Eligibility for the Voucher Cloud & Cybersecurity is set by article 4 of the ministerial decree of 18 July 2025 and referenced by article 3 of the directorial decree of 4 August 2026. The requirements must be met when the application is submitted and are declared in the form of a self-certified declaration (DSAN, dichiarazione sostitutiva di atto notorio).
Who is eligible
Grants are available to SMEs and self-employed workers operating throughout national territory. The directorial decree clarifies that all SMEs are eligible regardless of legal and organisational form, as are all self-employed workers regardless of role and activity.
SMEs are micro, small and medium-sized enterprises meeting the requirements of European Commission Recommendation 2003/361/EC and Annex I of Regulation (EU) No 651/2014 (GBER). A self-employed worker is a natural person practising an art or profession within the scope of article 1 of law 81 of 22 May 2017, including professionals registered with a professional body and those practising one of the professions not organised in bodies or colleges under article 1(2) of law 4 of 14 January 2013.
Each applicant may submit only one application. The spending plan may cover several local units; the application states the one where it mainly takes effect.
Entities already on the supplier list may also apply, provided they meet the same requirements and acquire the services from suppliers other than themselves and included in the list.
Ministerial decree of 18 July 2025, article 1(1)(b) and (c), and article 7(5); directorial decree of 4 August 2026, article 3 and article 5(3) and (6).
The 30 Mbps connectivity contract
The requirement that characterises this measure is holding, at the time of submission, a contract for connectivity services with a minimum download speed of 30 Mbps. The application declares possession of the contract; at disbursement stage a copy must be submitted and, on a sample, Infratel verifies that the service is actually available.
If the current contract falls short, the upgrade must be completed before the application is submitted and depends on the operator's activation times. This is the check worth starting first.
Ministerial decree of 18 July 2025, article 4(1); directorial decree of 4 August 2026, article 7(4) and (5).
Requirements for businesses
Under article 4(2), businesses must:
- be duly incorporated, registered in the Business Register and active;
- be in full and free exercise of their rights, not in voluntary liquidation nor subject to insolvency proceedings for liquidation purposes;
- be compliant with insurance obligations covering damage directly caused by natural disasters and catastrophic events, under article 1(101) of law 213 of 30 December 2023 and decree-law 39 of 31 March 2025;
- not be among businesses that received and did not repay, or deposit in a blocked account, aid identified as unlawful or incompatible by the European Commission;
- not be active in the sectors excluded by article 1 of the de minimis regulation;
- not fall under the grounds for exclusion in paragraph 4 of the same article.
Self-employed workers not required to register in the Business Register need only hold a VAT number, subject to registration with the relevant professional body where required and to the other requirements where compatible.
Ministerial decree of 18 July 2025, article 4(2) and (3).
Grounds for exclusion
Paragraph 4 excludes in all cases those subject to the disqualifying sanction under article 9(2)(d) of legislative decree 231 of 8 June 2001, or another sanction entailing a ban on contracting with public administration; those whose legal representatives or directors have been convicted, at the date the application is submitted, by final judgment or by a criminal conviction order that has become irrevocable, of offences constituting grounds for excluding an economic operator from a procurement or concession procedure; and those in other conditions which the law treats as causing incapacity to receive public financial support or as otherwise precluding it.
Ministerial decree of 18 July 2025, article 4(4).
Social security compliance is not an access requirement
This deserves clarification, because the point is often reported imprecisely. Article 4 does not list tax and social security compliance among the requirements declared in the application.
The check happens at a later stage: for the purposes of disbursement, the Ministry verifies compliance with the rules on public contributions, including the absence of defaults under article 48-bis of presidential decree 602/1973 and, for businesses, current social security compliance through acquisition ex officio of the DURC certificate. It is therefore not something the applicant files at application stage, but it remains a condition to keep in order because it affects payment.
Ministerial decree of 18 July 2025, article 9(4); directorial decree of 4 August 2026, article 7(5)(c).
The de minimis regime and combining aid
Grants are awarded under the de minimis regulation, Commission Regulation (EU) 2023/2831 of 13 December 2023, and may be combined with other State aid, including de minimis, within the limits set by the relevant European State aid rules.
Two practical implications. First, the grant consumes the business's de minimis allowance, so remaining headroom must be checked before deciding how much to claim. Second, if the national aid register shows that the ceiling set by the de minimis regulation has been exceeded, the application is not accepted and the Ministry notifies the business of the reasons.
Ministerial decree of 18 July 2025, article 1(1)(f) and article 6(2); directorial decree of 4 August 2026, article 1(1)(h) and article 6(4).
The reserve for southern regions
Of the EUR 150 million total, EUR 71,065,813.34 is reserved for operations in Abruzzo, Basilicata, Calabria, Campania, Molise, Puglia, Sardinia and Sicily. This is not a personal requirement: what counts is the location of the local unit where the spending plan mainly takes effect, which is stated in the application.
Ministerial decree of 18 July 2025, article 3(2); directorial decree of 4 August 2026, article 2(3) and article 5(3)(b).
Checks that cannot be compressed
Among the requirements listed, three involve steps that cannot be completed in a day and must be completed before the application is digitally signed, because the requirements must be met when it is submitted: any upgrade to the connectivity contract, taking out the catastrophe-risk insurance cover, and verifying de minimis headroom. The other registration and status requirements appear in the company registration extract (visura camerale); the grounds for exclusion in paragraph 4 require separate checks.
The insurance obligation of law 213/2023 applies to businesses required to register in the Business Register; for self-employed workers not required to register, the further requirements apply where compatible. The declaration that the insurance obligation has been met must be made in the application, on pain of the application being inadmissible, and is checked again at disbursement stage.
The declarations still matter after the award: the Ministry verifies their truthfulness on a sample basis at every stage of the procedure, and the grant is revoked if it is established that one or more article 4 requirements are not met or if the declarations prove false or non-compliant.
Ministerial decree of 18 July 2025, article 4(1) and (3), and article 12(1)(a) and (b); directorial decree of 4 August 2026, article 5(3)(i), article 7(5)(d) and article 9.
On the procedural side there remain the digital identity, the digital signature and the PEC mailbox, described in the guide to submitting the application.
References
- Ministerial decree of 18 July 2025, articles 1, 3, 4, 6, 7, 9 and 12.
- Directorial decree of 4 August 2026, articles 1, 2, 3, 5, 6, 7 and 9.
- Commission Regulation (EU) 2023/2831 of 13 December 2023.
This article is current as of September 2026 and does not replace the official texts.
