Italian E-Invoicing (SDI) Explained for Foreign-Owned Companies

Italy does not merely allow electronic invoicing: for domestic transactions it requires it, and it routes every invoice through a government clearing platform. A foreign-owned SRL must therefore issue Italian XML invoices through the Sistema di Interscambio (SDI) for everything it sells to Italian customers, and pull invoices from its foreign suppliers into the same channel even though those suppliers sit outside it. This guide covers the codes, the cross-border rules, storage and the penalties; for the wider tax picture see Italian taxes for a foreign-owned company and the codice fiscale and VAT guide for non-residents.

What the Sistema di Interscambio actually is

The SDI is the platform, run by the Agenzia delle Entrate for the Ministry of Economy and Finance, through which electronic invoices are transmitted, checked and delivered. Article 1 of Legislative Decree 127/2015 provides that supplies between subjects resident or established in Italy are invoiced exclusively with electronic invoices using the SDI and the prescribed XML format, commonly called FatturaPA. The technical rules are set by the Agenzia's provvedimento of 24 November 2022, no. 433608; the current specification is version 1.9.1, usable from 15 May 2026. Private-sector invoices use the FPR12 format, invoices to public bodies FPA12.

The SDI is not a passive mailbox. It checks the mandatory invoice data, the existence of the parties' VAT numbers in the Italian tax register, the delivery address in CodiceDestinatario, the consistency of taxable amount, rate and VAT, and duplicates. It then returns a receipt of delivery, or a rejection with an error code to correct and re-transmit. If the checks pass but the channel is unavailable — or the code is 0000000 — it issues a receipt of impossibility of delivery and makes the invoice available in the recipient's reserved area.

Two dates matter. From 1 January 2027 the rules in article 1 of Legislative Decree 127/2015 move into the new VAT Testo Unico, approved by Legislative Decree 10/2026; Normattiva records that article as repealed from that date, so references change in form, not substance. Italy's power to impose a mandatory system rests on an EU derogation, Council Implementing Decision (EU) 2018/593 as amended, valid to 31 December 2027.

Who must issue electronic invoices

The rule turns on where the two parties are established, not on who owns the company. A foreign-owned SRL is an Italian VAT holder, so it is inside the regime from its first Italian invoice.

Situation	Electronic invoice through SDI?
Italian SRL invoicing an Italian business (B2B)	Mandatory
Italian SRL invoicing an Italian consumer (B2C)	Mandatory
Italian SRL invoicing an Italian public body (B2G)	Mandatory, using the 6-character Codice Univoco Ufficio
Italian SRL invoicing a customer outside Italy	Optional; if not used, the transaction data must still be transmitted
Forfettario (flat-rate) Italian taxpayer	Mandatory since 1 January 2024
Non-resident business merely identified in Italy for VAT	Not obliged to issue or receive e-invoices, but its Italian suppliers must invoice it electronically

The B2B and B2C obligation dates from 1 January 2019 and covers supplies between VAT holders as well as to final consumers; B2G is older, from 2015, and flat-rate taxpayers are fully covered from 1 January 2024. The exemptions are narrow — small agricultural producers, and taxpayers dispensed from invoicing exempt operations — and invoices for healthcare services to final consumers must not go through the SDI.

One point causes repeated confusion. A non-resident company that holds only an Italian VAT position — through direct identification or a fiscal representative — is not itself required to issue or receive e-invoices, but its Italian suppliers must invoice it electronically, normally with 0000000 unless it gives them a specific channel. The parent's Italian VAT number can therefore receive invoices it cannot easily read without a channel or a delegate.

The recipient code, the PEC and the conventional codes

CodiceDestinatario carries a seven-character alphanumeric code identifying the telematic channel on which the recipient wants to receive invoices. It is not issued by the tax authority: it is assigned by the software provider operating the accredited channel and registered with the SDI, which is why many customers of one provider share a single code. There is no public register for private businesses; you obtain it from the customer, from the customer's accountant, or from your invoicing software. Our Italian-language tool to look up a VAT number and its VIES status and the Italian guide on how to find the codice SDI cover the practical routes.

Code	When it is used
The customer's 7-character code	The recipient has communicated its channel
0000000 plus the PECDestinatario field	The recipient receives invoices at a certified email (PEC) address
0000000 alone	A final consumer, or a VAT holder that has communicated neither a code nor a PEC
XXXXXXX	A customer resident outside Italy
The 6-character Codice Univoco Ufficio	An Italian public body, taken from IndicePA
2R4GTO8	A San Marino VAT operator, through its Tax Office channel

With 0000000 the invoice is still validly issued: the SDI makes it available in the recipient's reserved area — the "Fatture e Corrispettivi" portal for VAT holders, the tax drawer for consumers — but the issuer must still deliver a courtesy copy, because nothing arrives in the customer's accounting software. A VAT holder may also register a default telematic address against its VAT number, and that registered address prevails over what the supplier writes in the file, which is why a wrong code does not always mean a lost invoice.

