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Article 2375 of the Italian Civil Code, as amended by Article 1 of Decreto Legislativo no. 6 of 17th January 2003, is about the minutes of decisions taken by the assembly of a joint-stock company. It requires that the names of the participants in the assembly and the outcome of votes result from the minutes or from an attachment to them, thereby allowing the identification of approving, abstaining and dissenting participants. 

Article 2377, paragraph 4, no. 3, of the Civil Code, provides that a decision may be annulled for uncertainty about its content, its effects and its validity, but not for mere incompleteness or inaccuracy of the minutes.

With judgment no. 603 of 12th January 2017, the Court of Cassation has stated that, if the documentation indicating participants and voters is lacking and not attached to the minutes, a decision may be annulled, as per article 2377, paragraph 4, no. 3, of the Civil Code, in that such documentation is required to ascertain the process by which that decision was reached and the validity of the decision itself.

According to the Court, to avoid the annulment of a deliberation, it is necessary that the documentation at issue be expressly mentioned in the minutes or, at least, attached to the minutes themselves.