E-Invoicing in Italy: The SDI Rules Every Founder Must Follow

What Counts as a Valid Electronic Invoice in Italy?

The rule in one sentence: an XML file through the Sistema di Interscambio

Article 1(3) of Normattiva: D.Lgs. 127/2015, Art. 1 states the rule without qualification: for supplies of goods and services between persons resident or established in Italy, only electronic invoices may be issued, using the Sistema di Interscambio and the format the same article sets out. The obligation reached VAT taxpayers generally on 1 January 2019, after two sectors, fuel and public-contract subcontractors, went first on 1 July 2018. Intermediaries may transmit the file on a supplier's behalf, but the statute is explicit that liability stays with the person who made the sale.

Why "si intende non emessa" means the invoice legally does not exist

An invoice issued by any other means, an email, a PDF, a paper copy handed across a desk, is not a defective invoice. Under Art. 1(6) of the same decree it si intende non emessa: the law deems it never issued. Nothing in Italian VAT practice treats this as a technicality. The consequence is that the underlying sale carries no valid invoice at all, and the penalty regime described later on this page attaches to the supplier from that moment, not from the moment somebody happens to notice.

The statutory format reference, and what actually governs it today

The format itself is fixed by allegato A to D.M. 55/2013, the ministerial decree named in Art. 1(2) as the reference for the XML structure. That decree, however, was written for invoicing the public administration. What actually governs an invoice between two private parties is a separate instrument, Provvedimento no. 433608 of 24 November 2022, and the gap between the two rule sets is wide enough to earn its own section further down this page.

How Did Italy's Mandate Arrive, and Why Does It Have an Expiry Date?

Every top result for this query treats the mandate as a fixed fact of Italian law. It is not one. Italy can require electronic invoicing domestically only because the Council of the European Union granted a derogation from the VAT Directive, and that derogation carries an expiry date the search results rarely mention.

The 2018 derogation from Articles 218 and 232 of the VAT Directive

Compulsory e-invoicing needed permission first. Article 218 of Directive 2006/112/EC lets a taxable person choose the invoice format, subject to the recipient's acceptance under Article 232, and a single member state cannot simply override that choice on its own authority. The Council granted Italy a derogation from both articles in Council Implementing Decision (EU) 2018/593 of 16 April 2018, excluding only taxable persons who use the small-enterprise exemption of Article 282. The derogation from Article 232 is what let Italy drop the recipient's consent altogether.

Two extensions, and the current expiry: 31 December 2027

The first window ran from 1 July 2018 to 31 December 2021. Decision (EU) 2021/2251 extended it to 31 December 2024 and widened it to small enterprises, the change that eventually let forfettari come inside the obligation. EUR-Lex: Council Implementing Decision (EU) 2024/3150 then moved the expiry to 31 December 2027, and it fixed 31 March 2027 as the deadline for Italy to request anything further, alongside a report on how the measure affects small enterprises.

The EU general system that now exists, and what it changes

A derogation is no longer the only route to a mandatory system. Council Directive (EU) 2025/516 of 11 March 2025, part of the VAT-in-the-Digital-Age package, added a paragraph to Article 218 letting a member state require domestic e-invoicing without asking Brussels first, and a matching paragraph to Article 232 dropping the recipient's acceptance. See EUR-Lex: Council Directive (EU) 2025/516. Italy's own derogation now dies early if the Council's general system becomes applicable before 2027 arrives. Nobody can say today which of the two dates will govern first, and this page does not guess at an answer.

Does E-Invoicing Apply to Your Company?

Four questions settle the matter for almost every reader: is the company resident or established in Italy, does it sell to consumers as well as to businesses, is it a flat-rate taxpayer, and does the other side of a given transaction sit outside Italy.

Who is obliged: resident or established, B2B and B2C alike

Agenzia delle Entrate: who must issue an e-invoice, and who is exempt states the perimeter plainly: every VAT-registered person resident or established in Italy that deals with another person resident or established in Italy is obliged, whether the counterparty is a business or a consumer. Invoicing the public administration has run on its own electronic rule since 31 March 2015, alongside the 2019 general obligation, so a founder selling to a mix of businesses, consumers and public bodies meets the SdI on every side of the ledger.

