Temporary degradation of the RENTRI services: what to do with the digital FIR

What temporary degradation of the RENTRI services is

Directorial Decree No. 254/2026 defines temporary degradation as a condition in which, during the service availability hours, one or more RENTRI functions needed to manage the digital FIR are degraded, limited or not fully operational, to the point of preventing the operator's activity from continuing.

So it is not necessarily a system that is completely “switched off”.

It is a situation intermediate between full operation and the complete or serious unavailability already governed by Directorial Decree No. 319 of 30 October 2025 and by Directorial Decree No. 25 of 5 February 2026.

How can I show that this is RENTRI degradation?

The degradation must be accompanied by evidence generated by the RENTRI system: specific response codes or messages returned by the endpoints of the interoperability services, or error messages displayed in the Area Operatori or in the RENTRI FIR Digitale mobile app.

This evidence matters because it will have to accompany the declaration required by the decree. A mere slowdown perceived by the user, with no evidence attributable to the RENTRI services, is not enough to apply the procedure automatically.

When Directorial Decree 254/2026 does not apply

The procedure on temporary degradation does not apply:

• to ordinary or extraordinary maintenance work;
• to situations amounting to complete or serious unavailability of the RENTRI services governed by the earlier decrees;
• to problems exclusively internal to the company organisation that do not depend on degradation of the RENTRI services.

Connectivity and authentication: this is not RENTRI degradation

An important distinction must be drawn. Directorial Decree No. 25/2026 also governs specific cases of temporary unavailability of the Internet connection or of the digital authentication services used by the operator, when the problem arises from causes outside the operator's control and not from negligence or poor maintenance.

So a connection or authentication problem must not automatically be treated as “RENTRI degradation”: it must be referred to the correct procedure.

Why Directorial Decree 254/2026 is a derogation

Normally the format of the FIR chosen by the producer or holder at the outset determines how it is managed along the chain.

Directorial Decree 254/2026 introduces a derogation limited to the individual FIR, to the degradation situation and to the stage at which the operator cannot use the RENTRI services.

The procedure therefore does not authorise a business to choose paper freely whenever the system appears slow: the condition of degradation laid down by the decree must exist and the documentary procedures provided for must be followed.

If the FIR moves to paper, does it go back to digital when RENTRI resumes?

No. If during the degradation a given FIR is lawfully managed in paper form under Directorial Decree 254/2026, that movement continues under the paper regime until the cycle of the individual FIR is closed.

The mere restoration of the RENTRI services does not turn that consignment note back into a digital FIR.

For subsequent movements, however, once the degradation has ended you return to the normal operating methods.

Scenario 1 — I cannot complete, issue or sign the digital FIR

If the degradation prevents the digital FIR from being completed, issued or signed. This is one of the three cases expressly identified by the new decree; operationally:

• a stamped paper FIR is used;
• the consignment note is managed under Article 6 of Ministerial Decree 59/2023;
• in the annotations field the wording required by Directorial Decree 254/2026 is entered (the wording is to be entered in Italian, as laid down by the procedure): “FIR emesso in modalità cartacea ai sensi di quanto previsto dall'Allegato 1 al decreto direttoriale n. 254 del 9 settembre 2026”;
• the completed copy is returned according to the rules of the paper FIR;
• the ordinary obligations to transmit the data to RENTRI do not apply to that FIR;
• the operator completes the declaration provided for in Annex 1 and sends it by PEC within the prescribed deadline.

Scenario 2 — The FIR is digital but I cannot update it during transport

It may happen that the FIR has already been correctly issued in digital format, but during transport the RENTRI degradation prevents a necessary update: transhipment, technical stop, change or another event requiring the FIR to be updated. In this case the carrier:

• uses the printout of the digital FIR;
• adds the necessary data on the printout;
• adds the date and a handwritten signature;
• states in the annotations the wording required by the decree (to be entered in Italian, as laid down by the procedure): “FIR gestito in modalità cartacea ai sensi di quanto previsto dall'Allegato 1 al decreto direttoriale n. 254 del 9 settembre 2026”;
• from that moment manages that FIR under the paper regime;
• arranges the notification of the change of format;
• completes and sends the declaration required.
• The ordinary obligations to transmit the FIR data to RENTRI do not apply to that consignment note.

Scenario 3 — The recipient cannot update the FIR on acceptance

The problem may also arise when the vehicle has already reached the facility. If the recipient cannot complete its own stage digitally because of the RENTRI degradation:

• adds the data within its own remit on the printout of the digital FIR;
• adds the date and a handwritten signature;
• enters the wording required;
• the FIR continues under the paper regime;
• the notification of the change of format is made;
• the declaration is completed and transmitted.
• In this scenario too, the ordinary obligations to transmit the data of that FIR to RENTRI do not apply.

Careful: printing a digital FIR does not mean turning it into a paper FIR

This point is essential. Under ordinary conditions, the printout of the digital FIR is only a representation of the digital document.

The printout does not automatically become a paper FIR just because it is produced on paper.

The move to the paper regime takes place exclusively in the cases and in the ways provided for by the emergency procedures, including Directorial Decree 254/2026.

Must I always have the printout of the digital FIR on board?

Article 7(4) of Ministerial Decree 59/2023 provides that during transport the digital FIR may be accompanied by its printout or shown on a mobile device in the prescribed ways.

For the purposes of managing emergencies, however, having the printout physically available is strongly advisable. Indeed, if a degradation occurs during the journey and it becomes necessary to move to the paper procedure, the printout is the document on which the carrier can add the data and put a handwritten signature.

For this reason, from an operational point of view, it is prudent not to rely exclusively on viewing it on a smartphone.

Should you keep stamped blank paper FIRs?

Yes. The new decree suggests that operators should keep in advance a number of stamped blank paper forms proportionate to their needs, so as to be able to react immediately in the event of degradation.

This is not about turning paper into the ordinary method: it is a preventive measure to avoid finding yourself without a usable tool at the moment when the digital FIR cannot be issued.

The declaration to be sent by PEC

The operator who has applied the measures of Directorial Decree 254/2026 must complete and sign the declaration provided for in the Appendix to Annex 1. The declaration must be sent by PEC to dit.rentri@pec.it by the first working day following the end of the degradation condition.

At least one piece of evidence of the degradation must be attached to the declaration.

The communications may be subject to subsequent checks and inspections, and the operator must be able to demonstrate the correspondence between the degradation reported, the RENTRI evidence, the declaration, the FIR concerned and the paper procedure adopted.

Notification of the change of format

Directorial Decree 254/2026 also amends the earlier procedures of Directorial Decree 25/2026. When a FIR that started as digital is subsequently managed in paper form, the change of format must be notified to the producer or holder through the RENTRI services provided: the RENTRI services for returning the copy of the paper FIR, or the specific service available in the Area Operatori or through interoperability.

The notification must be made once the ability to use the services has been restored and in any event promptly.

What NOT to do

• Do not use Directorial Decree 254/2026 simply because the portal appears slow.
• Do not apply it during maintenance.
• Do not confuse degradation with complete or serious unavailability.
• Do not automatically attribute to RENTRI degradation problems that are exclusively internal to the company.
• Do not turn an ordinary printout of the digital FIR into a paper FIR without the conditions provided for being met.
• Do not forget the declaration and the evidence.
• Do not continue to consider the ordinary obligation to transmit the FIR data applicable when that consignment note has been managed under the specific emergency procedure.