Compulsory digital FIR from 16 September 2026: what really changes for businesses and carriers

From 16 September 2026, what changes for the FIR?

From 16 September 2026 the digital FIR becomes compulsory for operators registered with RENTRI.

Until 15 September 2026, under Law No. 26 of 27 February 2026, registered operators may still choose between the paper form and the digital FIR. From the following day this option ends.

The practical rule is therefore this: if the producer/holder is registered with RENTRI, from 16 September it issues the FIR in digital format; if the producer is not subject to registration, it continues to use the paper FIR; the method required of the producer/holder determines how the whole chain is managed, because the carrier and the recipient must use the same format.

This distinction is essential because from 16 September the paper FIR does not disappear completely: it remains in use for producers that are not registered with RENTRI and in the specific emergency situations provided for by the legislation.

Why 16 September 2026 is an important date

The path towards the digital FIR should have been consolidated in the preceding months, but in 2026 the legislator introduced a transitional period.

Article 13 of Decree-Law No. 200 of 31 December 2025, converted by Law No. 26 of 27 February 2026, allowed operators to continue issuing the paper FIR as an alternative to the digital one until 15 September 2026.

During this period the choice is up to the producer/holder: if the FIR is created digitally, the whole chain manages it digitally; if it is created on paper, it remains on paper for the entire movement.

From 16 September 2026, however, the digital FIR becomes the compulsory method for operators registered with RENTRI.

Who must use the digital FIR from 16 September?

The simplest answer is: operators registered with RENTRI must be able to manage the digital FIR.

For the registered producer/holder, the FIR relating to the movement is issued digitally.

The flow then involves the other parties: producer/holder, one or more carriers, recipient and any broker, where present.

When the transport starts, the digital FIR must contain the prescribed data and must be signed digitally by the producer/holder and the carrier. The recipient signs it digitally when it takes charge of the waste or rejects it.

Who continues to use the paper FIR instead?

Producers that are not required to register with RENTRI continue to use the paper form.

The RENTRI portal in fact provides a specific area called “Producers of waste not registered”, from which these parties can produce and validate the paper FIR compliant with the new template. Ministerial Decree No. 59 of 4 April 2023 provides that producers that are not registered keep the FIR on paper.

So a carrier registered with RENTRI will not always use the digital FIR: if it collects the waste from a producer that is not registered and must issue a paper FIR, the whole chain handles that movement on paper. The carrier must therefore be organised to manage both digital and paper FIR notes, depending on the position of the producer/holder.

Before and after 16 September 2026

Producer registered with RENTRI: until 15 September it may choose a paper or a digital FIR; from 16 September the digital FIR is compulsory.

Producer not registered: remains on the paper FIR both before and after 16 September.

Carrier and recipient: they follow the format chosen by the producer until 15 September and, from 16 September, the format required of the producer.

This scheme avoids a common mistake: thinking that from 16 September all waste transports must necessarily take place with a digital FIR. That is not the case: the position of the producer/holder remains decisive.

How the digital FIR works in practice

The digital FIR, often referred to in the RENTRI procedures also as xFIR, is built up progressively by the parties involved in the movement.

1. Issuance and completion: before the transport starts, the FIR may be issued and completed by the producer/holder or by the carrier, at the request of the producer/holder. It must contain, among other things: the details of the producer/holder, the recipient, the carrier or carriers, any broker, the characteristics of the waste, the date and time the transport starts, the driver's first and last name and the vehicle registration plate.

2. Signature at departure: when the transport starts, the FIR must be signed digitally by the producer/holder and the carrier. This is not an IT formality: the relevant data of the movement must be checked before signing.

3. Transport: the FIR remains digital during the journey. Simply printing it does not turn a digital FIR into a paper one in ordinary operations. Specific procedures exist for cases of unavailability (Directorial Decree No. 25 of 5 February 2026).

4. Arrival at the facility: the recipient completes the information within its own remit and signs the FIR digitally when it takes charge of the waste or rejects it. Partial acceptance is also handled within the same digital flow.

5. Return of the completed copy: the recipient returns the completed copy of the digital FIR through RENTRI to all the parties involved, within two working days of taking charge, both for hazardous and for non-hazardous waste. The parties must download it within 90 days of the return.

The digital FIR and data transmission to RENTRI are not the same thing

No. Managing the form in digital format is one thing; transmitting the data it contains to RENTRI is another.

For digital FIR notes relating to hazardous waste, the obligation to transmit the data applies in the manner applicable to the parties concerned.

It is not correct to say generically that every digital FIR must be transmitted in the same way: the procedure must be read taking into account the type of waste, the party involved and the specific transmission obligation.

What changes for a business that produces waste

For a business registered with RENTRI the main change is organisational. Before 16 September it must be clear: who prepares the FIR, who checks the data, who signs digitally, which system is used, who steps in if there is an error, how emergencies are handled and how the return of the completed copy is verified.