The only three carve-outs: two exemptions and one prohibition

Three exceptions exist, and only two of them are exemptions. Small agricultural producers under Art. 34(6) D.P.R. 633/1972, and holders of the Art. 36-bis dispensation for exempt operations, are relieved of invoicing altogether, so there is nothing left for the SdI to touch. Healthcare services supplied to a final consumer sit in a different category: they are not exempt, they are prohibited from the SdI, because routing medical data through a shared national platform raises a sensitivity concern of its own. The same healthcare invoices addressed to a VAT-registered counterparty stay inside the ordinary obligation, stripped of anything identifying the patient.

Forfettari: inside the obligation since 1 January 2024

Flat-rate taxpayers were the last group left outside, and the closure came in two dates rather than one. From 1 July 2022 a forfettario whose prior-year revenue exceeded EUR 25,000 came inside the obligation. Everyone else followed on 1 January 2024, under Art. 18(3) D.L. 36/2022. A flat-rate invoice still carries its own quirks: a 0% rate, the Natura code "Non soggette, altri casi", and a mandatory reference to Art. 1, commi 54 to 89, L. 190/2014.

Invoices to foreign counterparties are optional, not compulsory

Selling abroad removes the compulsion, not the choice. Issuing an electronic invoice to a foreign counterparty through the SdI is optional, and a supplier who chooses not to issue one instead reports the transaction data directly, a route unpacked further down this page under cross-border reporting.

The non-resident, VAT-identified-only case

One case has no clean answer, and any page that gives you one is guessing. The obligation is worded as covering persons "resident or established in Italy". A company that holds only an Italian VAT number, with no permanent establishment, sits outside that wording on its face. The Agenzia delle Entrate, however, states no matching exemption anywhere in its guidance, so the position has to be settled on the facts of the specific company rather than assumed from the statute's silence.

What Format Must the Invoice Take, and Who Actually Sets the Rules?

Two documents both claim to define the Italian e-invoice, and only one of them applies to an ordinary private company.

The XML file, and the size limits that actually bind you

The invoice itself is a structured XML file, transmitted to whatever telematic address the client has set up, through the SdI. Two size limits bind it in practice: a single invoice file cannot exceed 5 MB, and a PEC message carrying it, attachments included, cannot exceed 30 MB. Split a large batch before it reaches either ceiling, because the SdI does not negotiate on file size.

Two rule sets, and the regulator says so explicitly

Two regimes exist, and the Agenzia delle Entrate's own guidance separates them explicitly, though the separation rarely survives translation into English. Rules for preparing, transmitting, receiving and storing invoices between private parties come from Provvedimento no. 433608 of 24 November 2022. Invoices addressed to a public administration instead run on D.M. 55/2013 and the fatturapa.gov.it portal. A founder who reads a guide written for the public-sector channel and applies it to a B2B invoice will over-comply on some points and under-comply on others.

The technical specifications in force, and the document types you will actually meet

Agenzia delle Entrate: technical specifications version 1.9 has governed since 1 April 2025, and it is the document that fixes every field name used elsewhere on this page. Twenty-two document type codes exist, TD01 to TD29, but a founder meets only a handful in practice: TD01 for an ordinary invoice, TD04 and TD05 for a credit note and a debit note, TD16 to TD20 for reverse-charge and self-billing scenarios, TD24 and TD25 for a deferred invoice, and TD29 for reporting a supplier's omission.

Is a digital signature required?

Not between private parties. The SdI accepts an unsigned file for every invoice sent to a VAT taxpayer or a consumer, and validates the certificate only where one happens to be attached. Invoicing a public administration is the opposite case: the file must carry a digital signature, in CAdES-BES or XAdES-BES format, with no exception allowed.

How Is an Electronic Invoice Addressed?

Four scenarios cover every client a founder will invoice, and the codice destinatario changes with each one.

The four permitted values of CodiceDestinatario

Codice destinatario (recipient code) is a 7-character alphanumeric address for the client's receiving channel, and it takes one of four forms. A client with an accredited channel gets the code the SdI assigned when that channel was set up. A client who receives by PEC gets 0000000, with the PEC address itself entered in a separate field. An unknown channel also gets 0000000. A client established outside Italy gets XXXXXXX, which routes the file into cross-border reporting instead of ordinary delivery; using it on a counterparty whose country code reads "IT" triggers rejection error 00313.

