Article 198 of the Italian Motor Vehicle Code, entitled "Multiple Violations of Rules Providing for Administrative Fines," states:
"1. Unless otherwise provided by law, anyone who, through a single action or omission, violates multiple provisions providing for administrative fines, or commits multiple violations of the same provision, is subject to the penalty for the most serious violation, increased by up to three times.
2. Notwithstanding the provisions of paragraph 1, in urban pedestrian areas and *limited traffic zones, violators of access restrictions and other individual obligations, prohibitions, or restrictions are subject to the **penalties provided for each individual violation."*
In the event of multiple accesses to the limited traffic zone, the Local Police applies paragraph 2 of the aforementioned article and therefore imposes a fine for each access to the ZTL.
However, case law (Italian Supreme Court Decisions) does NOT consider the aforementioned provision applicable in the event of multiple accesses to the ZTL.
With reference to repeated access to a ZTL, case law (Supreme Court of Cassation decision of 17 July 2024, no. 19680; Supreme Court of Cassation decision of 11 September 2018, no. 22028) has established that if the violations occur within a short period of time and on the same route – therefore with several accesses made to the same area in limited and concentrated periods – it is possible to consider them as a single transgression, applying a single fine.
In such cases, therefore, the law (Article 8-bis, Law No. 689/81) applies, according to which administrative violations subsequent to the first are not considered repeat violations when they are committed in close succession and are attributable to a single event. In light of the foregoing, one can affirm that it is illegal to receive two or more fines for repeated entry—in close succession—in the same restricted traffic zone: in such cases, only the first violation is valid.
Therefore, according to established case law (see above Supreme Court Decisions), in the event of repeated entry into a restricted traffic zone (ZTL), only the first fine is valid. Subsequent fines, since they all stem from the initial omission and are devoid of the awareness and intent to violate the law, can be annulled by appealing to the Justice of the Peace or the Prefect.
It is therefore possible to conclude that, in the event of receiving multiple fines for entering a limited traffic zone within a few minutes of each other, you can turn to the Judge to pay only one fine.
Unfortunately that requires to follow the procedure for recourse in order to have the multiple fines reversed and only one applied.
