Electronic invoicing in Italy: how to assign responsibilities in the process

01

Who does what in the electronic invoice cycle

The process is split into three distinct responsibilities: who checks and prepares the invoice data, who transmits it to the Exchange System (SdI), and who ensures compliant archiving over time. Since January 1, 2019, this process applies to all supplies of goods and services between parties resident or established in Italy, both B2B and B2C, in addition to the B2G obligation already in force since 2015.

02

The relevant regulatory scope

The rules for preparing, transmitting, receiving and archiving electronic invoices between private parties are set out in measure no. 433608 of November 24, 2022. For invoices to the Public Administration, the rules of Ministerial Decree no. 55/2013 remain valid. Transactions with foreign parties are optional for e-invoicing, but require data transmission through the esterometro, except for customs-supported transactions or purchases up to 5,000 euros.

03

Recommended operational flow by role

Steps

1. Supplier data manager: checks the supplier's data in 'My Data' the first time the procedure is used, editable except for the VAT number.
2. Customer data manager: enters the customer's data; the procedure verifies in real time its existence in the Tax Registry.
3. Preparer: fills in the XML file using a PC, tablet or smartphone with software compliant with the technical specifications of the 2022 measure.
4. Sender: transmits the XML file to the SdI via the portal, the FatturAE App, PEC to sdi01@pec.fatturapa.it, or an activated SFTP/Web Service channel.
5. Archiving manager: ensures invoices are archived compliantly, securely and unalterably over time.

04

Hypothetical example of role assignment

Hypothesis: a professional firm with three people assigns supplier data verification to administration, invoice preparation to a staff member who uses the 'Invoices and Receipts' web procedure, and SdI sending to the accounting manager, who also oversees long-term archiving of the transmitted XML files.

05

Checks before sending

• The supplier's data in 'My Data' is correct, except for the non-editable VAT number.
• The customer's VAT number or tax code exists in the Tax Registry.
• The XML file complies with the technical specifications of the November 24, 2022 measure.
• The chosen sending channel (portal, App, PEC or SFTP/Web Service) is correctly activated.
• The invoice has been transmitted via SdI, the only method that certifies its issuance.

06

How to set up roles in a management software

A company can ask its software partner to configure distinct roles for supplier/customer data verification, XML file preparation, sending via SdI, and compliant archiving, with traceability of who performed each step. This is a suggested operational choice, not a legal requirement: the goal is to reduce transmission errors and ensure that any invoice rejected by the SdI due to non-existent identification data is quickly detected and corrected.

07

Frequently asked questions

Who can edit the supplier's data in the web procedure? All data except the VAT number, checked the first time and then saved for subsequent invoices.

What happens if the customer's tax code does not exist in the Tax Registry? Compilation is blocked, and if the invoice were still transmitted with a non-existent identifier, the SdI would reject it.

Which channels are valid for sending to the SdI? The online portal, web procedure or FatturAE App, PEC to the dedicated address, or a previously activated SFTP or Web Service channel.

08

Next step

Map the roles in your electronic invoicing process against this flow and check with your software provider how to trace each step, from preparation to archiving.