Sending, SdI checks, receipt and storage

A wholesaler in Brescia sends a 12,200 € invoice through the SdI with one digit of the customer's VAT number wrong. A few hours later a rejection receipt comes back. That invoice was never issued. A second invoice, sent the same day, went through but reached a full PEC mailbox: that one counts as issued, though the customer may not know it exists.

Four ways to reach the SdI

Electronic invoices must always reach customers through the SdI; otherwise they are considered not issued. The guide lists four ways of transmitting the XML file. They differ in effort and in volume, not in legal effect: an invoice accepted by the SdI counts the same whichever channel carried it.

• An online service on the Fatture e Corrispettivi portal that uploads an XML file prepared beforehand
• The web procedure or the FatturAE app, which prepare and send the file in one go
• A certified e-mail (PEC) with the XML attached, sent to sdi01@pec.fatturapa.it
• A telematic channel, SFTP or Web Service, activated beforehand with the SdI

The business may send its invoices itself or have a third party do it, usually an intermediary or a provider of e-invoicing services. The SdI accepts invoices from a PEC or a channel that the business does not run directly. A business without its own PEC may agree with its intermediary to send the file from theirs.

The SFTP or Web Service channel is for a different scale. It connects the company's servers permanently to the SdI and suits businesses with a high degree of computerisation, staff to watch it continuously, and a very large number of invoices. Activating it requires a service agreement, requested through an online accreditation form.

The guide's advice for a small business is short: if you send a few invoices a day, a PEC or the web service of the portal is enough. The accreditation form and its technical details belong to annex A of the measure of 24 November 2022, and are not a small business's concern.

What the SdI checks

Once the file reaches the SdI, the system runs a set of checks. If they pass, it forwards the file to the electronic address stated in the invoice. The guide gives the timing: from a few minutes up to a maximum of 5 days when the number of invoices being processed is very high.

• The minimum mandatory data of article 21 or 21-bis of Presidential Decree 633/1972 are present
• The supplier's VAT number and the customer's VAT number or tax code exist in the tax register
• The recipient code field is filled in
• Taxable amount, rate and tax are consistent with one another
• The same file has not already been sent

The minimum data, in general terms, are the identifiers of supplier and customer, the invoice number and date, the description of the nature, quantity and quality of the goods or services, the taxable amount, the rate and the VAT. The first module showed where each of them is entered.

The consistency check is arithmetic. The guide's own illustration: with a taxable amount of 100 euros and a rate of 22 %, the SdI checks that the VAT is 22 euros. An invoice whose tax does not match its base and rate does not get through, which catches typing errors before the customer sees them.

A digital signature is not required. For invoices to VAT-registered parties or to final consumers, the SdI also accepts unsigned files. If the file is signed, however, the SdI checks that the signing certificate is valid, so a signature with an expired certificate can cause a rejection that an unsigned file would have avoided.

Three receipts and what they mean

Whatever the outcome of the checks, the SdI sends a receipt to whoever transmitted the file. There are three kinds: rejection, delivery, and impossibility of delivery. They can be consulted in the dedicated area of the Fatture e Corrispettivi portal, and each one settles the invoice's status.

If one or more checks fail, the SdI rejects the invoice and sends a rejection receipt, the ricevuta di scarto, with an error code and a short description. The receipt goes back to the same PEC or channel the file came from. For invoices sent with the Agenzia's free services, it can be seen only on the portal.

A rejected invoice has never been issued. The error must be corrected and the file sent again. The guide advises recompiling the invoice with the same date and number as the rejected one, but changing the file name if the invoice is not produced with the portal's web procedure. The reference is circular 13/E of 2 July 2018.

If the checks pass, the SdI delivers the invoice to the address in the Codice destinatario and PEC destinatario fields, and sends the transmitter a delivery receipt. That receipt carries the date on which the recipient received the file, the IdSdI identifier, the file name given by whoever prepared it, and a hash code guaranteeing the file's integrity.

