From 21 September 2026 SIMEST is accepting applications for the “Investimenti IA” (AI Investments) section of Fondo 394/81: €200 million for artificial intelligence, a 50% advance and up to 10% as a non-repayable grant. A company can apply if it exports at least 3% of its turnover, or makes at least 10% of it with customers that export, and puts the whole intervention into AI.
Applications are submitted on the Portale Simest dei finanziamenti agevolati (SIMEST’s subsidised financing portal), as SIMEST announced in a press release on 14 September. Fondo 394/81 is by nature an instrument for companies that work with other countries. In the instrument the section comes from, Transizione Digitale ed Ecologica (Digital and Ecological Transition), the ordinary rules normally require at least 10% of turnover to come from exports. The artificial intelligence section lowers that threshold to 3%, and in exchange requires the whole intervention, down to the last euro, to go on AI expenses. A company that takes on this commitment can ask for a higher advance, a longer repayment period and a grant share. The press release gives a minimum rate of 0.37% “as of today”.
The requirements, figures and eligible expenses below come from circular no. 4/394/2023, in its July update. The full conditions remain those of the circular, and the circular should be read with your accountant.
Who can apply: the requirements
The requirement looks at the last financial year and has two routes: at least 3% of turnover from exports, or at least 10% made with client companies that export.
The second concerns companies that reach foreign markets through their customers. It applies if at least 10% of total turnover, that is item A1 of the income statement, is made with one or more exporting companies, and each of these in turn has export turnover of at least 3%. A company that makes components for a manufacturer that sells abroad may qualify even if all its invoices stay in Italy.
This second route, with the same numbers, already exists among the ordinary requirements. What is new in the section is the first. Under the ordinary requirement, 3% of exports is enough for energy-intensive companies or for those that have started a programme to reduce their energy consumption; for a company that exports between 3 and 10% of its turnover, is in neither of those two cases and does not reach 10% with exporting customers, this section is a new door.
The check is done with the latest financial statements and the list of main customers. For each one you need to know how much it weighs on your turnover and whether it sells at least 3% of its own abroad. You usually do not have your customers’ financial statements in-house: how that figure is documented is a question to put to SIMEST or your accountant before counting on it.
Then there is the commitment, which is made already in the application: 100% of the resources of the intervention goes to expenses attributable to artificial intelligence, those summarised in Annex 2 of the circular.
A company that already meets the ordinary requirements also has another route to weigh up. In the ordinary instrument, AI expenses are among the expenses allowed for the digital transition, so a mixed project, with one part AI and one part something else, can look there, under the ordinary rules of the circular. The conditions described further down, in that case, do not come from the AI commitment, and the declaration of compliance with AI legislation must be made anyway, because the circular requires it from anyone who puts even just part of the intervention into AI.
How much you can ask for
The minimum amount is €10,000. The maximum is the lower of two numbers: 35% of the average revenue of the last two financial statements, and a ceiling that depends on the size of the company.
| Company | Ceiling |
|---|---|
| Micro enterprise | €500,000 |
| SMEs, including those and the start-ups in the special categories provided for by the circular | €2,500,000 |
| Other companies | €5,000,000 |
The ceiling applies to the sum requested from SIMEST, between financing and any co-financing. It is worth doing the calculation on the last two financial statements before designing the project. How to handle a project that costs more than that sum is a question for your accountant.
Advance, repayment and grant: what you get
With the 100% commitment you can ask for a 50% advance, 2 more years of repayment and up to 10% as a grant, with a maximum of €100,000. The circular also grants the first two to other companies: the energy-intensive ones or those committed to reducing their energy consumption, those of the “Energia per la Competitività Internazionale” (Energy for International Competitiveness) measure and those with interests in the United States.
The advance rises to 50%. The first tranche, paid as an advance, is half of the intervention; the ordinary rule is 25%. It arrives within 30 days of any conditions precedent for disbursement being met, which must be settled within 15 days of the communication following the signing of the contract or of the proposal for a security deposit.
Repayment can be extended. The financing lasts 6 years from signing: 2 of pre-amortisation and 4 of repayment. You can ask for 2 more years on the repayment period, and indeed the press release speaks of financing of up to 8 years.
