Third Sector: news, deadlines and opportunities – Why it's time to talk about it

by Paolo Sardo

In 2026, the Italian third sector enters a new phase, with clearer rules, more modern tools and a more attentive look at efficiency and transparency. The challenge is great, but so are the opportunities. The important thing is not to be caught unprepared.

With the entry into force of Title X of the Third Sector Code, the tax system for Third Sector Entities (ETS) finally becomes fully operational. The regulatory framework, pending for years, was completed by Legislative Decree 186/2025, which defined application rules, flat-rate regimes and accounting simplifications for a vast number of entities registered with RUNTS.

Alongside this new tax system, the definitive divestment of non-profit organizations is also taking shape. In fact, starting from 1 January 2026, this legal qualification will be cancelled. The entities that still identify themselves as non-profit organizations today will necessarily have to decide whether to transform themselves into ETS, requesting registration in the RUNTS by 31 March 2026, or face the consequences, including financial ones, deriving from the loss of the qualification.

In this scenario, entities, managers and professionals are called upon to face a complex but potentially advantageous transition, provided they act in time and with full awareness of the new regulatory framework.

End of ONLUS and transition to RUNTS: what changes

According to the provisions of the draft circular on the Third Sector published at the end of 2025, the ONLUS qualification will no longer be valid starting from the tax period following 31 December 2025. From that date the NPO Registry will also be abolished

To ensure continuity between the old ONLUS regime and the new system ETSregistration to RUNTS31 March 2026

The absence of registration, or the rejection of the application, in fact entails the application of article 10, paragraph 1, letter f) of Legislative Decree 460/1997, with the obligation to donate the residual assets to Third sector entities

A delicate aspect concerns entities with operations that do not coincide with the solar year. In such cases, the application for registration to the RUNTS

The new ETS tax regime: structure and characteristics

From 2026, the tax rules contained in Title 80 CTS. This regime allows business income to be determined in a simplified way, by applying specific profitability coefficients to annual revenues, distinguished by nature and volume of the activity. The rates vary from 5% to 17%, depending on whether they involve different activities or services and the revenue range considered.

The new regime does not provide for the application of sector studies, ISA or other synthetic indicators of fiscal reliability. There is also exclusion from VAT obligations

ODV and APS: tax advantages and requirements

In parallel to the general regime, the Code provides specific flat-rate regimes for Volunteer Organizations (ODV) and Social Promotion Associations (APS),1% for ODV, 3% for APS85,000 euros per annum

The regime involves significant simplifications, including exemption from accounting registration obligations, certification of fees and the carrying out of withholdings. However, the obligation to conserve the documents issued and received remains, in addition to the annual tax return.

An important change introduced by Legislative Decree 186/2025

Accounting simplifications and new management rules

The changes are not limited to taxation. The new regulatory system also involves a rethink of the accounting and documentary management of the ETS

For non-commercial ETS, the option for the flat-rate regime is exercised in the tax return and is binding for at least three tax periods

The transition to the new system also requires a reflection on the internal governance of the entities: the obligation of transparency, the limits on various activities, the keeping of volunteers' registers and the requirements for the social budget - mandatory above certain thresholds - impose a more structured management, even for medium-small businesses.

A strategic opportunity, but we need to act now

2026 does not just represent a moment of formal adaptation, but a real opportunity to consolidate the legal, fiscal and organizational identity of Third Sector entities. The new regimes offer tangible benefits, but require conscious and planned choices. The risk of arriving unprepared for the deadline can translate into operational difficulties, loss of benefits, exclusion from public tenders and unexpected financial obligations.

The bodies, but also the professionals who assist them, are called upon to manage this change with attention and competence. There is not much time available, considering the need to adapt the statutes, verify the requirements for the flat-rate schemes, plan registration for the RUNTS