Within two years, between 2023 and 2025, tax disputes up to 5,000 euros decided at first instance by the single judge increased by 30.5% (from 79,785 to 104,120). This is not only a sign of a judicial system that, in the lower value range of disputes, has learned to speed up. The decisions of the single judge also show another effect: only 10.2% of his rulings are appealed, less than half compared to 22.1% of collegial ones. The single judge, therefore, not only ensures a driving force for closing files. He closes them, in the vast majority of cases, guaranteeing their durability. This is evidenced by the numbers contained in the analysis by the Tax Justice department led by Fiorenzo Sirianni (recently reconfirmed by the Government for another three years) on the new institutions of the tax process introduced with the reform measures of the litigation.
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Numbers that explain the Executive’s choice with the Pnrr decree at the beginning of the year (Dl 19/2026) to strengthen its jurisdiction, doubling from 5,000 to 10,000 euros the threshold for appeals notified since May 2.
The trajectory, however, begins in 2023. Within six months there is an increase in the threshold: initially set at 3,000 euros for appeals notified from January 1 (an intervention contained in law 130/2022 reforming justice and tax processes), then raised to 5,000 euros by Dl 13 with reference to those notified from July 1 of the same year. Now Dl 19/2026 completes the new jump to 10,000 euros. In practice, in three years the jurisdiction of the single judge has more than tripled.
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The impact has strengthened the trajectory in this direction, under the guidance of Deputy Minister of Economy Maurizio Leo. On the timing front, the advantage is tangible, though not overwhelming. In 2025 a case up to 5,000 euros decided by the single judge lasted on average 290 days, compared to 297 for a collegial decision above that threshold. The gap is clearer in the timing of the ruling deposit: 30 days for the single judge versus 41 for the collegial.
The real difference is measured, however, in the durability of the sentences. “Analyzing the 2025 data, it emerges that at first instance – explains the Tax Justice department – the percentage of appeals against single judge rulings valued up to 5,000 euros – equal to 10.2% – is lower than that recorded for rulings issued collegially, equal to 22.1%.”
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