On January 1, 2019, electronic invoicing became mandatory in Italy, in accordance with Law No. 205 of December 27, 2017. An electronic invoice is a commercial document created digitally in XML format, following the guidelines set by the Agenzia delle Entrate (the Italian Revenue Agency). Here, the word “digitally” means that the invoice must be originally created in a digital format—not just a scanned copy of a paper invoice.

Until the end of 2023, mandatory electronic invoicing did not apply to the flat-rate tax regime (“regime forfettario”), but it did impact most other taxpayers. However, as of January 1, 2024, electronic invoicing became mandatory for all taxpayers using the flat-rate regime.

In order for an invoice to be formally considered to have been issued, electronic invoices must be sent to customers via the Exchange System (SdI, from the Italian “Sistema di Interscambio”) operated by the Agenzia delle Entrate. The “date of issuance” is the date the invoice is submitted to the Exchange System. In this article, you will learn more about the flat-rate e-invoice, how e-invoices are filled out, and the penalties for late issuance.

What’s in this article?

• Introduction of mandatory electronic invoicing for flat-rate regime taxpayers
  
• Compiling and sending electronic invoices for the flat-rate tax regime
  
• Mandatory electronic invoice storage for flat-rate regime taxpayers
  
• Penalties for late submission of electronic invoices for flat-rate taxpayers
  

Introduction of mandatory electronic invoicing for flat-rate regime taxpayers

As of July 1, 2022, the provisions of Article 18(2) and (3) of Decree Law No. 36/2022, made electronic invoicing mandatory for flat-rate regime taxpayers whose revenue exceeded €25,000 in the prior year. Flat-rate regime taxpayers who earned less than €25,000 in 2021 were eligible for a transitional regime and were exempt from this requirement.

The transitional regime ended in 2023, and electronic invoicing became mandatory for all flat-rate taxpayers beginning January 1, 2024—regardless of their revenue or compensation in the previous year.

Compiling and sending electronic invoices for the flat-rate tax regime

Taxpayers under the flat-rate regime can use various free tools that the Agenzia delle Entrate provides or paid services that market providers offer. The free tools that the Agenzia delle Entrate provides are as follows:

• A web-based process for preparing and sending electronic invoices, accessible through the Fatture e Corrispettivi (Invoices and Receipts) portal
  
• PC software available on its website allows you to prepare and save electronic invoice files
  
• An app called “FatturAE”" is available in the iOS and Android stores, allowing you to transmit electronic invoices
  

Sender data

After selecting your e-invoicing tool or software for flat-rate taxpayers, the first section to complete on the e-invoice is the sender information:

• Company/DBA name, first and last name, address
  
• Value-added tax (VAT) number
  
• Tax regime (select RF19 for the flat-rate regime)
  
• Social security fund
  

Recipient data

• Company/DBA name, first and last name, address
  
• VAT number
  
• Recipient code or unique code
  
  • This is one of the key elements that differentiates an electronic invoice from a paper invoice. It is a code that identifies the recipient of the invoice and helps the Exchange System to deliver it. It consists of 7 digits for business-to-business (B2B) or business-to-consumer (B2C) invoices (between private parties) and 6 digits for Public Administration invoices. If you issue an invoice to a private individual without a VAT number, enter the standard code “0000000” (7 zeros) in the “CodiceDestinatario” (Destination Code) field and specify only the “CodiceFiscale” (Fiscal Code). To find a unique code, you can use public databases such as the IPA (Index of Public Administrations) portal or ask the customer directly. Alternatively, you can search for the recipient code of individuals and companies on the Agenzia delle Entrate website under “Fatture e Corrispettivi” (Invoices and Receipts).
    

Invoice data

• Sequential number: Sequential numbering for invoices continues just as it did for paper invoices. Even if previous invoices were on paper, the next one can simply follow the same sequential numbering, whether it’s a physical or electronic invoice.
  
• Date
  
• Products and services: Specify the number of units sold, the price, and the VAT type code N2.2 (for items not subject to VAT, as the flat-rate scheme is VAT-exempt).
  