Invoicing a foreign customer

Supplies to customers outside Italy are the part of the system where the obligation is optional but the reporting is not. The company either issues the invoice through the SDI, or issues it outside the system and transmits the transaction data to the SDI within the legal deadline. If the SDI route is used, the file must be built correctly:

• CodiceDestinatario = XXXXXXX.
• In the customer block, IdFiscaleIVA: IdPaese is the foreign country code in ISO 3166-1 alpha-2, and IdCodice is the counterparty's foreign identifier, up to 28 characters, on which the SDI performs no validity check. For a foreign consumer, complete only IdCodice and leave CodiceFiscale empty.
• For a foreign address, select the country and use 00000 as the postal code rather than an Italian province. Amounts in the summary block are read in euro; an Italian-issued invoice is expected to carry EUR in the currency field, with any foreign-currency figure as additional data.

The invoice is deemed issued when transmitted, and the SDI receipt — of delivery or impossibility of delivery — evidences it; since a foreign customer cannot receive from the SDI, the file must be accompanied by a copy sent by other means. Under article 21(4) of Presidential Decree 633/1972 the invoice is issued within twelve days of the transaction; for goods supported by a transport document, and for services identifiable from suitable documentation, a single deferred invoice may be issued by the fifteenth day of the following month. Where the SDI is not used for a cross-border sale, the data transmission is due by the same deadline as the invoice.

Recording invoices received from foreign suppliers

This is the part that surprises foreign owners most. A foreign supplier sits outside the Italian system and will send a normal invoice, in PDF or on paper, with no VAT because the transaction is taxed in Italy under the reverse charge. The Italian company must bring that document into the SDI itself, to account for the VAT and to satisfy the cross-border reporting obligation that replaced the old quarterly esterometro from 1 July 2022. The instrument is an integration of the supplier's invoice, or a self-invoice, transmitted through the SDI with a dedicated document type:

Code	What it covers
TD17	Services purchased from a supplier outside Italy (EU and non-EU)
TD18	Intra-EU purchases of goods
TD19	Purchases of goods under article 17(2) of the VAT decree (non-EU goods, and cases where the goods are already in Italy)
TD20	Regularisation and integration under article 6(9-bis), Legislative Decree 471/1997, or article 46(5), Decree-Law 331/1993
TD28	A paper invoice from San Marino carrying VAT

These documents are delivered only to the issuer, which is the party accounting for the tax, and they feed the Agenzia's pre-filled VAT registers: transmitting them is what makes the draft registers and the pre-filled return usable. The deadline is in article 1(3-bis)(b) of Legislative Decree 127/2015: by the fifteenth day of the month following receipt of the document evidencing the transaction, or following the transaction itself, in line with the registration deadline of article 25 of the VAT decree. For an intra-EU service, the document date is the date of receipt of the supplier's invoice, or a date within the month of receipt; for an extra-EU service, or a San Marino or Vatican City supplier, it is the date the transaction was carried out. One trap: the reverse charge, and therefore TD17, does not apply where the non-resident supplied the service through an Italian permanent establishment, because then the non-resident is itself the debtor of the tax.

Storage, and what the Agenzia does for free

Both issuer and recipient must store electronic invoices. The obligation comes from article 39 of Presidential Decree 633/1972, and the technical rules are in the ministerial decree of 17 June 2014. The period runs until 31 December of the eighth year following the year in which the relevant VAT return is filed — the "ten years" usually quoted in practice. Storage is a regulated process, not a folder of PDFs: the original file must remain retrievable and readable over time.

The Agenzia provides a free storage service for e-invoices that have passed through the SDI, from the reserved area of the "Fatture e Corrispettivi" portal, and where it stores the files the storage obligation is treated as satisfied for them. Certified private operators are the alternative. Consultation and storage are different: invoice files remain available for consultation until 31 December of the second year after the SDI received them, and after that only the invoice data, until the eighth year. If group reporting depends on downloading original XML files, build the export into the process rather than assuming the portal will hold them indefinitely.

San Marino: the short version

San Marino is the one non-Italian territory inside the SDI flow for business-to-business transactions. Since 1 July 2022 the electronic invoice is mandatory for supplies of goods between Italian and San Marino VAT operators, through the San Marino Tax Office's accredited channel, identified by the recipient code 2R4GTO8. Invoices to private individuals resident in San Marino instead use XXXXXXX, and a paper invoice from San Marino carrying VAT is brought into the system with document type TD28.

