[Art. 43 L. n. 234/2012] Il diritto di rivalsa dello Stato nei confronti delle Regioni e degli enti locali per violazione del diritto comunitario

Bruxelles, Palazzo Berlaymont

Negli ultimi decenni si è indubbiamente assistito ad un incremento del ruolo delle Regioni e, più in generale, degli enti substatali, nel contesto dell’integrazione europea (U. Bullmann, The Politics of the Third Level, in C. Jeffery (ed.), The Regional Dimension of the European Union. Towards a Third Level in Europe?, F. Cass, London, 1997, 3 ss.). Non si può più dunque parlare di una completa e totale «cecità» (H.P. Ipsen, Als Bundesstaat in der Gemeinschaft, in E.V. Caemmerer, H.J. Schlochauer e E. Steindorff, Probleme des Europäischen Rechts, Festschrift für Walter Hallstein zu seinem 65 Geburtstag, Frankfurt a. M., 1966, 228 ss.) dell’Unione nei confronti dei livelli di governo infrastatali, ma si deve prendere atto di un accresciuto ruolo degli stessi in ambito comunitario. Forse ci si potrebbe addirittura spingere sino al punto di affermare la presenza, oggi, di un “dovere”, per gli Stati membri, di riconoscere tale ruolo.

A questo proposito, in Italia, la riforma costituzionale del 2001 ha rappresentato per le Regioni un notevole passo in avanti rispetto al riconoscimento di una loro «dimensione comunitaria» (B. Sardella, La “dimensione comunitaria” dei nuovi Statuti regionali, in Le Istituzioni del federalismo, 2007, 431 ss.). Le profonde modifiche apportate all’art. 117, I e V co., Cost. hanno certamente “rafforzato”, a livello costituzionale, il ruolo delle Regioni nelle relazioni con l’Unione Europea, contribuendo al riconoscimento di un loro “diritto costituzionalmente qualificato” a partecipare, nelle materie di propria competenza, alla formazione e alla attuazione del diritto comunitario: la scelta di coinvolgere le Regioni nei processi comunitari è dunque «dovuta», non più «ottriata» (A. D’Atena, La nuova disciplina costituzionale dei rapporti internazionali e con l’Unione europea, in Rassegna Parlamentare, 2002, 921).

A fronte di una maggiore partecipazione regionale alla fase ascendente e, in particolare, discendente, risulta inoltre ampliata la responsabilità delle Regioni, peraltro sul solo versante interno, nel dare corretta e pronta attuazione agli obblighi derivanti dall’ordinamento comunitario. Rispetto al versante comunitario, infatti, è principio fondamentale che la responsabilità per violazione della normativa comunitaria sia attribuita esclusivamente allo Stato membro. Anche la Corte di Giustizia ha dichiarato, a più riprese, che l’unico soggetto chiamato a rispondere per violazione del diritto comunitario è lo Stato (Corte giust., causa C-33/90, 13 dicembre 1991, Commissione c. Italia, in Racc., I-5987). Nulla conta, pertanto, per l’ordinamento comunitario, che l’infrazione sia imputabile a un ente diverso da questi, sia esso un’autorità pubblica o territoriale (da ultimo si veda, ad esempio, Corte giust., causa C-573/08, 15 luglio 2010, Commissione c. Italia, in Racc., I-95), e nessuna rilevanza assume la ripartizione costituzionale delle competenze interna allo Stato.

Sul versante dell’ordinamento interno la questione è invece più complessa. È infatti innegabile che le Regioni debbano adottare – ancor più sulla base del novellato riparto costituzionale di competenze e del limite di cui all’art. 117, I co. – tutte le misure idonee ad assicurare l’esecuzione degli obblighi derivanti dal Trattato e dagli atti delle istituzioni comunitarie, astenendosi da qualsiasi azione che rischi di compromettere la realizzazione degli scopi comunitari.

In conseguenza dell’ingente numero di procedure di infrazione aperte dalla Commissione europea nei confronti dell’Italia per violazioni del diritto comunitario o omessa attuazione degli obblighi europei – peraltro in gran parte imputabili alle Regioni – e anche a causa dell’irrigidirsi dell’atteggiamento delle istituzioni comunitarie nei confronti degli Stati membri inadempienti, si è ripetutamente cercato, negli ultimi anni, di intervenire a livello di ordinamento nazionale italiano rispetto a due profili.

In primo luogo si è tentato di ridurre e prevenire il contenzioso con la Corte di giustizia, intervenendo più attivamente già nella fase del precontenzioso di fronte alla Commissione europea.

