Modello EAS for APS: when to file it and what you risk if you don't

Intro: the "invisible form" that could cost you €5,000 if you skip it

Many APS don't even know that Modello EAS exists. And yet, not filing it has concrete consequences: loss of tax benefits, fines of €250, and retroactive charges of up to €5,000 if it's discovered during an inspection.

Modello EAS is a telematic filing to the Agenzia delle Entrate (Italy's Revenue Agency) that tells them: "We are a non-commercial association, our members' fees are tax-exempt." It's the document that unlocks the tax exemption on the membership fees and contributions you receive from your members.

Without Modello EAS, technically, those fees could be treated as "income from services" (taxable). With Modello EAS, they're tax-exempt.

The problem? The deadline is very short: 60 days from incorporation. If your APS was founded on November 1, 2024, you had to file Modello EAS by December 31, 2024. If you missed it, you're already late (and need to catch up quickly).

This article walks you through it step by step: who has to file, when, how to fill it out, and what you risk.

What is Modello EAS?

EAS stands for Enti Associativi Sportivi ("Sport-related Associative Entities," a somewhat misleading name: in reality it covers all associations, not just sports ones).

It's a form you have to file electronically with the Agenzia delle Entrate to declare:
1. That you are a non-profit association
2. That your members' fees/contributions are tax-exempt
3. That you are claiming the tax exemption on institutional activities

Once filed, the Agenzia delle Entrate enters you in the official list of non-commercial associations. This allows you to:
- Avoid paying IRPEF (personal income tax) on membership fees received from members
- Avoid paying IRES (corporate income tax for APS) on revenue from institutional activities
- Access other benefits (IMU, local taxes, etc.)

Without Modello EAS, in theory you're not entitled to these exemptions.

Who has to send Modello EAS?

Not all APS. Check whether it applies to you:

Must send it:

1. New Associazioni di Promozione Sociale (APS): just founded, if not registered with the RUNTS (Registro Unico Nazionale Terzo Settore, Italy's national register of Third Sector entities)
2. Organizzazioni di Volontariato (ODV) not on the RUNTS
3. Cultural, recreational, amateur sports associations not on the RUNTS

Doesn't have to send it (exempt):

1. APS, ODV, ETS already registered with the RUNTS: the RUNTS communicates directly with the Agenzia delle Entrate, no Modello EAS needed
2. Amateur sports clubs registered with CONI: CONI communicates with the Agenzia delle Entrate
3. Pro-loco associations with prior tax-exempt status: they retain the exemption automatically
4. Public bodies: (municipalities, provinces, etc.)

Hybrid situation (pay attention):

If you're an APS that is about to register with the RUNTS, the situation is complicated:

- Phase 1 (before RUNTS registration): you must send Modello EAS within 60 days of incorporation (to get temporary exemptions)
- Phase 2 (after RUNTS registration): Modello EAS is no longer needed, the RUNTS replaces everything

Practical advice: if you've just been founded and plan to register with the RUNTS, send Modello EAS within the 60 days anyway. Then, once on the RUNTS, Modello EAS automatically lapses.

Timeline: critical deadlines

| Date | Event | What to do |
|------|--------|-----------|
| Day 0 | APS incorporation (notarial deed) | Keep the date |
| Day 60 | Modello EAS filing deadline (ordinary) | File it by tonight |
| Day 90 | End of the critical period | If you missed it, you can still catch up |
| Day 120+ | Late fee: €250 penalty + interest | Start paying |

Concrete example: APS OnStage founded on November 15, 2024. Modello EAS deadline: January 14, 2025. If not filed, you're late.

When you need to re-file Modello EAS

Besides the initial filing (60 days from incorporation), you must re-file Modello EAS if your data changes by March 31 of the following year.

Examples of changes that require re-filing:

Organizational changes

- Change of president or administrators
- Change of registered office
- Amendment to the statute (especially if it touches the non-profit clause)
- Change of corporate purpose (institutional activities)

Changes that don't require re-filing

- Change of email address
- Change of phone number
- Membership updates (unless they affect governance)

Procedure: amend Modello EAS from your Fisconline/Entratel account, entering the date of the change, and resubmit. The Agenzia delle Entrate updates your profile.

