PEC Obligation for Directors 2025: All the New Regulations

The new regulation on digital domiciles has introduced the obligation for all company directors to have a personal PEC address by June 30, 2025. This provision, contained in the 2025 Budget Law and clarified by the recent press release from the Ministry of Business and Made in Italy, represents a further step towards the complete digitalization of communications between businesses and the Public Administration.

Unlike the past, when the digital domicile of the company was sufficient, the new regulation requires that every single director has their own personal PEC, distinct from the corporate one, to be communicated to the Register of Companies by the established deadline.

Who is Subject to the Obligation

The obligation to communicate the personal digital domicile applies to:

• Sole directors
• Members of the Board of Directors
• General Managers
• Liquidators
• Commissioners of extraordinary administrations

The requirement applies to all directors of companies registered in the Register of Companies (Spa, Srl, Sapa, Scarl, Scapa and Cooperatives), including non-resident directors and non-EU citizens.

On the other hand, the following are excluded from the obligation:

• Statutory auditors and members of the board of statutory auditors
• Directors of consortia
• Directors of consortium companies
• Directors of non-agricultural simple partnerships
• Directors of business networks without legal personality

It is important to emphasize that the obligation concerns each director individually, regardless of the form of the management body (sole director, board of directors, joint or several management).

Deadlines and Timeline

To comply with the regulation on the digital domicile of directors, it is necessary to adhere to the following deadlines:

Failure to respect these deadlines results in the application of administrative sanctions as provided for in Art. 2630 of the Civil Code.

Communication Methods and Requirements

To correctly fulfill the obligation, every director must:

1. Equip themselves with a personal PEC address (different from that of the business)
2. Keep the PEC address active and functioning
3. Promptly communicate any variations

The communication must be carried out using model S2 for corporations and model S5 for partnerships, filling in the appropriate section dedicated to directors and indicating, for each, the relative digital domicile.

Sanctions and Consequences of Non-Compliance

Failure to comply with the obligation to communicate the digital domicile results in:

• Administrative sanction from 103 to 1,032 euros for each non-compliant director
• Possible automatic assignment of a digital domicile by the Chamber of Commerce
• Charging of costs for the automatic assignment
• Potential difficulties in official communications with the Public Administration

In addition, it is important to emphasize that communications sent to the digital domicile produce legal effects even if not read by the director, with possible negative consequences in case of failure to respond to important notifications.

How Gruppo AQ Can Support You

Gruppo AQ, through its division specialized in corporate consultancy, offers a complete service for the management of the PEC obligation for directors:

• Preliminary analysis of the corporate situation and specific obligations
• Activation of personal PEC boxes for directors
• Compliance verification of already existing PECs
• Preparation of the communication to the Registry of Companies
• Monitoring of deadlines to avoid sanctions
• Ongoing assistance for the management of the digital domicile

The professionals of Gruppo AQ guarantee a personalized approach that takes into account the specificities of each business and its administrative structure. Our integrated consultancy allows to manage the fulfillment in an effective way, minimizing the operational impact and guaranteeing full regulatory compliance.

Concrete Examples

Case 1: Company with sole director
An S.r.l. with a sole director must ensure that the latter has a personal PEC address different from the corporate one and communicates it by June 30, 2025.

Case 2: Company with Board of Directors
An S.p.A. with a board of directors composed of 5 members must ensure that each of the 5 directors communicates their personal PEC address.

Case 3: Director of multiple companies
A professional who holds the position of director in 3 different companies can use the same personal PEC address for all positions, as long as it is different from the PECs of the managed companies.

Conclusions: Why Rely on Gruppo AQ

The obligation to communicate the personal digital domicile for directors represents a further step in the process of digitalization of Italian companies. Although it involves an additional requirement, it offers advantages in terms of simplification, timeliness, and certainty of communications with the Public Administration.

Gruppo AQ, with its consolidated experience in the field of corporate and tax consultancy, represents the ideal strategic partner to manage this requirement effectively and in a timely manner. Our team of professionals is at your disposal for a personalized consultancy that takes into account the specificities of your company and its administrative structure.

Do not risk avoidable sanctions: contact Gruppo AQ for a preliminary assessment of your situation and discover how we can help you respect the deadline of June 30, 2025, with maximum tranquility.

Did you know that…?

1. Italy is the first European country for the number of active PEC boxes, with over 14 million active addresses in 2024 (Source: AgID)
2. According to a recent study, 40% of directors of Italian SMEs were not aware of the new personal PEC obligation (Source: Infocamere)
3. Italy is in fourth place in Europe for digitalization of public administration, with particular reference to the use of certified electronic mail, after Estonia, Denmark, and Finland (Source: Eurostat)
4. A PEC communication costs on average 85% less than a traditional registered letter (Source: Ministry of Business and Made in Italy)
5. 30% of sanctions to companies are due to the failure to read official communications sent via PEC (Source: Unioncamere)
6. In 2024, 78% of administrative procedures initiated by the PA towards companies were managed in digital format (Source: eGovernment Observatory of the Polytechnic University of Milan)

FAQ

1. Can I use the same corporate PEC as my personal digital domicile? No, the regulations expressly require that the director has a personal PEC address, distinct from that of the business.

2. If I am a director of multiple companies, do I need to have a PEC for each? No, a single personal PEC address to be communicated for all companies in which one holds the position of director is sufficient.

3. Does the obligation also apply to directors not resident in Italy? Yes, the obligation applies to all directors of companies registered in the Italian Registry of Companies, regardless of their residence.

4. Who must physically carry out the communication to the Registry of Companies? The communication can be made by the director himself or by a qualified professional (accountant, consultant). The responsibility for the requirement, however, remains with the director.

5. What happens if I change my PEC address after having communicated it? Every change of the PEC address must be promptly communicated to the Registry of Companies with the same procedures as for the initial communication.

6. Does the obligation also apply to companies in liquidation? Yes, the obligation also applies to directors of companies in liquidation, as long as they remain registered in the Registry of Companies.