Si è poi voluta introdurre una modalità di rivalsa dello Stato nei confronti delle Regioni e degli enti locali, principalmente allo scopo di istituire un deterrente per questi enti, affinché diano pronta attuazione agli obblighi comunitari o, nel recepire la normativa comunitaria, non ne violino il contenuto.

Quanto al primo profilo di intervento, senza dubbio significativo è l’Accordo, concluso in sede di Conferenza Unificata il 24 gennaio 2008 (in Repertorio atti n. 3/CU del 24.01.2008), con il quale si è cercato di instaurare una migliore collaborazione tra Stato e Regioni, stabilendo procedure e modalità per rendere maggiormente tempestiva e completa la reciproca informazione e prevedendo forme di effettivo coinvolgimento delle Regioni nelle diverse fasi della procedura di infrazione a livello comunitario, anche, e soprattutto, in quella precontenziosa.

A tal proposito è interessante notare come anche la recente Legge n. 234 del 24 dicembre 2012, recante «Norme generali sulla partecipazione  dell’Italia  alla  formazione  e all’attuazione della normativa e delle politiche dell’Unione europea» (su cui, su questo sito, già è intervenuto, in relazione ad un altro profilo di interesse, E. Albanesi, La partecipazione dei consigli regionali alla verifica del rispetto del principio di sussidiarietà di cui al Trattato di Lisbona), abbia inteso rafforzare le prerogative di informazione e di controllo sulle procedure giurisdizionali e di contenzioso riguardanti l’Italia, in parte già sancite nella Legge 11/2005 e nell’Accordo del 2008 (si vedano, in particolare, gli artt. 14, I co., lett. c); 15; art. 29, VII co., lett. f);  37; 40, I co., della L. 234/2012).

Si può quindi affermare senza esitazione che negli ultimi anni l’ordinamento italiano ha incentivato e incrementato le modalità di cooperazione e lo scambio di informazioni tra Stato, Regioni ed enti locali; si è così auspicata, e si è cercato di procedimentalizzare, una più attiva partecipazione degli enti substatali – quanto meno a livello nazionale – nell’ambito della procedura di infrazione, contribuendo alla riduzione del contenzioso di fronte alla Commissione europea e alla Corte di giustizia e alla archiviazione di molte delle procedure di infrazione aperte.

Quanto al secondo profilo, più di diritto sostanziale, si è tentato di introdurre e di definire modalità e limiti per il concorso di responsabilità tra lo Stato e gli enti substatali inadempienti.

Già nella legge finanziaria per il 2007 (L. n. 296 del 27 dicembre 2006, art. 1, co. 1213-1223) era stata introdotta per la prima volta un’azione di rivalsa dello Stato nei confronti delle Regioni e degli enti territoriali responsabili di inadempimenti e infrazioni comunitarie. Vi era prevista la possibilità per lo Stato di rivalersi degli oneri finanziari conseguenti alle sentenze di condanna della Corte di giustizia, salvo l’obbligo per gli enti territoriali – Regione compresa – di rimediare tempestivamente alle proprie violazioni. La norma aveva una prevalente funzione deterrente, in quanto volta a responsabilizzare i livelli di governo regionale e locale nei riguardi degli adempimenti derivanti dall’appartenenza dell’Italia all’Unione europea, in considerazione anche delle più ampie competenze loro riconosciute dalla riforma del Titolo V della Costituzione.

Il contenuto di questa  legge finanziaria è stato ripreso dalla legge comunitaria statale per il 2007 (L. n. 34 del 25 febbraio 2008, art. 6, I co., lett. e), e II co.), che ha inserito l’art. 16bis alla Legge 11/2005. Infine, il diritto di rivalsa è stato recentemente ridisciplinato integralmente nell’art. 43 della Legge 234/2012, che ha abrogato l’intera Legge 11/2005. Secondo la nuova disciplina, lo Stato «ha diritto di rivalersi, nei confronti delle Regioni, delle Province autonome, degli enti territoriali, di altri enti pubblici e soggetti equiparati, responsabili delle violazioni degli obblighi derivanti dalla normativa dell’Unione europea, degli oneri finanziari derivanti dalle sentenze di  condanna rese dalla Corte di giustizia dell’Unione europea ai sensi dell’art. 260, paragrafi 2 e 3, TFUE»[i]. La misura degli importi dovuti allo Stato a titolo di rivalsa, non superiore complessivamente agli oneri finanziari dovuti, è stabilita con decreto del Ministro dell’economia e delle finanze, emanato entro tre mesi dalla notifica della sentenza esecutiva di condanna della Repubblica italiana. Il decreto ministeriale, che costituisce titolo esecutivo nei confronti degli obbligati, deve essere emanato previa intesa sulle modalità di recupero con gli enti obbligati. Il termine per il perfezionamento dell’ intesa è di quattro mesi decorrenti dalla data della notifica, all’ente territoriale obbligato della sentenza esecutiva di condanna. L’intesa ha ad oggetto la determinazione dell’entità del credito dello Stato e l’indicazione delle modalità e dei termini del pagamento, anche rateizzato. Qualora non si riesca a raggiungere l’intesa con l’ente territoriale, spetta al Presidente del Consiglio adottare il provvedimento esecutivo nei successivi quattro mesi, sentita la Conferenza Unificata.