A grant share. You can ask for non-repayable co-financing of up to 10% of the intervention, with a maximum of €100,000. The AI commitment is one of the alternative requirements that give access to this share, and the award is decided by SIMEST’s Comitato Agevolazioni (Subsidies Committee).
The co-financing is granted within the limits of “de minimis”, the ceiling on aid set by Commission Regulation (EU) 2023/2831. The press release places the subsidised rate under the same regime too. If the company has already received other de minimis aid in recent years, it is worth asking your accountant how much room is left.
The deadlines, and what is at risk
Expenses must be incurred, invoiced and paid within the implementation period, which begins when the CUP code arrives and ends within 24 months of signing. An extension of up to 6 months can be requested.
Before that deadline there is another: within 12 months of signing the company must submit a first report on the expenses incurred. If it is missing, the circular provides for revocation of the entire intervention.
Then there is the revocation tied to the commitment. The part of the intervention that in the end did not go on AI expenses is revoked pro rata, on the financing and the grant together. The revocation is total if the intervention was used, even in part, for artificial intelligence systems prohibited by Article 5 of the AI Act. In addition, in the application and at the final report, the company signs a declaration of compliance with AI legislation.
Which AI expenses are eligible
Annex 2 of the circular summarises the expenses attributable to AI under ten headings. The third, “Sviluppo & Implementazione” (Development & Implementation), concerns building the system and contains these lines:
- custom development of proprietary models;
- fine-tuning of pre-trained models and monitoring of model performance (model drift);
- integration with existing systems (ERP, CRM, MES, SCADA);
- testing and validation of models;
- prompt engineering and optimisation.
Two neighbouring headings complete the picture. The fourth, “Dati” (Data), covers collecting and buying datasets, cleaning, labelling and preparing data, data governance and data quality tools. The tenth covers consultancy aimed at designing and building the solutions under the previous headings.
In practice, the list includes a model built on your data or one that already exists and is adapted to your case, the work to prepare that data, the connection with the management system and the CRM, testing before release and monitoring of the model afterwards.
What to decide before the application
The whole intervention must go on AI expenses. In this section a project that puts one part on non-AI expenses and the rest on a model does not get through. That means taking four decisions before opening the portal.
The first is the task to start from. A task that today costs hours or errors, and that a model can do or help do: checking images, or searching through thousands of documents.
The second is the data. A proprietary model is trained on your data, and it is worth knowing beforehand where it is, what format it is in, who can extract it and whether there is enough of it. Data preparation is a heading in the Annex, so it can be part of the project.
The third is the schedule. The plan must be divided into phases with dates, and the first phase must produce expenses to report within the 12 months of the first report. Whoever builds the system must be able to say what falls within the implementation period and what stays outside.
The fourth is whether the project really is artificial intelligence. A portal for customers or a new management system may be worth the investment, and in this section they stay out. Presenting them as AI exposes you to pro rata revocation.
What “custom development of proprietary models” means
It means a model built on the data and the problem of whoever commissions it. One example is a project of ours.
For a research and teaching institution we built a microscopy platform. The problem: slides to analyse one by one, and images too large for the tools in use. Alongside the platform we built a machine learning software, written in Tensorflow, that analyses the images and recognises on its own whether the cells identified are affected by certain pathologies.
The client is a public body, and the case should be read for what it shows: the first line of the “Sviluppo & Implementazione” heading applied to a real problem.
Artificial intelligence is also the business of Neurally, the company we founded.
On the tailored software development page you will find the six phases we work in, from analysis to maintenance, and three projects, microscopy included.
How to submit the application
The application is submitted by the company on the Portale Simest dei finanziamenti agevolati, from 21 September 2026. Before opening it, five checks, in the order in which it makes sense to do them:
- the requirement on the last financial year: at least 3% exports, or at least 10% of turnover with customers that export at least 3% of theirs; and, if you already export 10%, whether the ordinary instrument suits you better;
- the ceiling, calculated on the last two financial statements with 35% of average revenue and the threshold for your size;
- the task the project starts from, and checking that it is all AI expense;
- the data: where it is, what format it is in, who extracts it, whether it is enough;
- a phased plan with the first report within 12 months and the expenses closed within 24 months of signing.
If you want to think through the project before submitting the application, we start with a call, free of charge.