The Tax tutor for businesses: growth in membership of cooperative compliance and future prospects
Quick Look
- Membership of the cooperative compliance regime went from 111 in 2023 to 224 in 2026, with 60 companies on the waiting list and the aim of exceeding 280.
- The companies already participating represent over one thousand billion euros in capitalisation, equal to 75% of the total companies listed in Milan.
- From 2028 the access threshold will drop from 500 to 100 million euros in turnover, potentially involving another 11 thousand SMEs, although membership requires initial investments and continuous internal monitoring.
AI-generated summary
Why It Matters
Cooperative compliance, also known as collaborative compliance, is a regime that allows companies to equip themselves with a Tax control framework (Tcf) to manage tax risk in full transparency with the financial administration. Membership grew from 111 in 2023 to 224 in 2026, with the aim of exceeding 280 thanks to 60 companies on the waiting list.
The Tax Tutor for Business continues to slowly but surely gain ground. The numerical dynamics shows how from the 111 memberships in 2023 we went to 142 in 2024 up to 221 in 2025. A growth that further continued in 2026 reaching 224. But the prospect is to exceed 280, thanks to the 60 companies that have applied to join and are on the waiting list. The challenge is to extend the number of taxpayers who equip themselves with the Tax control framework (Tcf), i.e. a tax risk control and management system, and who therefore have a fully transparent relationship with the financial administration.
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In reality, the simple data of current and potential memberships does not fully capture the value of the regime which is technically called cooperative compliance or collaborative compliance. To have an order of magnitude it is necessary to refer to what was declared a few days ago by the director of Revenue Vincenzo Carbone during a conference organized by the National Council of Chartered Accountants and Accounting Experts. In practice, the (large) companies that are already currently under mentorship have a capitalization value exceeding one trillion euros. A figure arrived at starting from the value of the capitalization of companies listed on the Milan Stock Exchange which is equal to approximately 1,500 billion. 75% of this amount, i.e. more than 1,000 billion, is attributable to corporate groups in collaborative compliance.
the main entrance door to the regime is represented by the threshold of 500 million euros of turnover or turnover (if the requirements are met, you can also enter from other "lateral" doors such as, for example, the request for new investments). But from 2028 the threshold will drop lower to 100 million euros, as foreseen by the timetable outlined for the implementation of the tax reform. An expansion that could include another 11 thousand businesses.
The real challenge is represented by the optional entry by SMEs, which are below the size threshold. The financial administration is focusing a lot on this opportunity. This is demonstrated by the widespread investment in knowledge of the regime, but also in terms of human resources with the significant strengthening of staff specifically dedicated to cooperative compliance. Naturally, it must be considered that cooperative compliance requires both a strong initial investment to equip itself with the TCF and a continuous and constant internal monitoring capacity of all company functions to ensure that full transparency towards the tax authorities can then continue over time.
What to Watch
AI outlook — possibilities, not facts
The number of companies participating in cooperative compliance will exceed 280 by the end of 2026
Likely · Within months
From 2028 at least another 11 thousand companies will be able to access the cooperative compliance regime thanks to the reduction of the turnover threshold from 500 to 100 million euros
Likely · Within years
Open Questions
- What are the exact criteria for accessing the scheme via the 'side doors' other than the turnover threshold?
- What will be the actual impact of reducing the threshold to 100 million euros on SMEs in terms of compliance costs and tax benefits?
- How will the expected increase in staff dedicated to cooperative compliance be managed to support the entry of SMEs?






