In short
Legislative Decree 197/2026, published in the Official Gazette on 28 October 2026, transposes Directive (EU) 2024/1785 and enters into force on 12 November 2026.
The operator of every installation subject to an AIA must prepare and implement an environmental management system by 1 July 2030.
The system must follow the BAT conclusions and include objectives, indicators, an inventory of hazardous substances and, for certain activities, a transformation plan.
The minimum elements must be published online and the system must undergo an external audit at least every three years.
The decree recognises systems certified to UNI EN ISO 14001:2015 or registered under EMAS as equivalent; the EU directive contains no such equivalence.
On 28 October 2026 Italy's Official Gazette (Gazzetta Ufficiale, General Series no. 251) published Legislative Decree no. 197 of 28 September 2026, which transposes Directive (EU) 2024/1785 on industrial emissions, known as IED 2.0, into Italian law. According to Normattiva, the decree enters into force on 12 November 2026. Among the new rules is an obligation that directly affects anyone operating a plant with an integrated environmental permit (AIA): to prepare and implement an environmental management system.
The decree amends Italy's Consolidated Environmental Act (Legislative Decree 152/2006) and sets a general deadline of 1 July 2030 for this requirement. So there is time, but the required content is specific: objectives and indicators linked to the BAT conclusions, an inventory of hazardous substances, online publication and a periodic external audit. In this guide you will find what the text says, who it applies to, how it relates to ISO 14001 and EMAS, and what is worth doing now.
What does Legislative Decree 197/2026 on industrial emissions provide?
Legislative Decree 197/2026 implements Directive (EU) 2024/1785, which amended Directive 2010/75/EU on industrial emissions and Directive 1999/31/EC on landfill. In Italy these rules sit mainly in Part Two of Legislative Decree 152/2006, which governs the integrated environmental permit. The decree therefore amends many articles of the Consolidated Environmental Act, from definitions to permit conditions, from inspections to permit reviews.
The directive required Member States to transpose it by 1 July 2026. The Italian decree is dated 28 September 2026, was published on 28 October and, as the Normattiva record shows, enters into force on 12 November 2026. It is a wide-ranging text: besides the environmental management system it covers environmental performance levels, emission limit values, the rules for livestock farms and landfill.
The heart of the change: Article 29-sexies
The environmental management system enters the Consolidated Act through Article 13 of the decree, which amends Article 29-sexies of Legislative Decree 152/2006. A new paragraph 1-bis sets out the obligation, and new paragraphs 9-octies to 9-duodecies define its content, level of detail, transformation plan and publication.
The same article states that the AIA must contain appropriate provisions defining the characteristics of the environmental management system. In parallel, Article 3 of the decree adds the implementation of the environmental management system to the general principles of the AIA (Article 6(16) of the Consolidated Act). It is therefore not optional or simply recommended good practice: it becomes part of the rules for operating the plant.
Who must adopt an environmental management system?
The new paragraph 1-bis refers to every installation falling within the scope of the title dedicated to the AIA. The obligation lies with the operator, meaning whoever runs the installation. It therefore does not concern all businesses, only those operating plants that carry out activities subject to an integrated environmental permit.
If your company holds an AIA, check with your environmental adviser and the competent authority how the new rules apply to you. If you operate under other permits, such as a single environmental authorisation (AUA), this specific obligation does not stem from paragraph 1-bis. It is still worth checking whether the decree has extended the activities subject to an AIA and whether your plant falls within the new scope.
Do you need to apply for a new AIA?
No. The decree does not require you to submit a new AIA application in order to adopt an environmental management system. The obligation arises directly from the law, with its own deadlines. Permit conditions are updated through the existing review mechanisms: for existing installations, Article 43(2) of the decree provides that the new rules on AIA content, including those on the environmental management system, apply from when the permit is reviewed or updated, and in any case by 1 September 2036.
Installations with different timelines
The decree sets specific timelines for some categories that are only now coming into scope or that follow their own rules, such as pig and poultry farms, for which a separate title is introduced. The rules are in Article 43 of the decree, transitional provisions that need to be read case by case. If your plant falls into one of these categories, check which date applies to you before planning.
What must the environmental management system contain?
Paragraph 9-octies states that the environmental management system must be consistent with the relevant BAT conclusions, which determine the aspects to be covered, taking into account any implementing acts of the European Commission. The text then lists the minimum elements:
environmental policy objectives for the continuous improvement of the environmental performance and safety of the installation, with measures to prevent waste, optimise the use of resources and energy and the reuse of water, and prevent or reduce the use or emissions of hazardous substances;
objectives and performance indicators for significant environmental aspects, taking into account the benchmarks set in the BAT conclusions;
for those subject to an energy audit or an energy management system under Article 8 of Legislative Decree 102/2014, the inclusion of the related results and of the measures to implement its recommendations;
an inventory of the hazardous chemicals present in or emitted by the installation, with a risk assessment for human health and the environment and an analysis of the possibilities of replacing them or reducing their use or emissions;
the measures taken to achieve the environmental objectives and avoid risks to human health or the environment, including corrective and preventive measures where necessary;
the transformation plan under paragraph 9-decies, where required.
