Corporate e-bikes and welfare: let's set the record straight

Interview by Paolo Barbato with Silvia Spattini.

In recent months, ruling no. 41/2026 by the Italian Revenue Agency on the tax treatment of corporate e-bikes has sparked a heated debate. The subject is technical, the nuances are many, and it is no surprise that different readings of a document that is actually quite clear in its content have spread. The risk, however, is that Mobility Managers and HR leaders make decisions based on incomplete information.

To bring some clarity, I asked Silvia Spattini to analyse the key points of the ruling together. Silvia is one of the most authoritative voices in Italy on corporate welfare: senior researcher at ADAPT, adjunct lecturer in Labour Law at the University of Modena and Reggio Emilia and member of the AIWA Study Centre. Her analysis of the ruling, published shortly after the document was released, offers a particularly useful guide.

Mixed use or personal use: the fundamental distinction

The first source of confusion concerns the very nature of the asset. For company cars, the concept of mixed use exists: the vehicle is assigned to the employee for both work and personal purposes, and the tax treatment follows specific rules linked to conventional mileage. Many have applied the same framework by analogy to e-bikes. But the ruling says otherwise.

“The Revenue Agency clearly distinguishes personal use from mixed use. If the bicycle is used for the home-to-work commute, that is considered personal use, not use for work purposes: it takes place outside working hours and does not relate to the performance of work duties. Mixed use would only apply if the e-bike were also used for internal trips within the facility or for work-related activities,” Spattini explains.

The practical consequence is significant. E-bikes made available to employees for personal use do not follow the company car tax regime. Instead, they fall under the category of goods and services with a social utility purpose, governed by Article 51, paragraph 2, letter f) of the TUIR (Italian tax code), which refers to Article 100. An entirely different classification, with equally different operational implications.

The principle of employee non-involvement

A second aspect that the Revenue Agency firmly reiterates concerns how the benefit is provided. To qualify for favourable tax treatment, the service or good must be defined and agreed upon between the employer and the supplier. The employee benefits from it but does not participate in defining the service itself.

“This is one of the fundamental principles for the Agency: when services are made available, the employee must always remain uninvolved. The company agrees on the service with the supplier and pays for it. The worker must remain extraneous to the definition of the service, because otherwise the customisation becomes a circumvention of the rule: it is as if a sort of disguised income were being recognised,” Spattini clarifies.

In operational terms, this means the company enters into an agreement with a leasing or rental provider, defines the catalogue of available goods and makes them available to the employee population. The individual worker does not choose a specific model or negotiate particular conditions. Letter f) of Article 51 is broad and covers education, instruction, recreation, social and health assistance services. Sustainable mobility falls within it through the concept of social utility, as confirmed by at least three rulings by the Revenue Agency.

Monitoring: necessary or not?

A point that has fuelled particular confusion concerns monitoring the use of e-bikes. Some commentators have suggested that the company must verify that employees actually use the bicycle for at least 30% of their home-to-work commutes. The ruling, in reality, reports this information as an element described by the requesting company, not as a requirement set by the Agency.

“The conditionality on usage may exist for the company’s own purposes, but it is not relevant for tax purposes. The Revenue Agency does not require monitoring of the actual use of the good to grant the exemption. The good is made available and the worker can decide whether or not to use it,” Spattini specifies.

The distinction is subtle but substantial. A Mobility Manager might want to promote the use of e-bikes for commuting through nudging and awareness activities. This is perfectly legitimate and consistent with their mandate. But it is not necessary to build a monitoring system for tax purposes, and doing so could generate unnecessary complexity and risks regarding employee privacy.

Homogeneous categories: a bridge between welfare and mobility management

The conversation with Silvia Spattini brought out a particularly interesting aspect that directly connects the world of welfare to that of mobility management: the definition of homogeneous employee categories.

Welfare legislation provides that subsidised goods and services can be provided to the entire workforce or to homogeneous categories. This apparently technical concept opens up a space for joint work between the Mobility Manager and human resources that is rarely explored today.

The concrete question is: can the group of employees who live within a distance from the workplace compatible with bicycle use be defined as a homogeneous category?

“In principle, yes. There are already examples in collective bargaining where certain allowances or services are granted based on distance or workplace location. If workers at the Maranello site enjoy a certain welfare credit and those at the Cagliari site have free parking, objective criteria linked to location are being applied. The same reasoning could apply to the origin of the commute,” Spattini reasons.

The only caveat concerns numbers: the criteria adopted must not effectively restrict the benefit to very few employees, because in that case the Revenue Agency could challenge it as a targeted advantage rather than a measure aimed at a category. But in most corporate contexts, the analysis of the cyclable catchment area — an activity that the Mobility Manager already conducts or should conduct — produces segments of adequate size.

Here a natural convergence emerges. The Mobility Manager analyses employee mobility demand, segments the population by distance and mode of transport, identifies the catchment areas for each alternative to the private car. This same information can support the construction of homogeneous categories for the provision of targeted benefits, such as e-bikes. This is what in mobility management is called positive discrimination: allocating resources where they can generate the greatest benefit for both the worker and the company.

Welfare and mobility: two worlds that need to talk

What emerges from the conversation with Silvia Spattini goes beyond the single tax question of e-bikes. It is about recognising that mobility and corporate welfare are two sides of the same coin, and that the professionals who deal with them would have much to gain from working together.

The Mobility Manager knows the commuting patterns of the corporate population, knows where employees live, what modal alternatives are available and what infrastructure would be needed to enable them. The welfare specialist knows the tax mechanisms, the conditions for provision, and the ways to structure plans in a compliant and effective manner.

The problem is that today these two roles rarely communicate. Many corporate Mobility Managers do not have specific training in welfare, and do not always have the opportunity to engage with those who do. On the other hand, those who deal with welfare lack visibility into mobility data that could make benefit plans much more targeted and effective.

The e-bike case is emblematic, but it is not the only one. Think of local public transport services, corporate car sharing, bike-sharing agreements, or even less conventional solutions like near working — providing professional workspaces in the employee’s municipality of residence to avoid the most burdensome commutes. All initiatives that can, under certain conditions, fall within the scope of goods and services with a social utility purpose, and that acquire operational meaning only when mobility data meets regulatory expertise.

The key message

For those who need to make operational decisions, the picture that emerges from the analysis of the ruling with Silvia Spattini can be summarised in a few key points.

• E-bikes made available to employees for personal use are not comparable to mixed-use company cars. They fall under the category of goods with a social utility purpose under Article 51, paragraph 2, letter f) of the TUIR.
• Favourable tax treatment requires that the good is defined by the company without customisation by the individual employee.
• No monitoring of actual use is required for tax purposes, although the Mobility Manager may promote usage for commuting through parallel awareness initiatives.
• The homogeneous categories provided for by welfare legislation can also be defined based on proximity criteria to the workplace, creating a natural synergy between mobility analysis and welfare planning.

On a topic like this, where nuances matter and the operational implications are concrete, it is worth taking the time to read the original documents and consult those who know them in depth. This is the foundation for enabling Mobility Managers and HR leaders to act with full knowledge of the facts.