Maximum theoretical combined benefit (Sabatini + Transizione 5.0) on this investment: ≈ €45,090, i.e. 45% of the amount — conditional. The Sabatini portion (€10,090) does not depend on the energy component and is the basis of this study.
The company meets the EU SME definition (Rec. 2003/361/EC) on both headcount and revenue, operates in an eligible sector and shows no exclusion cause in the available registry data. The de-minimis ceiling has headroom — relevant because the 4.0 uplift of the Sabatini contribution is granted under the de-minimis regime (the base rate instead operates under the GBER block exemption).
| Requirement | Result | Source / note |
|---|---|---|
| SME under EU rules (micro/small/medium) | ✓ | Registro Imprese — small enterprise |
| Registered and active at the Business Register | ✓ | Company visura |
| Eligible sector (not financial/insurance) | ✓ | ATECO 63.12 — eligible |
| Not a "firm in difficulty" (Reg. EU 651/2014) | ✓ | From accounts; no proceedings pending |
| No insolvency / liquidation proceedings | ✓ | Registro Imprese |
| DURC in order (contributions regular) | ⚠ | To confirm at application and disbursement |
| De-minimis headroom (for the 4.0 uplift) | ⚠ | Check on the National Aid Register (RNA) |
NovaFood intends to strengthen the digital infrastructure supporting its quotation/matching engine, currently constrained by compute capacity. The project involves the purchase of new capital goods for productive use, functionally interconnected with each other and with the company's management systems, so as to form a system with functional autonomy — a condition required by the measure. The assets are to remain in Italy at the production unit for at least three years.
| Capital good (new, 4.0) | Amount | 4.0 category | Result |
|---|---|---|---|
| On-prem GPU compute cluster (interconnected) | €62,000 | Annex A — production assets | ✓ |
| Interconnected orchestration & management software | €28,000 | Annex B — software/systems | ✓ |
| Network, monitoring & security hardware | €10,000 | Annex A — 4.0 infrastructure | ✓ |
| Total eligible investment | €100,000 | ✓ |
Categories per Annexes A and B of Law 232/2016. Amounts indicative, to be fixed against binding supplier quotes. The software is eligible as it is instrumental to the operation of the 4.0 goods and is interconnected.
The incentive is anchored to a financing (bank loan or lease) covering the investment. Reference parameters:
| Parameter | Value for this project | Measure limit |
|---|---|---|
| Financed amount | €100,000 | €20,000 – €4,000,000 |
| Term | 5 years | ≤ 5 years |
| Technical form | Bank loan | Bank loan or finance lease |
| Guarantee | SME Guarantee Fund | coverage up to 80% |
Using the SME Guarantee Fund (Fondo di Garanzia PMI, up to 80% of the amount) lightens the collateral the bank requires and speeds up the credit decision — the standard channel for Sabatini files.
The grant is not a percentage of the asset: MIMIT pays an amount equal to the interest computed on a theoretical 5-year loan, with constant semi-annual instalments, at a conventional rate — 2.75% for ordinary goods, 3.575% for interconnected 4.0 goods (a 30% uplift). This yields the standard coefficients of 7.72% (ordinary) and 10.09% (4.0).
| Scenario | Conv. rate | Coefficient | Grant on €100,000 |
|---|---|---|---|
| Ordinary goods | 2.75% | 7.72% | €7,720 |
| 4.0 goods (NovaFood case) | 3.575% | 10.09% | €10,090 |
| Delta in favour of the 4.0 classification | +€2,370 | ||
Attesting the goods as 4.0 rather than ordinary is worth +€2,370 on this investment (+31% of grant). It is the technical point the file turns on: it requires the interconnection and 4.0 characteristics to be documented and attested before disbursement. This is where a well-structured file earns, and a badly structured one loses.
| Instrument | Cumulable with Sabatini | Indicative benefit |
|---|---|---|
| Tax credit / Transizione 5.0 (on the asset) | Yes, different base | up to €35,000* |
| SME Guarantee Fund (on the financing) | Yes | guarantee ≤80% |
| Other public aid on the same financing | No | — |
*Transizione 5.0: base rate 35% of the investment (first bracket), conditional on achieving and certifying a minimum energy saving from the project. It is not automatic: the energy feasibility of the cluster must be verified (efficiency versus the replaced infrastructure). Stacking with Sabatini is allowed within EU aid-intensity limits and provided the investment cost is not exceeded.
| Phase | Timing | Output |
|---|---|---|
| Quotes & application | Month 0 | Binding quotes + PEC application to the bank (before any order) |
| Credit decision & reservation | Months 1–3 | Financing resolution + MIMIT grant reservation/decree |
| Signing & start | Month 3 | Financing signed, orders placed, investment started |
| Delivery | Months 3–14 | Delivery, testing and interconnection of the goods (within 12 months) |
| Reporting | Month 14 | 4.0 attestation + completion documentation |
| Disbursement | Months 15–18 | Grant paid out (subject to catastrophe insurance — see §9) |
Indicative total duration 15–18 months from application to payout. Rolling non-competitive window: no ranking, funds available (2026 refinancing of €650M for the 2026–27 period).
1. Early start. An order, contract or payment to a supplier before the PEC application is sent → the entire investment is disqualified. This is the most common and the most serious error.
2. Interconnection not proven. Missing 4.0 attestation → the rate drops from 3.575% to 2.75% (a ~€2,370 loss) or, if the good is not even ordinary-eligible, exclusion.
3. Formal requirements. Irregular DURC, missing catastrophe policy (from 2026), or exceeding the de-minimis ceiling on the uplift → suspension/revocation of the disbursement.
The risk is procedural, not fiscal: it is managed with the correct sequence (application → order → delivery → attestation → disbursement) and a clean document file — exactly what Lumegran structures from the start.