Questo istituto, certamente innovativo, suscita tuttavia perplessità.

Un primo ordine di problemi sorge rispetto alla conciliabilità del diritto di rivalsa con la possibilità per lo Stato di sostituirsi agli enti substatali costituzionalizzata con la riforma del Titolo V del 2001, agli artt. 117, V co., e 120, II co.

Per quanto concerne l’esercizio del potere sostitutivo di cui all’art. 117, V co., Cost., la disciplina di attuazione (art. 10 L. 11/2005, ora art. 41 L. 234/2012) prevede che il Governo possa adottare provvedimenti, anche urgenti, per l’adeguamento agli obblighi derivanti dall’ordinamento comunitario in materie di competenza regionale. Le Regioni interessate devono esserne previamente informate e deve essere loro assegnato un termine per provvedere autonomamente. Ove necessario, inoltre, la questione può essere sottoposta all’esame della Conferenza Stato-Regioni.

Nell’ipotesi di esercizio del potere sostitutivo di cui all’art. 120, II co., invece, la disciplina di attuazione (art. 8, L. 131/2003) consente allo Stato di assegnare all’ente territoriale interessato un congruo termine per adottare i provvedimenti dovuti o necessari per porre rimedio alla violazione della normativa comunitaria; decorso inutilmente tale termine, il Consiglio dei ministri, sentito l’organo interessato, può adottare i provvedimenti necessari, anche normativi, oppure nominare un apposito commissario. Qualora si tratti di casi di assoluta urgenza e l’intervento sostitutivo non risulti pertanto procrastinabile, il Consiglio dei ministri può adottare immediatamente i provvedimenti necessari; essi, tuttavia, devono essere immediatamente comunicati alla Conferenza Stato-Regioni o alla Conferenza Stato-Città e autonomie locali, le quali possono chiederne il riesame.

La procedura di sostituzione prevede dunque, in entrambe le ipotesi, l’instaurazione di una previa collaborazione con l’ente inadempiente, la quale, da un lato consente a quest’ultimo di sopperire sino all’ultimo alla propria inadempienza nel rispetto del riparto di competenze e di un auspicato e maggiore coordinamento tra livelli di governo diversi; dall’altro  consente allo Stato di intervenire prima che l’inadempienza si realizzi e la conseguente responsabilità ricada su di esso.

Il diritto di rivalsa e i poteri sostitutivi statali paiono pertanto in contraddizione: lo Stato, sostituendosi alle Regioni e agli enti locali, ha  la possibilità di evitare un’eventuale inottemperanza nell’attuazione della normativa comunitaria (sul punto cfr. F. Bientinesi, Le Regioni nella formazione e nell’attuazione del diritto europeo, in A. D’Atena (a cura di), Regionalismo e sovranazionalità, Giuffré, Milano, 2008, 170; C. Bertolino, Il ruolo delle Regioni nell’attuazione del diritto comunitario. Primi passi significativi e profili problematici, in Le Regioni, 2009, 1302). Nell’ipotesi di un accertamento della violazione degli obblighi comunitari imputabile a enti substatali, difficilmente lo Stato potrebbe quindi rivalersi in toto su di essi: anzi, non avendo prontamente esercitato il proprio potere sostitutivo, risulterebbe imputabile – non solo per l’ordinamento comunitario, ma anche per quello interno – della violazione (F. Bientinesi, Il ruolo parlamentare nel processo legislativo di recepimento delle direttive, in C. Odone e G. Di Federico (a cura di), Il recepimento delle direttive dell’Unione europea nella prospettiva delle Regioni italiane, Ed. Scientifica, Napoli, 2010, 194).