How the foreign parent actually sees the invoices

The invoices are not pushed to the shareholder. Everything lives in the reserved area tied to the Italian VAT number, and access requires Italian credentials: SPID, CIE, CNS, or Fisconline/Entratel. The portal is then used under one of four profiles — as the taxpayer itself, as an appointee, under a direct delegation, or as a guardian. Delegation is the normal route for a foreign-owned group: the taxpayer can delegate to an intermediary such as an accountant, and the Agenzia's guidance confirms that the e-invoicing and storage services can also be delegated to subjects other than the traditional intermediaries, through the single delegation regime introduced by the provvedimento of 2 October 2024. A delegated accountant can prepare and transmit invoices, manage storage, consult the receipts and generate the VAT QR code.

For group reporting, three mechanisms do the work in practice: a mass download of invoice files and receipts from the portal; the provider's or ERP's channel, where the Italian company uses an accredited intermediary that also feeds the group system; and an export from the storage service, the safest source for original files in a group audit. Two warnings: the SDI is not a group reporting tool, so do not assume the parent's accounting system will receive Italian e-invoices automatically; and where the company is managed from abroad, whoever holds the credentials matters, because losing access means losing the receipts that evidence issuance.

Common mistakes, and what they cost

• A stale or wrong recipient code. It changes when the customer changes software provider; without a registered telematic address the invoice sits in the reserved area unnoticed.
• Assuming a foreign customer can receive from the SDI. It cannot; the file needs a copy sent outside the system.
• Leaving the foreign identifier incomplete. A customer outside Italy needs both IdPaese and IdCodice.
• Using XXXXXXX for a counterparty that actually has an Italian recipient code, such as a foreign group company with an Italian VAT position.
• Issuing late, forgetting the cross-border transmission when the foreign invoice is not issued through the SDI, or skipping the courtesy copy where the code is 0000000.
• Applying reverse charge when the supplier acted through an Italian permanent establishment.

The sanctions differ according to which obligation was breached.

Breach	Sanction
An invoice between Italian resident or established subjects issued outside the SDI	The invoice is deemed not issued; article 6 of Legislative Decree 471/1997 applies: 70% of the VAT, minimum €300, or €250 to €2,000 where the breach did not affect the correct VAT settlement. The customer also loses the right to deduct the VAT
Omitted or incorrect transmission of cross-border transaction data	€2 per invoice, capped at €400 per month for transactions from 1 July 2022; halved, capped at €200 per month, if the transmission or correction is made within the following 15 days (article 11(2-quater) of Legislative Decree 471/1997)

Both are administrative penalties and both can be reduced through voluntary correction under article 13 of Legislative Decree 472/1997. Because the reductions depend on the date of payment rather than filing, a late invoice spotted early is materially cheaper than one found in an audit — the Italian-language guide on late transmission and voluntary correction works through the arithmetic.

A short operational checklist

Before the first invoice leaves the system, confirm that the company's VAT number has a registered telematic address, so invoices reach it even when suppliers use a generic code; that each Italian customer's recipient code is stored and reviewed annually; that foreign customers produce XXXXXXX plus a complete foreign identifier and a copy outside the SDI; that foreign supplier invoices produce the correct TD17, TD18, TD19 or TD28 by the fifteenth of the following month; that storage is covered and original files are exportable; and that the parent has a defined route to the data, agreed with the accountant.

If the company is still being set up, the invoicing configuration belongs in the setup phase, not after the first sale: see how to open an SRL in Italy as a non-resident and our services for the compliance work an Italian SRL carries, or request a quote to have invoicing, storage and cross-border reporting handled with the bookkeeping. Recurring fees are on the pricing page.

Primary sources

• Normattiva — Legislative Decree 127/2015, article 1 (e-invoicing and cross-border data transmission), text in force on 23 September 2026
• Normattiva — Presidential Decree 633/1972, article 21 (invoice content and the twelve-day rule) and article 39 (storage)
• Normattiva — Legislative Decree 471/1997, article 6 (documentation and registration breaches) and article 11, including 2-quater (cross-border data)
• Agenzia delle Entrate — The electronic invoice and the Agenzia's free services (guide, December 2025)
• Agenzia delle Entrate — Guide to completing electronic invoices and the esterometro, version 1.10 (April 2025)
• Agenzia delle Entrate — Invoices to and from foreign subjects (transfrontaliere) FAQ
• Agenzia delle Entrate — Transmission methods FAQ (businesses), including non-residents identified in Italy
• Agenzia delle Entrate — Registration and storage FAQ
• Agenzia delle Entrate — Subjects obliged to issue e-invoices and exempt subjects
• Agenzia delle Entrate — Technical specifications version 1.9.1, usable from 15 May 2026
• Agenzia delle Entrate — San Marino invoices
• Gazzetta Ufficiale — Legislative Decree 10/2026, VAT Testo Unico (article 1 of Legislative Decree 127/2015 repealed from 1 January 2027)
• EUR-Lex — Council Implementing Decision (EU) 2024/3150 amending Decision (EU) 2018/593 (Italian e-invoicing derogation to 31 December 2027)