• Payment data
  

Virtual stamp duty

For invoices over €77.47, flat-rate taxpayers must add €2 stamp duty. With paper invoices, you had to physically apply the stamp duty on each invoice. With electronic invoicing, you can find a list of invoices subject to stamp duty and the total amount to be paid at the end of each quarter in your personal dashboard on the Agenzia delle Entrate website. You can pay by providing your International Bank Account Number (IBAN) or using Form F24.

Addition of mandatory wording

There is some mandatory wording that flat-rate regime taxpayers must include in their invoices. Most tools for creating electronic invoices for the flat-rate tax regime let you save this information, so that it is prefilled for subsequent invoices.

The mandatory wording for those in the flat-rate tax regime is:

• Transaction without application of VAT, made according to Article 1, paragraphs 54 to 89, of Law No. 190 of 2014, as updated by Law No. 208 of 2015 and Law No. 145 of 2018. (in Italian, “Operazione senza applicazione dell’IVA, effettuata ai sensi dell’articolo 1, commi da 54 a 89, l. n. 190 del 2014 così come modificato dalla l. n. 208 del 2015 e dalla l. n. 145 del 2018.”)
  
• The fee is not subject to withholding tax according to Law 190, Article 1, paragraph 67, of December 23, 2014. (in Italian, “Il compenso non è soggetto a ritenute d’acconto ai sensi della Legge 190 del 23 dicembre 2014 art. 1 comma 67.”)
  

Sending the electronic invoice to the client

Flat-rate taxpayers send e-invoices via the online service or dedicated e-invoicing software. Each completed e-invoice is converted into XML format by the flat-rate e-invoicing software and then sent to the Exchange System (SdI). The SdI receives the e-invoice and verifies that it contains all the required basic data. If the data is incorrect, the SdI sends a notification and cancels the invoice, which must then be reissued. If the data is correct, the invoice is sent directly to the recipient. The Agenzia delle Entrate is responsible for sending the electronic invoice to the customer, but it is advisable to send a copy directly to the customer.

Some tools help you automate the invoicing process, such as Stripe Invoicing, a comprehensive and scalable invoicing platform that lets you create and send both one-time and recurring payment invoices without writing a single line of code. With Stripe, you can save time and get faster payments, as 87% of Stripe invoices are collected within 24 hours. Thanks to collaboration with third-party partners, you can also use Stripe Invoicing for electronic invoicing.

Mandatory electronic invoice storage for flat-rate regime taxpayers

All flat-rate taxpayers are required to digitally store invoices in compliance with legal regulations. According to Article 39 of Presidential Decree No. 633/1972, both the issuers and the recipients of electronic invoices are required to store them electronically. This doesn’t mean simply storing them on a computer—there is a legally regulated process for digital storage, which eliminates the need to print and store invoices, reducing the risk of loss or damage. This type of storage is called “substitute archiving” (“conservazione sostitutiva”) because it replaces the paper invoice.

Taxpayers can either use private operators accredited as conservators with the Agenzia per l’Italia Digitale (AgID, Italian for “Agency for Digital Italy”) or take advantage of the free solutions the Agenzia delle Entrate provides through the Fatture e Corrispettivi portal, which archives invoices for 15 years.

Penalties for late or nonsubmission of electronic invoices from flat-rate taxpayers

In the event of late or nonissuance of an electronic invoice for the flat-rate scheme, taxpayers are subject to penalties between 5% and 10% of the incorrectly documented or registered receipts or invoices. However, when the breach is not relevant for the purpose of determining income, an administrative penalty ranging from a €250 minimum to a €2,000 maximum applies.

The deadlines for issuing electronic invoices for flat-rate taxpayers in 2024 are the same as for other taxpayers:

• Immediate invoice: Immediate invoice deadlines are up to 12 days after the date of the transaction.
  
• Deferred invoice: Deferred invoice deadlines are by the 15th day of the month following the date of the transaction.
  

The penalty can be greatly reduced by using voluntary disclosure (“ravvedimento operoso”), which allows taxpayers to voluntarily correct omitted or insufficient payments to the tax authorities. For further questions, we always recommend contacting your accountant to ensure tax compliance with electronic invoicing for flat-rate regime taxpayers.