In August, the sections are composed, the last enrollments are closed, and the obligations are lined up. It is the moment when the question returns that many coordinators asked us last winter: does the obligation of electronic register for private schools still apply, or was it a measure linked only to 2025/26?
It still applies. There is no new regulation that changes the rules, and this is the central point of the piece. Here you find what remains valid, what you can do now in concrete terms, and what — honestly — is still unclear.
The Regulation, in Two Lines
Decree Law 45/2025 inserted paragraph 31-bis in Article 7 of Decree Law 95/2012, extending the electronic register and electronic report card to private schools starting from the 2025/2026 school year. Law 79/2025 confirmed it during the conversion, referring to private schools of all levels and specifying that the obligation must be fulfilled without new burdens on public finances.
If you need the complete picture of the text and its implications, we have reconstructed it in the article Electronic Register for Nursery and Kindergarten: What the Regulation Says. This piece starts from there and looks at the educational year about to begin.
What Remains Valid in 2026/27
The first misunderstanding to clarify concerns the duration. This is not a one-time obligation linked to a single school year: the obligation came into effect with 2025/26 and continues in 2026/27. Those who were within the scope last year are still within it now, under the same conditions. You do not need to look for a new regulation: you need to confirm what you have already set up.
The second point is that formula regarding costs, without new burdens on public finances. Put simply, it means that the tool remains the responsibility of the institution. There is no dedicated fund to cover the expense, so the digital register must be included in the budget like any other organizational item for the year.
Who is Included and Who is Excluded
Private schools of the first and second cycle fall under the obligation without room for interpretation. On this, the text is clear, and there is nothing to interpret.
Nurseries and educational services for 0-3 are instead excluded: they are not private schools under this regulation and therefore do not fall under the obligation. For a 0-3 structure, the digital register remains a managerial choice, to be evaluated for its organizational advantages and not as an obligation to be fulfilled.
This is a distinction worth putting in writing, especially if you manage multiple facilities with different age groups: the same organization can have part within the scope and part outside, and the two things are treated differently.
Private Kindergartens: The Still Discussed Point
Here, maximum honesty is required, as this is the issue on which we receive the most questions.
The paragraph regarding the computer protocol expressly specifies "first and second cycle". The one on the electronic register, however, does not contain any grade specification. From this difference arises the prevailing interpretation that even private kindergartens would be included in the obligation.
This remains an interpretation, not a certainty. It is a reasonable and widespread reading, but it is not a source: it is the way the text is commonly read in the absence of an official clarification. And an official clarification, at the time of writing, does not exist: the Ministry has not yet issued a circular defining the scope of application.
The practical consequence is a single one. Before committing to expenses, verify your position with your consultant and the relevant regional school office. They are the ones who can tell you how the regulation applies to your case and in your territory. No rush and no deadlines to chase: a thorough check before signing anything.
What to Do Now, in Concrete Terms
- Put in writing the position of each facility. For each location: age group served, legal nature, presence or absence of parity. This is the basis for any subsequent decision.
- Request a written confirmation. An email to the consultant and a request to the regional school office give you a documentary reference, useful even months later.
- If you already use a digital register, check the data output. Ensure you can export and store what you record in formats readable outside the software.
- Decide who records what. Entry, exit, absences: establish now who takes care of it in each section and at what time of day, so that there is no improvisation in September.
- Align information and privacy appointments. If you change tools, the information to families and the appointment of the supplier as data processor must be updated accordingly.
- Prepare communication to families. A few lines in the start-of-year letter avoid dozens of questions on the first day of opening.
How It Translates into the Daily Life of a Section
Beyond the regulatory framework, a digital register only makes sense if it keeps pace with the real rhythm of a 0-6 structure. In Easy.School, the digital register is included in the license: it is not an additional module to be purchased separately.
It records entry, exit, and absence with time, accompanying person, and reason, and the recording can occur manually, via QR code, or PIN, depending on how the entrance of the structure is organized. The logbook aggregates presence, lunch, snack, nap, needs, activities, and daily averages: educators have a single place to note down, instead of three different notebooks. Recurring registrations are automated by section, day of the week, and time slot, so what repeats every week does not have to be rewritten each time.
On the documentation front, the registers can be exported in PDF, Excel, and CSV. There is also a protocol register with progressive numbering for the year, SHA-256 hash on the file, and ZIP export for date range. Each structure has a dedicated database, the data remains in the European area, the appointment act as data controller is downloadable, the DPO is appointed, and actions on the tables are logged.
Regarding costs, since the regulation does not bring funding with it, the number is this: for the first 20 enrolled children, the license costs 25 euros per month or 250 euros per year plus VAT, with 4 GB included. Each additional child adds 0.60 euros per month (6 euros per year) and 0.2 GB. The only variable costs are extra GB, SMS, and AI functions. Easy.School is a cloud management system dedicated to 0-6, developed by a Roman software house active since 2010 and used by over 1000 structures.
In Summary
The electronic register for private schools was not a measure for just one year: it remains valid in 2026/27, with the same framework as 2025/26. Private schools of the first and second cycle are included; nurseries and 0-3 services are outside the obligation and evaluate digital as a managerial choice; for private kindergartens, the prevailing reading is of inclusion, but it is an interpretation, and there is still no ministerial circular clarifying the scope.
Before committing resources, have your position verified by the consultant and the regional school office. Then choose the tool calmly, looking at how your structure really operates. Try Easy.School for free.