L’obiezione è stata superata dalla dottrina, la quale evidenzia come «l’inosservanza regionale non può essere sempre arginata dallo Stato, come si può constatare ad esempio in materia di circolazione della disciplina sugli aiuti pubblici alle imprese» (O. Porchia, La gestione del contenzioso con l’Unione europea per violazioni imputabili alle Regioni: gli strumenti previsti in Italia e in Spagna, in Il Diritto dell’Unione Europea, 2011, 423). Posto dunque che non si possono prevedere ex ante tutte le ipotesi di violazione della normativa comunitaria da parte degli enti substatali, nonché la quota di responsabilità dello Stato per mancata attivazione del potere sostitutivo, non è da ritenersi incoerente l’introduzione di un diritto di rivalsa a favore di quest’ultimo.

Peraltro, sarebbe opportuno interrogarsi preliminarmente, anche se non è possibile farlo in questa sede, sull’esistenza per lo Stato di un vero e proprio obbligo di intervento sostitutivo nelle ipotesi di inadempienza regionale. Qualora fosse teorizzabile tale obbligo lo Stato diverrebbe per l’ordinamento interno, al pari di quello comunitario, l’unico responsabile della violazione degli obblighi comunitari. Di conseguenza, l’introduzione di un diritto di rivalsa potrebbe risultare illegittima. A tale teoria si potrebbe tuttavia obiettare – oltre quanto già rilevato supra – che il riconoscimento costituzionale di una competenza regionale rispetto alla fase discendente del diritto comunitario non può esonerare le Regioni dalla propria responsabilità, con la conseguenza che si dovrebbe piuttosto pensare ad una responsabilità solidale Stato-Regioni.

Altro aspetto di incertezza risiede nel fatto che lo Stato, unico legittimato passivo a livello comunitario, attraverso la procedura precontenziosa è messo sin da subito in condizione di conoscere l’illecito e di adottare i provvedimenti per evitare la sentenza di condanna (M. Bini, Il diritto di rivalsa dello Stato per le violazioni da parte delle Regioni del diritto dell’Unione europea: uno strumento di impulso all’attività regionale o un istituto inapplicabile?, in Quaderni Regionali, 2010, 853). Nel momento in cui si apre un contenzioso con le istituzioni comunitarie lo Stato ha infatti a sua disposizione più strumenti idonei ad evitare una sentenza di condanna: pertanto, la responsabilità di un fallimento in questa situazione dovrebbe forse essere imputata solo ad esso.

L’ordinamento interno ha però provveduto in questi ultimi anni ad introdurre disposizioni che procedimentalizzano, già nella fase precontenziosa, la maggiore partecipazione e la collaborazione anche degli enti substatali inadempienti. Queste procedure colmano in qualche misura il gap dovuto all’assenza di una loro legittimazione processuale a livello comunitario. Il diritto di rivalsa costituisce pertanto per lo Stato, in qualche modo, una misura estrema.

Un ulteriore aspetto lascia incerti rispetto all’utilizzo e alla reale efficacia deterrente del diritto di rivalsa. In una situazione di difficoltà economica per il Paese, come quella odierna, in che modo lo Stato pensa  di rivalersi realmente su Regioni o enti locali, i cui bilanci risultano già notevolmente depauperati? Di fronte al diritto prescrittivo, sembra dunque più rilevante il “principio di realtà”, il quale pone innegabili vincoli alle politiche dei legislatori. Inoltre, non si può non concordare con la dottrina che ritiene che, sino a quando sarà in vigore un sistema di finanza derivata, difficilmente «il diritto di rivalsa dello Stato potrà costituire un valido deterrente» (V. Boncinelli, Il mancato recepimento e la violazione del diritto comunitario imputabili a comportamenti, omissioni e ritardi del Governo, in S. Baroncelli (a cura di), Il ruolo del Governo nella formazione e applicazione del diritto dell’Unione Europea, Giappichelli, Torino, 2008, 225).

Infine, è vero che la disciplina del diritto di rivalsa prevede il raggiungimento di un’intesa tra lo Stato e l’ente responsabile dell’inadempimento e, in mancanza di questa, un parere della Conferenza Unificata. Per quanto ciò sia auspicabile, si dubita tuttavia del positivo raggiungimento di tale intesa: in astratto è pressoché impossibile predeterminare i criteri per ripartire la responsabilità; anche in concreto, l’operazione risulta difficilmente realizzabile: essendo dunque l’intesa debole, sarà prevalentemente lo Stato a stabilire in che modo ripartire la responsabilità e, soprattutto, quanto deve essere comminato alla Regione. Da parte sua l’ente obbligato potrà comunque ricorrere nelle competenti sedi giudiziarie avverso il provvedimento in questione.