Deadline: March 31 of the year after the change. If the change happens in July 2026, you must re-file by March 31, 2027.

How to access the portal and fill it out

Step 1: Access Fisconline or Entratel

Modello EAS is filed via Fisconline (for those not otherwise registered) or Entratel (for professionals with advanced credentials).

Access:
- Fisconline: https://fisconline.agenziaentrate.gov.it (free online service)
- Entratel: https://www.entratel.it (legacy service, less used)
- Through a CAF/accountant: they have enabled access

If you don't have credentials:
1. Visit fisconline.agenziaentrate.gov.it
2. Click "Register"
3. Enter your APS's tax code (Codice Fiscale)
4. You'll receive a username and password by email
5. Log in and navigate to "Modello EAS"

Registration time: 15 minutes. Not complicated, but slow.

Step 2: Fill out Modello EAS

Once inside Fisconline, you'll find the EAS form with these sections:

Section 1: APS identification data
- Name: full name of the APS (e.g., "APS OnStage")
- Codice Fiscale: your tax code
- Date of incorporation: day/month/year of the notarial deed
- Registered office: full address, city, postal code

Section 2: Administrative data
- President: first name, last name, tax code, date of birth
- Secretary (if any): same
- Treasurer: same
- Names of other members of the governing body (board, council, etc.)
- For each person: phone number and email

Section 3: Compliance declarations
You must check:
- "The entity is established and operates without profit purpose" ✓
- "The activities carried out are of general interest" ✓
- "The statute provides for no distribution of profits to members" ✓
- "Membership fees/contributions are collected to cover costs, without profit" ✓

Section 4: Activity carried out
Enter a brief description of the activity. Examples:
- "Organization of cultural festivals and urban art workshops"
- "Training workshops and cultural research"
- "Promotion of freestyle culture, hip-hop and street art"

You don't need a ten-page essay. A 5-6 line sentence is enough.

Section 5: Attachments
Upload as PDF:
- A copy of the statute (founding document)
- The notarial deed of incorporation (or an excerpt copy)
- The president's ID document
- (Optional) 2024 financial statement, if you have one (not necessary for newly founded APS)

Step 3: Submit and keep the receipt

Once everything is filled in, the system will show you a summary. Check the data (this is your last chance to correct it).

Click "Invia" ("Submit").

The system will give you a protocol number (e.g., "PEC/2026/123456"). Print or screenshot this number: it's your proof of filing. Keep it for 5 years.

Processing time: the Agenzia delle Entrate usually processes Modello EAS within 10 business days. You'll get an email (at the address you provided for the APS) confirming acceptance.

What happens after filing?

If everything is OK (best-case scenario)

Within 10 days, you'll get an email: "Modello EAS accepted. The entity [your name] has been entered in the list of non-commercial associations, effective [date]."

From that moment on:
- Membership fees received from members are tax-exempt
- Revenue from institutional activities is tax-exempt (or follows the Art. 79 regime, see previous article)
- You can apply for IMU/TASI benefits (local property tax) if you own real estate

If the Agenzia delle Entrate asks for additional documents

You'll get an email: "Documentation incomplete. Provide within 30 days: [list]."

Upload the missing documents in the Fisconline portal.

Time: another 10 days of processing.

If Modello EAS is rejected

A rare, but possible scenario. The Agenzia delle Entrate writes to you: "Your Modello EAS has been rejected because: [reason]."

Common reasons:
- The statute is not clear about the absence of profit purpose
- Attached documents are corrupted or unreadable
- Inconsistent data between the statute and the declarations

Remedy: fix the document (e.g., update the statute), resubmit Modello EAS.

It's not a failure, it's a natural cycle.

What you risk if you DON'T send Modello EAS

Let's be blunt about the risks. They're real.

