficult to assess with certainty what the government initially planned to include or exclude from the plan, and thus how CSO recommendations influenced the final proposed list of measures. 

Arrangement to set up a standing consultation/monitoring body for the Plan

CSOs haven't received any information on this, leading tot he impression that no monitoring committee is likely to be established (the same happened with the Italian Recovery and Resilience Plan, where no monitoring committee was put in place).

Involvement of Local Authorities

Local authorities were generally actively involved in the process. The National Association of Italian Municipalities (ANCI) played a coordinating role by collecting input from local governments. However, it remains unclear which of the proposals by local authorities were actually taken on board. 

Energy poverty definition

The definition of energy poverty is consistent with the one outlined in the Social Climate Fund Regulation (Article 2). 

Effective targeting of vulnerable households

The Plan introduces the figure of the "domestic energy tutor" (in Italia: Tutor per l’energia domestica or TED) to provide technical assistance with expertise in energy. This is a positive step considering that the Italian government has finally recognised the need for such a measure to address energy poverty. 

TEDs are planned as frontline operators tasked with informing, raising awareness, guiding, and advising vulnerable households on energy efficiency, with the role to offer professional support and practical guidance on the various dimensions of energy poverty. The measure includes training programs to equip TEDs with the necessary skills to provide assistance through physical help-desks and non-personalised tools (e.g. newsletters, energy cafés, webinars). 

The goal is to ensure at least one help-desk per province. However, operating at the provincial level is inadequate for the Italian context, as provinces are often too vast and socially heterogeneous: these professionals should instead operate at the neighbourhood or district level, where trust can be built and maintained and thus offer better support to the people in need. 

Measures addressed to households that are not immediatedly impacted by ETS2

The measures foreseen in the Italian Social Climate Plan aim to target already energy and transport poor households, regardless of ETS2. 

Pass-on benefit guarantee (100% of benefits reaching vulnerable households)

The Plan lacks explicit provisions to guarantee that benefits received by non-vulnerable actors, such as for example landlords, are fully passed on to vulnerable households to ensure affordable housing and energy. 

This is particularly negative, considering that families who rent represent a significant percentage of vulnerable households today.

Housing sector reforms & investments

The plan includes five interventions in the housing sector, including measures:

• targeting both public and private residential buildings,
• supporting social housing,
• aiming at improving energy efficiency with initiatives such as the Esco Card (financial tool designed to support energy efficiency upgrades in buildings targeting public residential housing) and
• renovations of public housing in poor energy classes. 

However, 1) The plan’s energy efficiency targets (e.g., 30% reduction in consumption) are not ambitious, thus the plan does not fully apply the “energy efficiency first” principle by aiming for the highest technically achievable efficiency levels rather than modest targets.; 2) the measure targets only public social housing in energy classes F and G, covering about 19,000 buildings out of 710,000, leaving many inefficient homes unsupported; 3) Accessibility barriers for low-income households persist, as some measures still exclude key vulnerable groups, such as tenants.

Heating & cooling sector reforms & investments

There's only a partial investment in the heating and cooling sector through the measure M5 - Reddito Energetico, which supports the installation of photovoltaic systems combined with heat pumps for low-income households. 

However, the measure is limited to individual households and does not include community or cooperative-owned projects.

Measures and investments for energy communities

The plan only mentions energy communities linked to the the measure "energy income for the installation of photovoltaic systems combined with a heat pump", and specifies that the fund can be used to finance photovoltaic systems serving energy poor households and can also be applied within energy communities. 

But there is no financing clearly dedicated and earmarked for energy communities. 

Public transport & active mobility

The Plan includes targeted support for vulnerable users to access public transport (measure M.3 “Il mio conto Mobilità”), and incentives for low-emission vehicle purchase, leasing, or long-term rental, which prioritise low-income and rural residents. 

The Social Ecobonus for used vehicles includes incentives to make used low-emission vehicles more accessible. Additionally, financial support is foreseen for vulnerable users to access public and other sustainable transport services (measure: My Mobility Account). 

Lastly, funding is foreseen for integrated transport in low-density areas and for mobility hubs and combined transport options to improve service accessibility.

Vulnerable micro-enterprise support

There's one measure targeting vulnerable micro-enterprises, which will support interventions aimed at achieving energy savings through energy efficiency actions. However, the measure aims for 30% efficiency improvements which is an insufficient target to tackle fossil fuel supply challenges and will not fully shield companies from the impact of upcoming ETS2 quotas.

Problematic investments

There are two investments that could be considered as problematic:

• The plan’s measure for energy retrofitting in private housing includes replacing existing heating systems with biomass generators.
• Measure I.4 will support the purchase of not just zero, but also low-emission vehicles.

Cost-supportive measure design

The Italian plan includes one income support measure, the measure M5 - Reddito Energetico, which is a energy subsidy for the installation of photovoltaic systems combined with a heat pump. However, this measure is not primarily designed as a temporary shielding mechanism from carbon pricing, but a structural support measure aimed at providing vulnerable households with free photovoltaic (PV) systems, thereby permanently lowering their energy costs and reducing their reliance on fossil fuels.

Strategic alignment & linkages with other major national strategies & plans

The draft measures in the Italian Social Climate Plan align with the updated 2024 Italian National Energy and Climate Plan, particularly in addressing the prominent issue of energy poverty highlighted in the plan. 

Moreover, it has been repeatedly acknowledged that the Ministry is aware of the timing overlap with the conclusion of the Recovery Plan, and the proposed timeline seems to be consistent with this.

Mobilisation of broader ETS2 revenues

This information is not mentioned in the documents that were made publicly available at the end of May.