Compared with a "classic" management system, the newest elements are the inventory of hazardous substances with the substitution analysis and the direct link to the benchmarks in the BAT conclusions. These require technical data from the plant, not just procedures.
Proportionate to the plant, without duplicating documents
Paragraph 9-novies clarifies that the level of detail must be consistent with the nature, size and complexity of the installation and with its possible effects on the environment. A small, simple plant does not need to produce the same documentation as a large chemical site.
The same paragraph provides that, where objectives, indicators or measures have already been developed under other EU legislation and comply, a reference to the relevant documents is enough. In practice, what you have already produced for other obligations, such as the energy audit, can be referenced rather than rewritten.
Publication on the internet
The elements listed in paragraph 9-octies must be made available on the internet, free of charge and without restricting access to registered users. The text allows the information to be redacted or, where that is not possible, withheld if disclosure would harm the interests protected by Article 5(2) of Legislative Decree 195/2005, such as commercial and industrial confidentiality, provided the competent authority is informed in advance.
This point deserves attention: for many companies it is the first time that parts of the management system become public by law. It is worth deciding early what to publish, in what form and where, and documenting any redacted parts.
What are the deadlines and the transitional rules?
The general deadline is 1 July 2030, but the decree sets several related dates. We summarise them in the table, with the reference to the text.
Requirement | Deadline | Reference |
|---|---|---|
Prepare and implement the environmental management system | 1 July 2030 | Art. 29-sexies(1-bis) |
Installations granted an AIA later | Deadline for the first notification under Art. 29-decies(1) | Art. 29-sexies(1-bis) |
First audit of the system | By the same deadlines | Art. 29-sexies(1-bis) |
Further audits by an accredited body or environmental verifier | At least every three years | Art. 29-sexies(1-bis) |
Review of the system | At least at every AIA review with renewal effect | Art. 29-sexies(1-bis) |
Transformation plan (for certain activities) | 30 June 2030 | Art. 29-sexies(9-decies) |
Assessment of the transformation plan | 30 June 2031 | Art. 29-sexies(9-undecies) |
New AIA conditions on the system, for existing installations | At review or update, by 1 September 2036 at the latest | Art. 43(2) of the decree |
External audit every three years
Paragraph 1-bis requires the system to be audited at least every three years by a conformity assessment body accredited under Regulation (EC) 765/2008, or by an environmental verifier accredited or licensed under the EMAS Regulation (EC) 1221/2009. The audit checks that the system and its implementation comply with Article 29-sexies.
The transformation plan
By 30 June 2030 the operator includes an indicative transformation plan in the system if it carries out the activities in points 1, 2, 3, 4, 6.1.b and 6.1.c of Annex VIII to Part Two of the Consolidated Act. The plan describes how the installation will transform over the period 2030–2050 to contribute to a sustainable, circular and climate-neutral economy. Several installations of the same operator or company can be covered by a single plan.
Why the directive says 2027 and the decree 2030
In the text of Article 14a of Directive 2010/75/EU, as amended in 2024 and published on EUR-Lex, the deadline for preparing and implementing the system and for the first audit was 1 July 2027. The Italian decree sets 1 July 2030 instead. Meanwhile, at European level, the Commission has tabled a proposal to simplify environmental legislation (procedure 2025/0394(COD)) which, according to the European Parliament's Legislative Observatory, moves the deadline to 2030 and lightens some requirements of the environmental management system. It is a proposal: follow the outcome of the EU procedure, as it could affect the required content.
Are ISO 14001 and EMAS enough to comply?
The Italian decree contains a precise sentence at the end of paragraph 1-bis: systems already certified to UNI EN ISO 14001:2015 or registered under Regulation (EC) 1221/2009, that is EMAS, are recognised as equivalent. It is an explicit recognition that rewards those who have already invested in a certified or registered environmental management system.
It is just as important to be precise about what the text does not say. The European directive does not mention ISO 14001: it refers to the EMAS Regulation only to indicate who can carry out the audit, as an environmental verifier. The equivalence is a choice made by the Italian legislator. Moreover, the decree cites the 2015 edition of the standard and says nothing about the new ISO 14001:2026: if you are working on the transition to ISO 14001:2026, ask the competent authority how the reference will be read.
What still needs checking even if you are certified
The decree does not explain in detail how the equivalence fits with the specific elements of paragraph 9-octies, such as online publication, the inventory of hazardous substances or the transformation plan. On these points, pending any implementing guidance, the prudent choice is to compare your system with the list in paragraph 9-octies and close the gaps in good time, rather than assume the certification covers everything.
