Understood.
Whilst this is not answering your specific question, a number of EASA NAAs have issued Exemptions which extends the PBN compliance date to 25 April 2021.
I have been unable to find anything on the ENAC website stating this but if you are able to confirm that ENAC is allowing extensions, that may buy you a bit of time to achieve compliance. I can quote the UK version but this is no good for other NAAs.