Italy: VAT in the Digital Age (ViDA) and E-Invoicing Requirements

E-Invoicing in Italy: Key Insights

Italy has been implementing generalized obligation of electronic invoicing as from 1st January 2019 with some special cases already active previously e.g. business-to-government (B2G) transactions as from 31 March 2015 (Ministerial Decree n. 55/2013).

To date E-invoicing applies to the issuance, transmission and receipt of invoices (including related down-payments) for all invoices issued from taxpayers established in Italy.

Non-residents, even if identified in Italy for VAT purposes, are not required to issue electronic invoices via the SdI, without prejudice to the possibility of issuing them on an optional basis.

E-invoicing obligations have also been extended to include invoices received from non-established taxable persons by Italian-established taxable persons. In this case, the invoices must be issued as self-invoices by the taxable persons established in Italy.

Transactions in the healthcare sector are out of the scope of E-invoicing for privacy reasons. B2C retail transactions, do not require an invoicing obligation unless the customer specifically requests one, in any case,  must be documented by a commercial document (E-receipt) issued through a telematic cash register which transmits the sales data in aggregated form.

Legal Framework for E-Invoicing in Italy

Directive 2014/55/EU, which has been transposed into national legislation, was the first EU legislation that specifically regulates electronic invoicing, only in the context of business-to-government (B2G) transactions.

Italy has requested and obtained a derogation under Article 395 of VAT Directive 2006/112/EC. This exemption allows for special measures to combat tax evasion and fraud by legitimizing the general obligation of B2B and B2C electronic invoicing through the SdI (Interchange System) starting from 1st January 2019.

 Technical specifications were defined by the Italian Revenue Agency provisions No. 89757/2018 (later replaced by No. 433608/2022).

Requirements for E-Invoicing

Invoices must be exchanged through a centralized e-Invoicing system named SdI (“Sistema di Interscambio”) which manages all e-Invoice transmissions. The SdI system is managed by the Italian Revenue Agency, with technical support from Sogei, the government’s IT provider.

Can be considered “electronic” the invoice created, transmitted, and received in XML (eXtensible Markup Language). The Fattura PA XML format adopted in Italy is compliant with European Standard EN 16931.

An invoice transmitted via SdI is considered issued only if it has not been rejected by the SdI. The latter certifies the date of transmission and therefore the issuing date.

Under Italian invoicing general rules, invoices must be issued within 12 days of the time of supply or, in case of deferred invoice, by the 15th day of the month following the time of supply of goods or services.

Businesses are advised to consult with their advisors to ensure compliance, as regulations may vary and change across countries. For those with international operations, coordination with global colleagues is recommended.

Archiving and accessibility of E-Invoices

Both the issuer and the recipient of an E-invoice are required to store it in compliance with legal standards and are responsible for guaranteeing the authenticity, integrity, and legibility of e-invoices during the retention period.

Compliant storage is a process technically regulated by law (CAD – Digital Administration Code). Through this compliant storage process, it is guaranteed over the years that invoices will always remain readable, and, above all, that the original invoice can be retrieved at any time (as well as any other electronic documents chosen for storage).

Additional considerations

In the longer run, the Italian model is expected to align with ViDA, especially for intra-EU transactions starting from 2030.

E-Reporting

E-invoices allow a real-time reporting system for all transaction types, including B2B, B2C, B2G, and cross-border transactions, with data transmitted near real-time to the Italian Revenue Agency. No specific E-reporting obligations are applicable in Italy.

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