A short guide to electronic Invoicing in Italy

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Yes, for all B2B, B2G and B2C invoices.

According to Article 1: “The electronic invoice is a digital document containing no executable code or macro-instructions, and in which proof of the date, authenticity of origin and integrity of the content are guaranteed by affixing the time reference and the issuer's certified electronic signature under the terms of the Digital Administration Code”.
No, it is not mandatory for B2G or B2B invoicing.
For B2C invoicing, if the customer requests an invoice, they can choose either paper or digital format.
In Italy, it has been mandatory to issue e-invoices to the government (B2G) since 2014.

From January 1st 2019 and with the implementation of the legge di bilancio 2018, it will also be mandatory to issue e-invoicing between companies (B2B).

For the end user (B2C), e-invoicing will be compulsory if the customer expressly requests it.

The European Commission has authorised Italy to compulsorily implement e-invoicing in order to fight against fraud. This exceptional measure is valid until 31 December 2021.

The Agenzia delle Entrate and Sogei have developed a free PA e-invoicing system called Sdi.

The Sdi system can be used either by the public administration or by companies using the standardised model of the Agenzia delle Entrate (XML).

In electronic B2B invoicing, they have to use the same standardised models developed by the Agenzia delle Entrate, using the ‘FatturaPA’ model (in XML documents).

According to the Budget Law 2018, the enforceability of electronic invoicing between companies (B2B) came into effect since January 1st 2019. However, from January 1st 2018, invoices must be electronically sent in the following scenarios:

1. Fuel or diesel oil supply to be used as combustible for engines

2. Outsourcing commercial services with the public administration
In order to create, receive, sign, issue or store electronic B2B invoices between individuals, professionals or companies, it is required to use a system with the same legal requirements as the SdI.

Steps to issue electronic B2B invoices:

  • 1. Access the service and choose the ‘use of work’.
  • 2. Generate an electronic invoice.
  • 3. Select the electronic invoice format.
  • 4. After, you can either generate a new invoice, check the latest one created or import the XML archive.
  • 5. Once the XML archive is ready, invoices can be issued between individuals via the exchange system or other compatible software.
  • 6. Once the invoice is sent, the company or an authorised third party will have to wait for the receipt of confirmation via the SdI, via Fisconline or Entratel.
  • 7. If the recipient is connected to the SdI, they will be notified. If not, the invoice will be sent to the PEC (Posta Elettronica Certificata). As per Italian Law, all companies must have a PEC address.
Steps to issue B2C invoices:

  • 1. If the client requests an invoice, the issuer will have to issue an electronic invoice via the SdI.
  • 2. It is expected that the client will be able to check all invoices in the Agenzia delle entrate’s system.
  • 3. An electronic or analog (paper-based) copy of the invoice must be sent to the client.
  • 4. In any case, the client could refuse an electronic or analog copy of the invoice.
Steps to issue foreign transactions:

  • 1. Invoices can be issued via SdI.
  • 2. If not issued via SdI, the VAT registered person or entity, resident in Italy is required to send a statement of all goods or services, delivery date of issue/reception for non-identified individuals in the State, to the Italian Revenue.
  • 3. Telematic transmission to the Revenue must be via a specific communication protocol called ‘cross-border communication’. This must be sent prior to the last day of t the month after the issuing or reception date as appears on the document.
No. There is no pre-approval process required by the Italian Revenue.
Yes, a 3rd party may prepare, issue and transmit electronic invoices on behalf of the supplier. However, this must be clearly stated on the invoice and an Externalisation Agreement is required.

However, Italian law doesn’t specifically state what content should be included in the Externalisation Agreement. Tax authorities have stated that both parts must agree with the terms of issuing and the operating system; and make use of the progressive number sequence of the invoice.

Non-resident operators liable for VAT must inform the Agenzia of the delievery date for all goods or services issued/received from non-resident parties, except of those issuing a customs receipt.

When subcontracting in non-EU countries (without a mutual Agreement), a notification must be sent prior to the transactions and the supplier needs to have worked in Italy for at least 5 years with a clear VAT record of operation.
Yes, as Article 1 states “The electronic invoice is a digital document containing no executable code or macro-instructions, and in which proof of the date, authenticity of origin and integrity of the content are guaranteed by affixing the time reference and the issuer's certified electronic signature under the terms of the Digital Administration Code”.

Any system accepted, p.e. by a qualified electronic signature, or by a digital signature from a qualified certificate with a cryptographic key system (using local approved hardware) or by an electronic stamp.

