The permitting framework in brief
Legislative Decree 25 November 2024 no. 190, the consolidated act on renewable energy (Testo unico FER), reorganises authorisation regimes into three categories: free activity, the PAS (procedura abilitativa semplificata, simplified authorisation procedure) and the single authorisation (AU). For some projects, environmental checks are added, such as an EIA (VIA) or a screening procedure.
Which regime applies depends on the type of plant, its size and its location. The classification of suitable areas, defined by the national rules (DM 21 June 2024) and by regional laws, also affects procedures and timing. For a complete overview, read our guide to PAS and AU solar permitting.
PAS filed vs PAS approved: two teaser fields
Pipeline.Solar registers each project with standard fields. Two of them describe the permitting status:
- PAS filed: the application has been submitted to the competent municipality. The procedure is running, but the outcome is not yet final.
- PAS approved: the procedure has been completed and the project has its authorisation title.
Keeping the two fields separate avoids ambiguity. A project with PAS filed but not approved is a late-stage project; a project with PAS approved, accepted STMG and secured land is typically ready to build. Both can be relevant, depending on your mandate.
PAS and AU: what changes for the investor
The PAS is handled at municipal level and is generally used for projects that fall within the conditions set for simplified procedures. The AU is a broader procedure, usually managed by the region or a delegated body, involving a conference of services with the authorities concerned.
From an investor's point of view, the differences matter in three areas:
- Content of the title: the AU may include the grid works and other ancillary authorisations in a single act, while with a PAS some of these may require separate steps.
- Prescriptions: both titles may contain conditions to be met before or during construction.
- Challenge risk: any authorisation can be challenged within the terms provided by law, a point your legal advisors will check.
What remains after the permit
An approved PAS is a key milestone, but it is not the end of development. After the title, an authorised solar project usually still requires:
- the authorisation or completion of the grid connection works under the accepted STMG;
- the final deed on the land, if the surface right or purchase is still under option;
- compliance with any prescriptions contained in the title;
- the executive design and the selection of the EPC contractor;
- the financing structure and, where relevant, participation in support schemes such as FER X.
Checking the validity period of the title and any deadlines for starting works is part of the investor's due diligence.
Who buys permitted solar projects
Authorised projects attract investors who want to limit development risk and move quickly to construction: infrastructure funds, IPPs, utilities, industrial investors and EPC contractors who want to build their own assets. Foreign investors entering Italy often start from this stage because the main administrative uncertainty has already been resolved.
The purchase can take the form of a share deal on the project company or an asset deal with transfer of the titles. See solar SPV share deal for the first option.
In an asset deal, the transfer of the authorisation title to the buyer follows the procedures provided for the specific title and must be coordinated with the transfer of the grid connection and of the land rights. In a share deal the titles stay with the project company, and the focus shifts to the history and liabilities of the company itself.
Receive teasers for authorised projects
Contact us via WhatsApp or the investor access form. After an introductory call you get a personal link to the reserved area, where you set your criteria: stages, minimum and maximum capacity of the single plant, regions, technologies and structures. When a project with PAS approved matches your range, the staff sends you a teaser. Then come the NDA, the data room and direct negotiation with the owner.
Frequently asked questions
Is a project with PAS approved automatically RTB?
Not necessarily. RTB usually also requires an accepted STMG and secured land rights. The teaser shows each element separately.
Do you also share projects authorised through AU?
Yes. Projects authorised through the single authorisation are shared in the same way, with the permitting status described in the teaser and in the documents after the NDA.
Can I see the PAS documents before signing the NDA?
No. The teaser contains summary data only. The authorisation documents are made available in the data room after the NDA.