RENTRI has entered the phase that directly affects most businesses, and the 2026 deadlines have caused considerable confusion. The most common misunderstanding concerns the digital FIR: many believe the paper form was banned from 13 February 2026, but this is not the case. Until 15 September 2026, you may still choose it as an alternative. In this guide, we explain what really changes: what RENTRI is, who must register and when, how the dual-track system works, and what you should do now to be ready for the deadline.
What are RENTRI and the digital FIR?
RENTRI is the Italian National Electronic Register for Waste Traceability: a system that digitises how companies record and move their waste. It is provided for by Article 188-bis of Legislative Decree 152/2006 and governed by Ministerial Decree No. 59 of 4 April 2023. It is managed by the Ministry of the Environment and Energy Security with the support of the National Register of Environmental Managers.
To understand how RENTRI works, keep two tools in mind. The first is the chronological waste loading and unloading register, which becomes digital. The second is the FIR, the Waste Identification Form, i.e. the document that accompanies waste during transport. Its electronic version, the digital FIR (or xFIR), replaces the old paper form: it is completed, signed and transmitted through the RENTRI portal services or connected management software.
Who must register and when: the three phases
Registration with RENTRI did not begin at the same time for everyone: its introduction was phased according to the type of waste and number of employees. The three registration windows are:
- First phase (from 15 December 2024 to 13 February 2025): facilities, carriers, brokers and producers of hazardous waste with more than 50 employees.
- Second phase (from 15 June to 14 August 2025): producers with between 11 and 50 employees.
- Third phase (from 15 December 2025 to 13 February 2026): producers of hazardous waste with up to 10 employees and other remaining categories subject to the requirement.
Watch out for a common misunderstanding: not every company that produces waste is among the entities required to register. The relevant factors are the activity carried out, the type of waste and the exemptions introduced by the 2026 Budget Law (Law 199/2025), which eased the rules for some categories. The precise list of exemptions should be checked on the official portal, as it is the most up-to-date source.
Paper FIR until 15 September 2026: the transitional regime
This is the heart of the matter. Ministerial Decree 59/2023 set the start date for the digital FIR as 13 February 2026, but Decree-Law 200/2025, converted into Law No. 26 of 27 February 2026, introduced a transition period: until 15 September 2026, the paper FIR may be issued as an alternative to the digital version. From 16 September 2026, however, the digital form becomes the only valid option for registered entities.
One often-overlooked point: the same shipment cannot be managed using a mix of formats. The producer or holder of the waste chooses the format, and that choice binds the entire chain. If the producer issues the FIR digitally, the carrier and recipient must also manage it digitally; if it is issued on paper, the entire chain remains paper-based. It is therefore advisable to agree on the method in advance with your partners.
How to prepare: operational checklist
To avoid leaving everything until the deadline, it is best to proceed step by step. Here are the practical steps to register with RENTRI and complete the transition:
- Check whether your company falls within the categories required to register, based on the type of waste and number of employees.
- Access the operator area of the portal using SPID, CIE or CNS, through a legal representative or a person authorised by the company.
- Obtain a qualified electronic signature, required to sign digital FIRs.
- Decide how you will issue the forms: the portal's free services are sufficient for low volumes, while API-connected management software is more suitable for companies with many waste movements.
- Agree on the format with carriers and recipients, and train the staff who will manage FIRs within the company.
Penalties: what you risk and what changes from 15 September
When it comes to penalties, it is important to distinguish between two areas, because this is where the main changes to RENTRI arise. Penalties for failure to register or irregular registration are already in force: anyone who was required to register and failed to do so is already exposed, although in many cases a reduction is available if compliance is restored within a short period.
The situation is different for transmission of FIR data to the system: the relevant penalties apply only from 15 September 2026. In other words, the transition period concerns the format of the form and data transmission, not the registration requirement, which remains in force. The amounts provided for by Article 258 of Legislative Decree 152/2006 vary according to the seriousness of the breach and the type of waste, and should be checked against the legislation currently in force.
Don't handle the deadlines alone!
Once the various obligations are separated, the framework is more manageable than it may seem: RENTRI registration follows deadlines that have already passed, while for the digital FIR you have until 15 September 2026 to complete the transition calmly. The right time to organise is now, while you can still choose the format and test the tools without pressure. If you would rather not navigate deadlines, signatures and system configurations alone, our consultants can support you with registration and compliance: contact us and we will identify what your company needs.
Frequently asked questions from clients
Here are the questions our clients ask most often.
- Do I have to switch to the digital FIR from 13 February 2026? No. Until 15 September 2026, you may continue issuing the FIR on paper as an alternative to the digital version. The digital form becomes mandatory as the sole option from 16 September 2026 for registered entities. It is still advisable to prepare in advance rather than deal with everything at the last minute.
- Is my company required to register with RENTRI? It depends. The requirement is determined by the type of waste produced, the activity carried out and the number of employees, not by a single criterion. Producers of hazardous waste are generally covered, while the 2026 Budget Law excluded certain categories. The safest approach is to check your position on the RENTRI portal or with a consultant.
- Who decides whether to use a paper or digital FIR? The decision rests with the producer or holder of the waste who issues the form, and it binds the entire chain. If the digital format is chosen, the carrier and recipient must also manage that shipment digitally; if paper is chosen, the whole chain remains paper-based. The two formats cannot be mixed for the same shipment, so it is advisable to agree in advance with your partners.
- What is required to sign and transmit the digital FIR? SPID, CIE or CNS are required to access the RENTRI operator area. A qualified electronic signature is required to sign digital forms. Data can be completed and transmitted through the portal's free services, suitable for companies with few movements, or through API-connected management software, which is more convenient for high volumes.