The third receipt covers a file that passed the checks but could not be delivered: a full PEC mailbox, an SFTP or Web Service server temporarily unavailable, or a recipient code of 0000000. Reading the customer's VAT number or tax code, the SdI then places a duplicate of the invoice in the customer's reserved area on the portal.

The transmitter then receives a receipt of impossibility of delivery, stating the date on which the file was made available to the customer on the portal. The guide draws the consequence: the invoice counts as issued for the supplier, but not yet definitively received, for tax purposes, by the customer.

Issued for one, received for the other

For VAT, the guide summarises the dates. For the supplier, whenever the SdI sends a delivery receipt or a receipt of impossibility of delivery, the invoice counts as issued, and the date on which the tax becomes chargeable is the date shown on the invoice.

For the customer, a delivered invoice counts as received, and the VAT can be deducted from the date of delivery. If the invoice passed the checks but could not be delivered, the date from which the VAT can be deducted is the date on which the customer viewed it in the reserved area of the portal.

The gap between the two dates is where the supplier has a duty of care. The guide asks the supplier to tell the customer, by means other than the SdI, such as e-mail or telephone, that the invoice is waiting in the reserved area. Until the customer looks, the customer cannot deduct the VAT on it.

A supplier who ignores the receipt of impossibility of delivery loses nothing on the VAT side, since the invoice is issued anyway. The customer loses time on the deduction and may not even know the invoice exists, which is how payment delays begin. A short message after each such receipt costs less than a reminder later.

Receiving your own purchase invoices

When the checks pass, the SdI delivers to the address written in the invoice, whether or not that address belongs to the customer directly. A business can receive at its own PEC, at its own SFTP or Web Service channel, or through an intermediary. What it cannot do is leave the choice to chance.

To be sure of receiving invoices, the guide says, a business must tell each supplier clearly and promptly not only its VAT number and details, as with paper invoices, but also its electronic address: a PEC, or a 7-character recipient code. The supplier writes that address into the invoice, and the SdI follows it.

Two services on the portal make this sturdier. The first registers, against the VAT number, the address at which all invoices are to be received. Once registered, that address prevails over whatever the supplier writes in the invoice: the SdI delivers to the registered address. One registration replaces dozens of instructions to suppliers.

The second generates a QR code containing the VAT number, the business's details and the registered address. Shown to a supplier, much like a health card at a pharmacy, it lets the supplier capture the data automatically when using the Agenzia's procedures or software that reads QR codes, without typing errors.

Consultation is not storage

All invoices and credit notes correctly issued and received through the SdI can be consulted on the portal, under Fatture elettroniche e altri dati Iva. The guide separates this from storage. Consultation is for day-to-day work around issue and receipt: checking against orders, bookkeeping, collections and payments.

Consultation also has a time limit. Invoice files remain viewable until 31 December of the second year after the year in which the SdI received them. After that, only the invoice data remain available, until 31 December of the eighth year after the year in which the relevant return was filed. A consultation area is not an archive.

Storage is another obligation. Under article 39 of Presidential Decree 633/1972, both the issuer and the recipient of an e-invoice must store it according to the rules, a conservazione a norma. That is not saving the file on a PC: it is a process governed technically by the Digital Administration Code, the CAD.

The process guarantees, over the years, that invoices are never lost, can always be read, and that the original can be retrieved at any time, for instance to produce it in a dispute. Certified private operators offer it; the Agenzia also offers it free of charge for all invoices issued and received, from the portal's reserved area.

The free service is activated under Fatturazione elettronica e Conservazione, by signing a service agreement. Invoices that passed through the SdI before joining can be brought in by choosing a start date, which cannot be earlier than 1 January of the second year before joining. Without such a date, storage starts on the day after joining.

The same consultation area also carries a link for paying stamp duty on e-invoices, where the business sees lists A and B and the amount to pay, and may amend list B proposed by the Agenzia. The rules on when stamp duty is due are set out in the Agenzia's separate guide and are not covered here.