2025 ETS budgets: which models to adopt and what changes

With the start of the financial reporting season, Third Sector Entities (TSEs) whose financial year coincides with the calendar year are required to prepare their 2025 TSE financial statements. The choice of format to adopt requires careful consideration, in light of the rules introduced by Legislative Decree 117/2017 (Third Sector Code) and the models approved by the Ministerial Decree of March 5, 2020.

Ordinary balance sheet or cash flow statement?

Non-commercial ETSs must use one of the established ministerial templates. The ordinary financial statement consists of three inseparable documents: Balance Sheet, Management Statement, and Mission Report. Alternatively, if specific size restrictions apply, a cash flow statement, consisting of a single statement, may be used.

The choice of format for the 2025 ETS financial statements depends on two key elements: the possession of legal personality and the amount of annual revenue generated.

• ETS without legal personality
  • up to €300,000 in income: option to choose between cash flow statement and ordinary balance sheet;
  • over 300,000 euros: ordinary budget obligation.
• ETS with legal personality
  • up to 60,000 euros: option to opt for cash accounting;
  • over 60,000 euros: ordinary budget obligation.

A "super simplified" form of cash flow statement is also envisaged (Article 13, paragraph 2-bis), intended for entities with revenues not exceeding €60,000, but the relevant form has not yet been issued.

Rule for calculating thresholds: To determine the applicable regime for the 2025 budget, it is necessary to refer to the proceeds of the previous financial year (2024). Income from divestments (for example, the sale of capital goods) and those obtained through financing, such as mortgages, are strictly excluded from the calculation.

Loss of non-profit entity status

If the ETS is predominantly commercial in nature, the financial statements must be prepared in accordance with the provisions of the Civil Code. Social enterprises, in any case, are always required to be in the statutory form.

Documents to be attached and filed with the RUNTS

In addition to the actual financial statements, the overall file to be submitted must include:

• The reports of any occasional fundraisers (according to the model of the Ministerial Decree of 9 June 2022);

• The report of the supervisory body or the statutory auditor, if appointed;

• The minutes of the meeting's approval.

The filing must be made exclusively electronically with the National Third Sector Register (RUNTS) within 180 days of the end of the financial year: for the 2025 ETS financial statements, the deadline will be June 29, 2026. Entities also registered with the Business Register must comply with the reduced deadline of 60 days from approval.

Documents must be submitted in PDF/A format; filing may be carried out by the legal representative or another authorized person, including through a specific proxy.

Obbligo di bilancio sociale

ETSs with revenues exceeding one million euros must also prepare, file, and publish their social report on their institutional website, in accordance with the guidelines of the Ministerial Decree of 4 July 2019, within 180 days of the end of the financial year.

Correctly identifying the appropriate model and adhering to the filing deadlines are essential steps to ensure transparency, administrative regularity, and full compliance with Third Sector regulations. Careful prior verification of the entity's size requirements and tax status allows for greater confidence in the 2025 financial reporting season.

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