Why a registered telematic address beats the one on the invoice

A supplier does not always know a client's channel, and a client does not have to trust every supplier to write it correctly. Registering a default telematic address inside Fatture e Corrispettivi solves both problems at once: once registered, that address prevails over whatever a supplier put in the file. The same portal generates a QR code carrying the VAT number, the registry data and the registered address, which a supplier scans instead of retyping.

Addressing a customer with no Italian tax identifier

A foreign customer with no Italian code still gets a genuine electronic invoice if the supplier chooses to issue one. The file carries XXXXXXX, the buyer's ISO country code, up to 28 unvalidated characters as the identifier, and the generic postcode 00000. Nothing in that block is checked against a register, which is exactly why it works for a party Italy has no record of at all.

Get the addressing wrong on a domestic client and the SdI's checks catch it within minutes. Get it wrong on a foreign one and nothing catches it at all, because there is no Italian register to fail against.

How Do You Send an Invoice to the SdI?

The four transmission channels

Four routes reach the SdI, per the Agenzia's own guidance:

1. Uploading a prepared XML file through the Fatture e Corrispettivi portal.
2. The free web procedure, or the Agenzia's own FatturAE app, which builds and sends the file without a separate upload step.
3. A PEC message with the XML attached, to [email protected] for the first transmission; the SdI's own reply names the address to use for anything that follows.
4. An accredited SFTP or web-service channel, set up in advance through a service agreement with the SdI, aimed at operators with high volume and a staffed system.

Why most non-resident founders appoint an intermediary

Portal access needs an Italian digital identity: SPID, CIE, CNS or Entratel/Fisconline credentials, none of which a non-resident director typically holds on day one. The statute allows an intermediary to transmit invoices on a supplier's behalf, and most non-resident founders use that route rather than acquiring Italian credentials of their own. Appointing an intermediary changes nothing about who is liable: the law is explicit that responsibility stays with the person who made the sale, whoever presses send on their behalf. Pick the channel that matches your own invoice volume rather than the one a software vendor recommends first; a founder issuing a handful of invoices a month has no real need for an accredited SFTP connection built to handle thousands.

What Happens After You Press Send?

One file, three possible outcomes, and a different clock attached to each.

The four checks the SdI runs, and the duplicate check

Agenzia delle Entrate: what the SdI does when it receives an invoice lists four checks run on every file:

1. The minimum particulars required by Art. 21 or 21-bis D.P.R. 633/1972.
2. The existence, in the Anagrafe Tributaria, of the supplier's VAT number and the buyer's VAT number or the tax code.
3. Whether CodiceDestinatario has been filled in at all.
4. The internal consistency of the taxable amount, the rate and the tax.

A fifth check, run alongside the other four, catches a file that duplicates one already processed.

Three receipts, and always exactly one of them

Processing takes minutes in the ordinary case, and up to 5 days when the SdI is handling unusually high volume. Whatever the timing, exactly one of three receipts follows: a delivery receipt, a rejection receipt, or a non-delivery receipt. Each carries its own identifiers and its own consequence, and none of the three is optional or skippable.

A rejection means the invoice was never issued, and you have five days to fix it

A rejection receipt arrives within 5 days of the SdI receiving the file, and it means the invoice, or the batch inside it, counts as not issued at all. A formally correct file is still rejected if the codice destinatario simply does not exist. The fix is a resend within 5 days of the rejection notice, keeping the original date and number rather than starting the invoice over from scratch.

The non-delivery asymmetry: issued for you, not yet received for them

A full PEC inbox, a channel that is down, or a 0000000 code with no fallback address all produce the same result: the SdI deposits a copy in the client's reserved area and issues a non-delivery receipt instead of a delivery one. The invoice then counts as issued for the supplier but not yet, for tax purposes, received by the client. Nothing in the SdI notifies the client directly, so a supplier who wants to be paid on time still has to pick up the phone or send an email outside the system.