Risk 1: Loss of tax benefits (immediate)

If you don't send Modello EAS, technically you have no right to the tax exemptions on membership fees.

Scenario:
- You receive €5,000 in membership fees from 100 members in 2025
- Without Modello EAS, those €5,000 could be treated as "income from services" (taxable)
- You get a discount: IRES for APS is 12%, so €5,000 × 12% = €600 in tax owed

In reality, nothing happens right away. But if the Agenzia delle Entrate inspects you, it will find out.

Risk 2: Administrative penalty (within 120 days)

If you go beyond 120 days without filing Modello EAS, the Agenzia delle Entrate sends you a notice of irregularity and applies a €250 penalty.

It's not much, but it's a warning sign.

How to avoid it: file Modello EAS within 60 days. If you missed it, act now. The penalty only kicks in after 120 days.

Risk 3: Retroactive taxation over the preceding 5 years (upon inspection)

Worst-case scenario: the Agenzia delle Entrate inspects you in 2027 and discovers that since 2024 you've never filed Modello EAS.

They could:
1. Retroactively tax membership fees for 2024, 2025, 2026 (3 years of arrears)
2. Apply a penalty of 100% to 200% of the amount owed (example: €600 in taxes × 150% penalty = €900 extra)
3. Add statutory interest (currently 2.5% per year)

Total potential: fees €5,000 × 12% IRES × 3 years = €1,800 in taxes. Plus penalties €1,800 × 150% = €2,700. Total: €4,500.

That's a big number for a small APS.

Risk 4: Denial of the 5x1000 registration

When you register for the 5x1000 (see article 1), the Agenzia delle Entrate checks that you have an active Modello EAS. If you don't, it could deny your 5x1000 registration (lost value: €3,000-7,000 a year).

The connection isn't obvious, but it exists in practice.

How to catch up (if you're late)

If your APS should have sent Modello EAS but didn't, here's what to do now:

Step 1: Access Fisconline and fill out Modello EAS

As described above. Fill everything out carefully.

Step 2: In the "Notes" section, explain the delay

When you upload Modello EAS, there's a "Notes" or "Remarks" section. Write:

> "Modello EAS filed late. Filing was due by [original date]. The delay is due to [reason: change of accountant, administrative disorganization, etc.]. The entity remains non-commercial, as per its statute."

It's not an excuse, it's an explicit statement that you are aware of the delay.

Step 3: If you're past 120 days, pay the penalty

If more than 120 days have passed since you should have filed Modello EAS:

1. Pay the €250 penalty via F24 Elide (the electronic AAMS payment form)
- Reason: "Penale tardiva Modello EAS" ("Late penalty, Modello EAS")
- Tax code: 8110 (penalty on forms)
2. Attach the F24 receipt to the Modello EAS you submit

Important: paying the penalty doesn't cancel the obligation to file Modello EAS, it's just the fine for being late.

Step 4: Keep your documentation

Keep:
- Screenshot of your Fisconline registration
- Confirmation email for the Modello EAS filing
- F24 receipt (if you paid it)
- Protocol number

For 5 years.

Box: Changes and re-filings (practical overview)

If your APS is already in order with Modello EAS, but your data changes, here's the workflow:

Example: president Mario Rossi (who was named in the 2024 Modello EAS) steps down. A new president arrives: Francesca Bianchi. What do you do?

1. Update the statute (if necessary): the assembly resolves on the new president
2. Access Fisconline: look for the "Modello EAS" section
3. Click "Invia variazione" ("Submit change") (not "new form")
4. Enter the date of the change: date of the assembly resolution (e.g., March 15, 2026)
5. Update the data: new president's name, tax code, contact details
6. Upload a copy of the assembly resolution: as a PDF attachment
7. Submit

Deadline: by March 31, 2027 (by March of the year after the change).

If you forget, the same procedure as before applies: up to 120 days you're fine, then the penalty kicks in.