An advantage that already existed
Article 29-octies of the Consolidated Environmental Act already provides an advantage for those with a recognised system: the periodic AIA review, which normally falls due after 10 years, is extended to twelve years for ISO 14001 certified installations and to sixteen years for EMAS registered ones. The review triggered by the publication of new BAT conclusions still applies. With Legislative Decree 197/2026 the environmental management system becomes mandatory for all AIA plants, and an existing certification is a solid starting point. To understand how the standard works, read our guide to the ISO 14001 environmental management system.
What to do now: the operational checklist
The deadlines are some way off, but a few steps do not take much effort and show straight away how much work lies ahead. Here is where to start.
Check whether your plant is subject to an AIA and whether the decree has changed the activities or thresholds that concern you.
Identify the BAT conclusions relevant to your main activity: they set out the aspects the system must cover.
Carry out an initial gap analysis between what you have today and the list in paragraph 9-octies.
If you are ISO 14001 certified or EMAS registered, check that the certificate or registration is valid and note the edition of the standard.
Start the inventory of hazardous chemicals present or emitted, beginning with safety data sheets and existing records.
Gather the results of the energy audit or energy management system, if you are subject to Article 8 of Legislative Decree 102/2014.
Check whether you carry out the activities that require a transformation plan by 30 June 2030.
Appoint an internal lead and add the decree's deadlines to your compliance calendar.
These steps help turn a long piece of legislation into a concrete work plan. The result is a map of the gaps to close before the deadline, with owners and timescales.
What to do in the medium term?
Between now and 2030 the work shifts from checking to building. The aim is to reach the deadline with a system that has been running for some time, not one written at the last minute.
Link objectives, indicators and BAT
Set objectives and performance indicators that take into account the benchmarks in the BAT conclusions, as paragraph 9-octies requires. Indicators should be measurable with the data the plant already collects, such as water and energy consumption, waste generated and reuse of materials. That way monitoring becomes a management tool rather than a separate formality.
Integrate energy, substances and environment
Many AIA companies already have an energy audit, an energy management system or chemicals obligations. Paragraph 9-novies allows you to reference existing documents where they comply, so it makes sense to organise them in a single system. If you already manage quality or safety, an integrated management system avoids duplicating procedures, audits and reviews.
Prepare for publication and audit
Decide early where and how you will publish the required elements and which confidential information you will need to redact, informing the competent authority. Plan an internal audit before the external one, to check that the system really works and not just on paper. Keep an eye on EU implementing acts and on the outcome of the simplification proposal, which could change some of the content.
How Complaion helps you with environmental management systems
Complaion supports companies with a dedicated Lead Auditor who follows the organisation over time and proposes the most suitable path, from ISO 14001 certification to integration with other management systems. The internal audit is carried out by the Lead Auditor, who checks how the system really works before the certification audit.
The Complaion platform collects evidence, manages documents, keeps the compliance calendar and prepares the audit. In ISO 14001 certification paths the Complaion method leads to the external audit with a 100% success rate. We work with more than 1,000 clients. If you want to understand where to start, contact us.
Frequently asked questions on the environmental management system for AIA plants
When does Legislative Decree 197/2026 enter into force?
The decree was published in Official Gazette no. 251 of 28 October 2026 and, according to Normattiva, enters into force on 12 November 2026. The obligation to prepare and implement the environmental management system, however, has its own deadline, generally set at 1 July 2030.
Is the environmental management system mandatory for all companies?
No. Paragraph 1-bis concerns installations falling within the scope of the AIA rules, and the obligation lies with the operator. If you do not hold an AIA, this obligation does not directly concern you, but check whether the changes to the annexes of the Consolidated Act have altered your position.
Is ISO 14001 certification enough?
The decree recognises systems already certified to UNI EN ISO 14001:2015 or registered under EMAS as equivalent. The text does not explain how the equivalence fits with specific elements such as online publication or the inventory of hazardous substances: it is worth comparing your system with paragraph 9-octies and asking the competent authority for confirmation.
Who can audit the environmental management system?
Under paragraph 1-bis, the periodic audit is carried out by an accredited body for conformity assessment under Regulation (EC) 765/2008, or by an environmental verifier accredited or licensed under the EMAS Regulation. It must be repeated at least every three years.
Do I have to publish the whole management system online?
The elements listed in paragraph 9-octies must be published, free of charge and without registration. Information whose disclosure would harm protected interests, such as commercial confidentiality, can be redacted or, where that is not possible, withheld, after informing the competent authority in advance.
What is the transformation plan?
It is an indicative document describing how the installation will transform between 2030 and 2050 to contribute to a climate-neutral economy. It is required by 30 June 2030 for the activities in points 1, 2, 3, 4, 6.1.b and 6.1.c of Annex VIII and forms part of the environmental management system.