There is no rejection button

Electronic invoicing introduced no mechanism letting a client refuse an invoice through the SdI. A dispute over the goods or the amount travels by ordinary correspondence, exactly as it did before 2019; the platform validates a file's form, not the underlying commercial relationship between the parties.

When Must an Invoice Be Issued?

Twelve days for an immediate invoice

Normattiva: D.P.R. 633/1972, Art. 21 fixes the ordinary deadline at 12 days from the date the operation is treated as carried out, a rule that has applied since 1 July 2019. "Issued" is read broadly: delivered, dispatched, transmitted or simply made available to the buyer all count equally.

The deferred invoice: the 15th of the following month

A supplier who can point to a documento di trasporto (delivery document), or equivalent proof for a service, buys more time. The deferred invoice covers everything supplied in the same calendar month to the same counterparty, issued by the 15th of the following month rather than within 12 days. The regulator's own reading of the rule is a practical one: it exists to give a business time to prepare and transmit the XML, provided the client already has a paper or electronic record of what was delivered.

Services to EU and non-EU taxable persons

Two more categories land on the same 15th-of-the-month date, under different paragraphs of the same article: services supplied to an EU taxable person that fall outside Italian VAT under Art. 7-ter, and services supplied to or received from a taxable person established outside the EU. A founder invoicing across borders ends up on one calendar in practice, regardless of which of the three rules technically applies. Miss any of the three and the invoice is simply late, a different problem from the one this page opened with, though not a smaller one: a late invoice still corrects itself under the same five-day discipline the SdI applies to a rejected one.

What Replaced the Esterometro?

Nothing about cross-border reporting was abolished. It moved inside the SdI itself, and the move is easy to miss if a founder is still looking for a separate quarterly form.

The obligation and its three exclusions

Art. 1(3-bis) D.Lgs. 127/2015 requires reporting on supplies made to, and received from, persons not established in Italy. Three categories fall outside it: transactions already declared to customs, transactions for which an electronic invoice already passed through the SdI, and purchases of no more than EUR 5,000 per transaction that have no Italian territorial relevance under Arts. 7 to 7-octies D.P.R. 633/1972.

Outgoing within the invoicing deadlines, incoming by the 15th

Outgoing data follows the same clock as the invoice itself: within 12 days, or by the 15th of the following month for a deferred one. Incoming data runs on a single fixed date, the 15th of the month after the document was received or the operation carried out. Building the outgoing file is often the simpler half, since an electronic invoice coded XXXXXXX clears the reporting duty for that transaction automatically, though it does nothing for the separate Intrastat forms.

What the register relief of Art. 1(3-ter) actually says, and what it does not

Art. 1(3-ter) of the decree releases anyone obliged to report invoice data from the register entries required by Arts. 23 and 25 D.P.R. 633/1972. Read that sentence for exactly what it says and no further: it is a statement of statutory wording, not an instruction to stop keeping the VAT registers a company relies on elsewhere, and no source found in this research reconciles the two provisions in operational terms.

How Long Must You Store Electronic Invoices, and Is Saving the XML Enough?

Conservazione a norma is a regulated process, not a backup

Both the issuer and the recipient of an electronic invoice must store it a norma (per the rules), an obligation Normattiva: D.P.R. 633/1972, Art. 39 places on each side independently. Saving the XML file on a laptop is not compliance. Conservazione a norma (compliant digital preservation) is a process regulated technically under the CAD, the Codice dell'Amministrazione Digitale, and it has to be run as such, whether through the Agenzia's own service or a certified provider.

Ten years is the floor, not the ceiling

Ten years from the last entry is the Civil Code minimum, under Art. 2220. Normattiva: D.P.R. 600/1973, Art. 22 then extends that period, for accounting records, until the tax assessments for the corresponding period are settled, even where that runs past the ten-year mark. A founder who deletes on a ten-year schedule alone is following only half the rule.

The Agenzia's free storage service, and its retroactive limit

The Agenzia delle Entrate stores every invoice that passes through the SdI free of charge, inside Fatture e Corrispettivi, and the statute bars its technology partner, Sogei S.p.A., from sub-contracting the service to anyone else. Signing up does not reach back indefinitely: the retroactive date cannot precede 1 January of the second year before the year of signature, so a company that waits three years to enrol loses the earliest invoices to the free service and has to arrange their storage another way.

