E-invoicing: how to assign responsibilities in the process, from preparation to sending to the SdI

01

Four tasks, four owners

Responsibility for e-invoicing can be split across four distinct tasks: who prepares the data, who verifies the customer's records, who generates the XML file, and who transmits it to the Exchange System (SdI). The first time a procedure is used, the supplier's data retrieved from the Tax Register must be checked, all of which can be edited except the VAT number.

If the customer's VAT number or tax code does not exist in the Tax Register, the invoice is rejected by the SdI: assigning this check to a specific person reduces rejections.

02

The regulatory framework

Since 1 January 2019, the e-invoicing requirement has applied to B2B and B2C transactions between parties resident or established in Italy; for transactions with Public Administration, the obligation had already been in force since 31 March 2015. The rules for preparing, transmitting, receiving and storing e-invoices between private parties are set out in provision no. 433608 of 24 November 2022, while for invoices to Public Administration the rules of Ministerial Decree no. 55/2013 still apply.

03

The sequence of tasks

Steps

1. Preparation: complete the XML file with the minimum data required by art. 21 of Presidential Decree no. 633/1972, using the web procedure, downloadable software, or the FatturAE App.
2. Supplier check: on first use, verify the supplier's data retrieved from the Tax Register; only the VAT number cannot be changed.
3. Customer check: enter the customer's data; the procedure verifies in real time whether the VAT number/tax code exists in the Tax Register.
4. Sending: transmit the XML file to the SdI via the portal, web procedure, FatturAE App, certified email (PEC) to sdi01@pec.fatturapa.it, or an SFTP/Web Service channel.
5. Storage: store invoices in a compliant, secure and unalterable way using the Agency's free services or software conforming to the technical specifications.

04

A hypothetical case of role assignment

In a hypothetical case, an Italian SME assigns invoice preparation to the administrative team, customer data verification to a sales manager who knows the counterpart, and sending via SFTP channel to whoever manages the information systems. If the customer has a VAT number that does not exist in the Tax Register, the sales manager corrects it before the invoice is rejected by the SdI.

05

Checks to assign before sending

• Verify the supplier's data retrieved from the Tax Register, except for the VAT number, which cannot be changed.
• Check that the customer's VAT number or tax code exists in the Tax Register.
• Choose the transmission channel to the SdI: portal, web procedure, FatturAE App, PEC, or SFTP/Web Service channel.
• Verify that the software and services used comply with the specifications of the provision of 24 November 2022.

06

How management software can make the process traceable

Management software can be configured to show who prepared an invoice, who verified the customer's data, and who sent it to the SdI, tracking responsibility at each step. This is a suggested operational choice: defining a role for records verification before sending helps catch cases where the VAT number or tax code does not exist in the Tax Register, avoiding rejection by the SdI.

07

Frequently asked questions about roles

• Who should verify the supplier's data? Whoever uses the procedure for the first time, since all data can be changed except the VAT number.
• Who checks the customer's VAT number? Whoever enters the customer's data, since the procedure verifies its existence in the Tax Register in real time.
• Who chooses the sending channel? Whoever manages the information systems, choosing between the portal, web procedure, FatturAE App, PEC, or SFTP/Web Service channel.

08

The practical next step

Map the four tasks - preparation, supplier check, customer check, sending - to defined people or roles in your company, verifying that the software used complies with the provision of 24 November 2022.