Box: Simplified EAS for some APS

There are categories of APS that can use a simplified procedure for Modello EAS:

- Small Associazioni di Promozione Sociale (fewer than 50 members, budget under €10,000)
- Local amateur sports associations (minor football, volleyball, etc.)
- Rural Organizzazioni di Volontariato

Not every accountant knows this, but if you're a micro-APS, you might be entitled to a "streamlined" form that doesn't require a financial statement.

Ask your CAF: "Are we entitled to the simplified Modello EAS?"

Case study: APS OnStage catches up on Modello EAS

APS OnStage was founded on November 15, 2024. It should have filed Modello EAS by January 14, 2025. But over the winter, no one remembered.

In April 2026 (5 months after the deadline), they realize: "Wait, we never sent Modello EAS!"

What happens:
1. 168 days have passed since the deadline (January 14). They've gone past the 120-day tolerance.
2. They access Fisconline, fill out the late Modello EAS (everything is still valid: statute, president, offices)
3. In the notes section they write: "Late filing. Founded November 15, 2024, due by January 14, 2025. The delay is due to administrative disorganization. Late filing submitted April 20, 2026."
4. They pay the €250 penalty via F24
5. They send everything together (Modello EAS + F24 receipt)

Result:
- Modello EAS accepted (even though late)
- €250 penalty paid
- From May 2026 onward: tax benefits active (membership fees tax-exempt)
- Retroactivity: the Agenzia delle Entrate probably won't retax the 2024-2025 fees, given the long delay (they showed good faith)

If they hadn't sorted it out by 2026:
- 2027: an inspection finds Modello EAS missing for 3 years
- 2024-2025 retaxation: ~€1,800 in taxes + €2,700 penalty = €4,500

Lesson: the cost of "getting it in order" now is €250. The cost of "hiding it" is €4,500 two years from now.

CTA: send Modello EAS by May 2026

If your APS was founded in 2024 or 2025 and hasn't sent Modello EAS, do this now:

1. Go to fisconline.agenziaentrate.gov.it: register (5 minutes)
2. Fill out Modello EAS: 15 minutes
3. Upload documents: statute, notarial deed, photo of president's ID (5 minutes)
4. Submit: keep the protocol number (2 minutes)
5. If you're late (over 120 days): pay the €250 penalty via F24 (10 minutes)

Total time: 40 minutes. Cost: €0 (if on time) or €250 (if late).

ROI: you avoid future retroactive taxation of €4,500+.

If your accountant says "it's not important," find a better accountant. Modello EAS is a legal requirement.

Disclaimer

This article is informational and is based on Agenzia delle Entrate regulations as of May 2026. The procedure may change with updates to the Fisconline portal.

This is not formal tax advice. If your APS has a complicated situation (a contested statute, mixed commercial/non-commercial activities, etc.), consult a CAF or accountant before filing Modello EAS.

If you receive a notice of dispute or a request for additional documents from the Agenzia delle Entrate, turn to a specialized firm (not your generic accountant, who may not know the procedure).

Regulatory sources:
- Agenzia delle Entrate — Modello EAS information page
- Agenzia delle Entrate — Modello EAS instructions
- TUIR (Testo Unico IRPEF, Italy's consolidated income tax code) — Art. 4, paragraphs 4 to 10

Further reading:
- CAF ACLI — Modello EAS 2026
- Cantiere Terzo Settore — Modello EAS operational guide

Internal links in the APS Taxation series:
1. [5x1000 for APS: registering on the 2026 list](/blog/5x1000-aps-iscrizione-elenco-2026-procedura-agenzia-entrate)
2. [Donations to APS: the 19% deduction](/blog/erogazioni-liberali-aps-detrazione-19-percento-deducibilita)
3. [ETS tax regime: decommercialization](/blog/regime-fiscale-ets-decommercializzazione-art-79-cts-cosa-cambia)
4. Modello EAS for APS (this article)
5. [VAT and the Third Sector: exemptions in 2026](/blog/iva-terzo-settore-aps-quando-applicarla-esenzioni-2026)