Third Sector entities are required to verify, on an annual basis, the accuracy of the data recorded in the Single National Register of the Third Sector (RUNTS) regarding their membership base and the entity’s operational components. This requirement specifically concerns the number of members, volunteers, and employees or quasi-subordinate workers, which must be communicated to RUNTS by June 30, should such data have changed compared to the situation already present in the Register as of December 31 of the previous year.
Decree of the Ministry of Labour and Social Policies No. 2 of January 13, 2026, published in the Official Gazette No. 66 of March 20, 2026, which entered into force on April 4, 2026, modified the management rules of RUNTS, extending the information obligation to all registered ETS. The previous regulations already provided for specific communication obligations for Odv (Volunteer Organizations) and Aps (Social Promotion Associations). With the 2026 ministerial intervention, the requirement is brought under a unified logic, applicable to all entities registered in RUNTS, regardless of their specific section.
Data to be communicated to RUNTS
The update concerns the total number of individuals making up the membership and operational base of the entity. In particular, data relating to members or associates with voting rights must be communicated, distinguishing between natural persons and member entities. For the latter, it must be specified whether they are registered in the same section of RUNTS. Furthermore, employees and quasi-subordinate workers with an active insurance position, volunteers registered in the entity’s internal register, and volunteers belonging to other entities with which the association collaborates or whose services it utilizes must also be indicated. The communication is of more than merely formal significance, as the legal representative of the entity, or the person delegated to transmit the filing, is responsible for the completeness and truthfulness of the information provided to the Register.
Annual deadline and grounds for variation
The ordinary deadline for the update is set for June 30 of each year, with reference to the situation existing as of the preceding December 31. However, the requirement should not be understood as an automatic communication to be carried out every year in all cases. The obligation arises only if, compared to the last communication made and the data already present in RUNTS, changes have occurred in the number of members, volunteers, or workers. In the absence of changes, the entity is not required to submit a new update filing.
Newly registered and already registered ETS
Third Sector Entities submitting an application for registration in RUNTS after April 4, 2026, the date of entry into force of Ministerial Decree No. 2 of January 13, 2026, are required to provide the requested information at the time of registration.
Regarding entities other than APS and ODV already registered as of April 4, 2026, which have never previously communicated such data, it is advisable that they proceed with the relevant communication to RUNTS by June 30, 2026, to allow for the initial acquisition of said information.
Reduction of the membership base below minimum limits
Particular attention must be paid by Odv and Aps, for which the Third Sector Code requires compliance with minimum thresholds for the composition of the membership base. Should the number of members fall below the minimum limit provided—equal to seven natural persons or three member entities—the relevant communication to RUNTS must be made within thirty days. In such a case, the entity has one year to restore the requirement. Failing this, the competent Office may initiate the procedure for cancellation from the Register, with significant consequences for the retention of ETS status and the possibility of continuing to benefit from the related legal regime.
Procedures for transmitting the filing
The communication must be transmitted exclusively electronically to the territorially competent RUNTS Office, identified on a regional or provincial basis. Access to the platform is via the national portal, using the digital identity of the legal representative or the delegated person. Once the relevant entity has been selected using the tax code, a variation filing must be started and the fields required by the guided procedure must be completed.
Upon completion, the system generates the request form, which must be downloaded, signed, and subsequently re-uploaded to the platform. The conclusion of the procedure is confirmed by the sending of a PEC (certified email) communication confirming that the update has taken place.
The new deadline for filing financial statements
The Ministerial Decree of January 13, 2026, also intervened regarding the deadline for filing the annual financial statements of ETS. The deadline is no longer identified as the fixed date of June 30, but as the flexible deadline of one hundred and eighty days from the close of the financial year, in coordination with Art. 48, paragraph 3, of Legislative Decree no. 117/2017. For entities with a financial year coinciding with the calendar year, the deadline will therefore continue, in practice, to ordinarily fall by the end of June. For entities with a financial year not coinciding with the calendar year, however, the deadline must be calculated in relation to the specific closing date of the financial year. For ETS established in the form of a foundation, the approval resolution must also be filed in addition to the financial statements. Furthermore, where a control body or auditor has been appointed, their respective reports must also be filed.