The formats required are PKCS # 7-CAdES, PDF, XML (XMLDSIG-XAdES).
Yes, all electronic invoices must be electronically signed by the issuing entity or professional, as it is the only way to ensure the integrity and authenticity of the XML archives and the timestamp.

If using a third party, this intermediary, as the issuing subject, must digitally sign the document, although responsibility with the tax authorities will always lie with the seller/supplier.

Qualified certificates issued by a Certification Authority accredited in an EU Member State are generally accepted. In certain cases, local practices and other considerations may require the use of local Certificate Authorities.

For B2B invoicing, it is not mandatory to include an electronic signature. However, if it is included, it must meet the legal established requirements.
Invoices sent via SdI must use the ‘FatturaPA’ format.
Invoices should be stored in such a way as to guarantee their integrity, authenticity and availability during the required storage period.

The original invoice should be stored with its digital signature and any other appropriate evidence of integrity or authenticity. Any evidence of this type must also be stored in a digital format.
Storage in a foreign country is limited to countries that have a bilateral agreement with Italy. If invoices are stored abroad, they are required to be accessible online.

Revenue authorities must be previously notified.
Yes, but responsability must be assigned previously for the archived data (Responsable della Conservazione RDC, in Italian).

This role can be totally or partially delegated to one or various external parties. The person or entity selected must have a direct mandate to delegate a RDC.

The storage system must be capable of generating three information blocks: deposit, distribution and data archive. (Check the following Preservation section).

All invoices must be stored together with its digital signature, and signed by the RDC or a designated third party, no later than three months after the annual tax return due date.

Before storing electronic invoices, they must be signed off by a physical person responsible for the storage or a legal representative. Separate signatures are not allowed unless using the XAdES system.

Italy only allows the following signatures: XML-XAdES, PKCS # 7-CAdES y PDF. Signatures and validation policies are not allowed in invoices.

A predefined format to store invoices (pacchetto di archiviazione) is recommended.
Invoices are to be stored for 10 years from the date of reception.
The Italian Legislative Decree establishes the obligatory information required for tax purposes. The following information must be included in invoices:

  • 1. Date of issue.
  • 2. Unique identifying number .
  • 3. Different codes for electronic and paper-based invoices.
  • 4. The trading name or registered company name, name and surname, residence or domicile of the supplier of any fiscal representative and the permanent location of any non-residents
  • 5. Suppliers registered VAT number.
  • 6. Name, surname or registered company name, residence or domicile of assignee for the fiscal representative and the permanent location of the any non-resident persons.
  • 7. Client’s VAT number or equivalent, in the case of being from another EU member state, as issued by that member state. When the client’s economic activities are not professional and artistic and are resident or domiciled within Italian territory, the fiscal code is required.
  • 8. The nature, quality and quantity of the goods and services covered by the transaction.
  • 9. The fees and other data necessary in determining the taxable base, including the normal value of any goods sold at a discount, with a bonus or rebate pursuant to Art. 15, No. 2
  • 10. The normal value of other goods sold at a discount, with a bonus or rebate.
  • 11. The tax rate, amount of tax and taxable amount rounded to the nearest euro cent.
  • 12. The date of first registration or entry in public registers and number of kilometres travelled, hours sailed or hours flown, if it is an intra-community sale of a new means of transport, pursuant to Art. 38, subsection 4, of Italian Decree Law No 331 of 30 August 1993, converted, with amendments, by Italian Law No. 427 of 29 October 1993.
  • 13. Annotation that the same has been completed by the customer or, on behalf of the seller or supplier, by a third party.
Currency on invoices:

  • 1. The taxable base and VAT must be presented in Euros.
  • 2. The rest of the items on the invoice (description, total base, total invoice) can be presented in a foreign language and currency.
  • 3. At the request of the Tax Authority, invoices in a foreign language can be translated to the national language for control purposes.
Corrective invoices (art. 21bis Presidential Decree 633/72):

  • 1. Date of issue.
  • 2. Unique progressive number as an invoice identifier.
  • 3. the trading name or registered company name, residence or domicile of the subjects involved in the operation and any tax representatives, permanent location of the organisation for non-resident subjects.
  • 4. In relation to sellers or suppliers, the VAT number.
  • 5. If the buyer is located in another EU State, the VAT number (or equivalent) of that state. If the buyer is not involved in an economic activity, of artistic or professional nature, the Fiscal Code is needed.
  • 6. Description of goods and services provided.
  • 7. Total remuneration and VAT, or any data used to calculate it.
  • 8. Regarding art. 26, reference to the corrected invoice and modifications made.
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