Nonostante la più ampia autonomia riconosciuta in ambito comunitario alle Regioni dalle riforme di questi ultimi anni, occorre quindi constatare come oggi l’ordinamento italiano si caratterizzi per la perdurante presenza di pratiche “viziose”, che purtroppo portano ancora troppo spesso all’apertura di procedure di infrazione nei confronti del nostro Paese da parte della Commissione europea. Per quanto infatti debba ritenersi che vi sia ormai un impianto normativo che attribuisce alle Regioni efficaci strumenti di partecipazione sia alla fase ascendente che a quella discendente, i risultati tardano ancora a venire.

Tale situazione è dovuta, in parte, ad almeno due fattori. In primo luogo, alla complessità della normativa comunitaria, specie in alcuni ambiti materiali, la quale si intreccia con la «elasticità fisiologica» (A. Anzon, Un passo indietro verso il regionalismo duale?, in AA.VV., Il nuovo Titolo V della parte II della Costituzione. Primi problemi della sua attuazione, Giuffré, Milano, 2002, 232) delle materie di cui al novellato art. 117 della Costituzione.

Un secondo fattore che ha indubbiamente contribuito all’instaurarsi di un circolo “vizioso” è il potere sostitutivo riconosciuto allo Stato. Anzitutto nella prassi: nonostante la normativa preveda che lo Stato, nel sostituirsi alle Regioni, debba esplicitare la cedevolezza del proprio intervento,  non sempre questa viene espressa. Ne consegue una incertezza complessiva del sistema che ha sostanzialmente indotto le Regioni a non dare attuazione agli obblighi comunitari.

Si ritiene dunque che per il complessivo funzionamento del sistema si debba con insistenza e determinazione perseguire la trasformazione di questo circolo “vizioso” in circolo “virtuoso”. Alcuni passi in avanti sono stati compiuti in questo senso, attraverso, in specie, le apprezzabili previsioni che vincolano Stato, Regioni ed enti locali a processi di costante e reciproca informazione. Le fasi ascendente e discendente, infatti, «sono collegate in realtà dall’acquisizione di informazioni: il volano dell’efficienza» (G. Pastore, La fase discendente: governance interistituzionale nell’attuazione regionale delle direttive comunitarie, in Il ruolo del Governo nella formazione e applicazione del diritto dell’Unione Europea, cit., 268) è pertanto costituito in maniera rilevante dalla quantità e qualità delle informazioni “in entrata” e “in uscita”.

Molto altro ancora può essere fatto in questa direzione. In particolare, a fronte del decentramento territoriale cui si è assistito negli ultimi vent’anni – per quanto con la crisi economica mondiale si stia indubbiamente andando verso un riaccentramento delle competenze – si deve riconoscere che lo Stato «is no longer the unrivalled king of the hill» (B. Guy Peters e J. Pierre, Developments in intergovernmental relations: towards multi-level governance, in Policy & Politics, 2001, vol. 29, 132); non ha più, dunque, lo “scettro del comando”. Esso, tuttavia, non solo può, ma deve assumere lo “scettro” del dialogo e della negoziazione. Si sostiene dunque fermamente che si debbano privilegiare normative concordate e processi di leale collaborazione, che coinvolgano Stato e Regioni non solo dal punto di vista organizzativo e procedurale, ma prima ancora politico e culturale (C. Bertolino, Il principio di leale collaborazione nel policentrismo del sistema costituzionale italiano, Giappichelli, Torino, 2007).

Solo in questo modo la Repubblica italiana, e gli enti territoriali che la costituiscono, potranno raggiungere una piena maturità rispetto alla propria “dimensione comunitaria” e, soprattutto, rendere efficienti la propria partecipazione al processo di integrazione europea e i singoli strumenti pensati per darvi concreta attuazione.


[i] Si noti peraltro come siano previste altre due ipotesi di rivalsa dello Stato. La prima fattispecie riguarda la rivalsa dello Stato per regolazioni finanziarie “operate a carico dell’Italia a valere sulle risorse del Fondo europeo agricolo di garanzia (FEAGA), del Fondo europeo agricolo per lo sviluppo rurale (FEASR) e degli altri Fondi aventi finalità strutturali”. La seconda ipotesi, invece, è relativa al diritto di rivalsa, su soggetti che si siano resi responsabili di violazioni delle disposizioni della Convenzione per la salvaguardia dei diritti dell’uomo e delle libertà fondamentali e dei relativi Protocolli addizionali, “degli oneri sostenuti per dare esecuzione alle sentenze di condanna rese dalla Corte europea dei diritti dell’uomo nei confronti dello Stato in conseguenza delle suddette violazioni”.

Cristina Bertolino

(Università degli Studi di Torino)

Foto | Wikipedia.org

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