On October 17, 2025, the Ministry of Economy and Finance opened a public consultation on the Ministry of Economy and Finance's National Plan for the Social Economy, to which we responded with the following considerations.
As rightly underlined at the beginning of subsection D.1, it is necessary to ensure that the social economy easier access to sources of financing; however, with regard to the consequent desire to develop "“new financial instruments and mechanisms” (art. 94 of the Plan), we believe it is appropriate to recall the truly “revolutionary” step taken by the legislator in the legislative decree 117/2017 (Third Sector Code) where, in art. 77, it introduced the concept of solidarity bonds which useful tools to "“promote the financing and support of the activities referred to in Article 5 carried out by third sector entities registered in the Register”. These titles:
- on the one hand, they could be made operational by proceeding with the necessary dialogue with the European Commission; and
- on the other hand, they can be an inspiration for the definition of forms of access to even simpler economic resources, such as products of “social impact” deposit”, as experimented by our Foundation since 2016, and which have already seen the realisation of two projects (Lights in the Park and Common House) and are starting the third project (STAGE).
With this type of banking product that is safe (because it is protected by the Interbank Deposit Protection Fund) and easy to understand for most people, it would therefore be possible to go to encourage the desired (art. 97) investment also by natural persons “stimulating the attitude towards patient and impactful investments”.
Moreover, the approach that our Foundation has borrowed from social impact investing, more solidly spread in other countries, provides for an intervention not in the capital/assets of the subjects of the social economy, but the financing of a specific and clearly identified project, promoted by a third sector organization, thus strengthening both the beneficiary organization's commitment to the implementation of the planned project interventions and the signatory's connection to a clear and tangible project, as well as stimulating a sort of social entrepreneurship on the part of the beneficiary organization itself.
The aforementioned tangibility becomes even more concrete if we consider that this investment method has as its core there valorization of public real estate assets, to which the Plan dedicates attention in subsection D4, and which is, and has been, the object of our interest through the regeneration of a former orphanage owned by the Tuscany Region, in the Luci nel Parco project, and of a property confiscated from the Camorra, available to the Municipal Administration of Naples, in the Casa Comune project.
We also believe that the so-called solidarity bonds with their possible declinations would also respond to what is stated in article 101 of the Plan, regarding the matching fund, which could also see philanthropic institutions and banking foundations among the subscribers of impact banking products, in a logic win-win of an investment that, at the same time, guarantees a return and finances a project.
We therefore hope that a real finance of this type become systemic and integrated with the banks' sustainability policies, which, precisely in the exercise of their typical activity (that of collection), could give concrete form to the ESG commitment required of them also by European directives. Consequently, we allow ourselves to hope not so much for the identification of a "“dedicated and specialized financial entity”, but rather the diffusion within the banking system of innovative, yet simple, forms of support for social economy projects. Moreover, referring to a particularly current issue, this could also be implemented principle of "restitution" to the community which has been much debated in recent hours, for example through a mechanism of advantageous interest rates or additional loans from the bank, in favor of the specific project, in relation to the collection made.
Finally, we would like to express our doubts about the social rating theorized in art. 98 which, at present, could go to further tighten the relationship between finance and the third sector, and which, in our opinion, should be preceded by a strong strengthening of a multitude of entities that, although small and not always structured, ensure the performance of important and necessary functions, especially at the local level. Furthermore, the rating would risk slowing down the entire process of disseminating products inspired by solidarity bonds, opening a theoretical debate on how to set up the rating itself: this has already happened with the measurement of social impact, which is still undefined but has become the constituent activity of ETSs that have never actually implemented a social impact project.