Thinking that the problem is solved simply by having SPID or by accessing the portal is not enough: the FIR involves the office, operational staff, the carrier and the recipient.

What changes for carriers

For a business that transports waste the situation is more delicate, because it will have to handle two scenarios.

Scenario A, producer registered with RENTRI: the FIR is digital and the carrier must receive it or take part in completing it, add the data within its own remit, check it, sign it digitally, manage it during transport and coordinate with the recipient.

Scenario B, producer not registered with RENTRI: the FIR is on paper and the carrier continues to handle the movement on paper.

A carrier that from 16 September can only use the digital FIR is therefore not really prepared: it must be able to recognise which regime applies to each collection.

What a business must check before 16 September

1. Check whether it is registered with RENTRI: the format must not be decided on the basis of the apparent size of the business or of a generic type, but by checking the operator's actual position.

2. Decide how to manage the digital FIR: RENTRI provides its own services and tools for interoperability with management software; the choice must be consistent with the number of movements and with the internal organisation.

3. Enable users correctly: it must be clear who can complete, amend, sign and consult the FIR and handle any anomalies.

4. Train operational staff: training only the people who work in administration is not enough; drivers and the staff handling handovers must know how to check the FIR, what to do if there is an error, whom to contact and what to do if the system becomes unavailable.

5. Check the flow with customers, carriers and facilities: digital management involves the whole chain; a perfect internal procedure can stall if an external party is not organised.

Practical case 1: a construction company registered with RENTRI

A construction company registered with RENTRI must hand over waste from a site. From 16 September the FIR must be issued digitally.

Before departure the following are entered: producer, place of production, waste, EWC code, quantity, carrier, recipient, vehicle and driver.

Producer and carrier sign digitally; the destination facility completes the form when it takes charge; the recipient then returns the completed copy through RENTRI.

Practical case 2: a small producer that is not registered

A small producer falling among the parties not required to register must dispose of waste. Even after 16 September it continues to issue the paper FIR using the new template provided by RENTRI.

The fact that the carrier and the facility are registered with RENTRI does not automatically make the form digital: the entire movement remains on paper.

What happens if RENTRI is not working?

From 16 September the digital FIR becomes compulsory for registered operators, but this does not mean that a technical outage must block a transport.

Directorial Decree No. 25 of 5 February 2026 governs the operating procedures in the event of unavailability of the RENTRI services, of temporary unavailability of the Internet connection and of unavailability of the digital authentication services, under the conditions provided for.

The procedures change according to when the problem arises: it is advisable to set up a specific company procedure and not to rely on the generic rule “if it does not work, we print the FIR”.

What happens to penalties from 15 September 2026?

Law No. 26/2026 provides that the penalties for failure to transmit, or incomplete transmission to RENTRI of, the data contained in FIR notes apply, on first application, from 15 September 2026.

Be careful not to turn this provision into a generic statement such as “from 15 September all the digital FIR penalties kick in”: the rule referred to specifically concerns the failure to transmit, or the incomplete transmission of, the data contained in the forms.

Other breaches relating to the FIR must be assessed on the basis of the specific case provided for by Legislative Decree 152/2006.

The most common mistakes to avoid

Thinking that from 16 September paper disappears: that is false, it remains for producers that are not registered and in the extraordinary cases provided for by the legislation.

Deciding the format on the basis of the carrier: the method starts from the producer/holder, it is not the carrier who chooses freely.

Confusing printing with the paper FIR: printing a digital FIR does not change, in ordinary conditions, the digital nature of the form.

Confusing the digital FIR with data transmission: they are connected but not identical obligations.

Not checking the completed copy: the movement is not administratively closed just because the lorry has unloaded; the return of the completed copy must also be verified.

Checklist before 16 September 2026

• We have checked whether the business is registered with RENTRI.
• We know whether our FIR notes will have to be digital.
• We have chosen between the RENTRI services and an interoperable management system.
• The users are enabled.
• We know who completes the FIR and who signs it.
• The drivers have been trained.
• We know how to handle customers that are not registered with RENTRI.
• We have a procedure for RENTRI unavailability.
• We know how to check the return of the completed copy.
• We have checked the obligations to transmit the data of FIR notes relating to hazardous waste.

From 16 September it is not only the document that changes

The real change is not moving from a sheet of paper to a screen. From 16 September businesses registered with RENTRI must manage a digital document flow involving several parties, while they may continue to receive or handle paper FIR notes when the producer is not registered.

Proper preparation means knowing: which format to use, who must complete it, who must sign it, which data to check, how to behave during transport, how to verify that the movement has been closed and what to do if RENTRI is unavailable. Those who clarify these procedures before 16 September greatly reduce the risk of operational errors.