Storing invoices abroad

Storage abroad is permitted on one condition: a mutual-assistance instrument has to exist between Italy and the country in question, and the Italian-established taxpayer has to guarantee automated access to the archive for control purposes, with everything in it printable and transferable on request.

What Are the Penalties for Getting E-Invoicing Wrong?

Issuing outside the SdI: the invoice does not exist, and the penalty follows

Normattiva: D.Lgs. 471/1997, Art. 6 sets the base penalty at 70% of the tax on any amount not correctly documented or recorded during the year, with a floor of EUR 300 under Art. 6(4). That figure is recent: it stood at 90% until D.Lgs. 87/2024 replaced it, and the lower rate applies only to breaches committed from 1 September 2024 onward.

Where the VAT settlement was unaffected, or the operation was non-taxable

A breach that left the correct VAT settlement untouched costs EUR 250 to EUR 2,000 instead of a percentage. Non-taxable, exempt, out-of-scope or reverse-charge operations carry their own rate, 5% of the consideration, or the same EUR 250 to EUR 2,000 range where the breach has no bearing even on income tax. Only one penalty applies per operation, whatever the number of duties it happened to breach at once.

The buyer's own exposure, and the 90-day TD29 escape

A buyer who receives no invoice, or an irregular one, is not a bystander. Art. 6(8) exposes the buyer to 70% of the tax with a minimum of EUR 250, unless the omission or irregularity is reported to the Agenzia within 90 days of the date the invoice should have arrived. That report travels through the SdI itself, as document type TD29, and it is a communication only: it does not let the buyer recover the VAT, it only stops the penalty clock from running.

Penalties on cross-border reporting

Missing or late cross-border data carries its own figure under Normattiva: D.Lgs. 471/1997, Art. 11(2-quater): EUR 2 per invoice, capped at EUR 400 a month, halved to EUR 1 per invoice and EUR 200 a month where the transmission, or the correction, reaches the SdI within 15 days of the deadline.

When Is Stamp Duty Due on an Electronic Invoice?

The EUR 2 rule and the EUR 77.47 threshold

Stamp duty on an electronic invoice is a flat EUR 2, regardless of what the invoice's own "Importo bollo" field states, and it is flagged with a "Bollo virtuale" annotation set to yes. The duty applies where the operation totals more than EUR 77.47 and the invoice carries a Natura code marking it out of scope, non-taxable or exempt: N2.1, N2.2, N3.5, N3.6 or N4.

The quarterly cycle and the four payment dates

Agenzia delle Entrate: stamp duty on electronic invoices publishes two lists inside Fatture e Corrispettivi by the 15th of the month after each quarter, with corrections to the second list due by the end of that month, except that the Q2 deadline of 31 July moves to 10 September. Payment itself falls due on four dates: 31 May, 30 September, 30 November and 28 February of the following year, by modello F24. Two deferrals soften small amounts: a Q1 bill of no more than EUR 5,000 can wait until 30 September, and a combined Q1-plus-Q2 bill of no more than EUR 5,000 can wait until 30 November.

Stamp duty is where the one-off mechanics of an invoice end. What follows, the monthly VAT settlement and the annual return that the invoice data feeds, belongs to Company in Italy: accounting services in italy rather than to this page.

From Our Practice: What Non-Resident Founders Get Wrong First

Three mistakes recur often enough to name, and none of them is a difficult legal question.

A supplier treats an emailed PDF as a valid invoice, complete in every field except the one that matters: it never passed through the SdI, so in law it never existed, and the Art. 6 D.Lgs. 471/1997 penalty attaches regardless of how carefully the PDF was prepared.

A company never registers a default telematic address in Fatture e Corrispettivi, so the SdI keeps delivering to whatever a supplier happens to write, and a lapsed inbox turns into a compliance gap that nobody notices until year-end.

A founder assumes that appointing a bookkeeper or a software provider to transmit invoices moves the liability off the company. It does not: the statute keeps responsibility with the party that made the sale, whoever actually presses send on their behalf.

The rules, articles and figures above are given as in force at the update date shown at the top of this page. A specific company's position should be checked against the current text and, where the wording is silent, against the Agenzia delle Entrate directly.

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