Electronic Invoicing in Italy: Who Does What, Step by Step

01

Who Does What in Electronic Invoicing

In Italy, electronic invoicing has been mandatory since 1 January 2019 for B2B and B2C transactions between parties resident or established in the country, and since 31 March 2015 for B2G transactions with Public Administration (citation-1). The technical rules for preparing, transmitting, receiving and archiving invoices between private parties are set out in measure no. 433608 of 24 November 2022, while invoices to Public Administration follow Ministerial Decree no. 55/2013 (citation-2). Assigning distinct responsibilities for each stage - preparation, checking, sending, archiving - allows an organisation to distribute these tasks consistently with official rules, reducing the risk of errors or omissions.

02

Exceptions That Require Dedicated Oversight

For invoices issued to foreign parties, and for self-invoices or VAT integrations related to purchases from foreign parties, issuing an electronic invoice remains optional (citation-1). Those who decide not to issue one must still transmit the data to the Revenue Agency through the 'esterometro', with two exceptions: transactions already supported by a customs declaration and purchases not exceeding 5,000 euros (citation-1). Defining who follows these particular situations prevents less frequent, but still binding, obligations from being forgotten within the normal invoicing flow toward Italian customers.

03

The Operational Stages to Assign

Steps

1. Preparation: whoever fills out the invoice uses a PC, tablet or smartphone and software that generates a compliant XML file (citation-3).
2. Supplier check: on the first invoice, the supplier's data retrieved from the Tax Registry is checked, and it can be modified except for the VAT number (citation-0).
3. Customer check: whoever enters the customer's data checks that the VAT number or tax code exists in the Tax Registry (citation-0).
4. Sending: the person responsible for transmission chooses between the portal, the FatturAE App, certified email (PEC), or the SFTP/Web Service telematic channel toward SdI (citation-4).
5. Archiving: whoever handles storage uses the Agency's free services or software compliant with the 2022 measure (citation-2).

04

A Hypothetical Case of Task Division

Hypothetical example: in a small professional firm, the administrative assistant prepares the invoice with management software in the required XML format, the owner checks the supplier's data on the first entry, verifying that everything is correct except the VAT number, and a colleague sends the file via certified email to sdi01@pec.fatturapa.it (citation-0, citation-4). Before sending, the same colleague checks that the customer's tax code exists in the Tax Registry, since otherwise the Exchange System would reject the invoice (citation-0). This division reflects the stages set out by the regulations without overlap between those who prepare and those who transmit.

05

Checks to Assign Before Sending

• Check the supplier's data on the first invoice, correcting everything except the VAT number (citation-0).
• Verify the customer's VAT number or tax code exists in the Tax Registry (citation-0).
• Choose a transmission channel among the portal, FatturAE App, PEC, or SFTP/Web Service (citation-4).
• Use the 'Resume last file' or 'Import from XML file' functions to correct previous invoices (citation-4).
• Check whether the transaction falls among those with optional invoicing that require the 'esterometro' (citation-1).

06

Setting Up Roles With a Software Partner

A company can ask its software partner to configure distinct roles for preparing the XML file, checking the supplier's and customer's registry data, sending via SdI, and archiving, so as to reflect the stages set out by the regulations (citation-2, citation-3, citation-4). It is useful to keep a record of who checked the data before sending and to include a review step before transmission to the Exchange System, so that no invoice is sent without a check (citation-0). These are suggested operational choices for organising work, not legal requirements imposed by the software.

07

Frequently Asked Questions About Operational Roles

• Electronic invoicing has been mandatory for B2B and B2C transactions since 1 January 2019 and for B2G since 31 March 2015 (citation-1).
• For invoices to foreign parties, electronic issuance is optional, but the 'esterometro' is required except for specific exceptions (citation-1).
• Sending must always go through the Exchange System, otherwise the invoice is not considered issued (citation-4).

08

The Next Operational Step

Define in writing who prepares the XML file, who checks the supplier's and customer's registry data, who chooses the sending channel to SdI, and who handles invoice archiving, referring to the stages and channels set out by the regulations (citation-2, citation-3, citation-4). Documenting this division helps maintain consistency even when staff involved in the invoicing process changes.