Italy's SdI: The Veteran Regime That Keeps Changing
Italy has cleared every business invoice through a central platform since 2019, and Europe has largely copied the idea. But the regime has not stood still: new specifications, new document types, new rejection codes and a pre-filled VAT return are reshaping a system most companies consider finished.
Country briefing · September 2026 · CFOs, Tax and Finance leads
Download Full Briefing (PDF, EN)2019
Clearance of all B2B and B2C invoices through the SdI
12 days
To issue an invoice after the transaction
1.9.1
The technical specification in force since 15 May 2026
2027
The current EU derogation runs to 31 December; the pre-filled VAT return widens
Key takeaway for finance and tax leaders: Italian e-invoicing is rarely broken. It is usually a little behind, and the gaps sit on the buyer's side, where the regime has grown most since go-live. The question to ask this month: are we on specification 1.9.1 and, if we invoice as part of a VAT group, have any invoices been rejected since May?
Seven Years of Clearance, and Still Evolving
Italy made electronic invoicing to the public sector compulsory in 2014–15 and extended clearance to all business invoices on 1 January 2019. Every domestic invoice passes through the Sistema di Interscambio (SdI), which validates it and delivers it. Cross-border transactions have been reported through the same channel since 2022, and flat-rate taxpayers joined in 2024.
The Regime at a Glance
B2G: all public administrations, through the SdI
B2B and B2C clearance: every domestic invoice through the SdI, in the national XML format
Cross-border reporting moves into the SdI, replacing the old separate report
Flat-rate taxpayers brought into scope, in two steps
Electronic receipts: card terminals linked to cash registers
The pre-filled VAT return widens; the EU derogation runs to 31 December
Why “Finished” Is the Wrong Word
The specification changes: two versions in fourteen months, each with new codes and new rejection rules.
The same invoices now feed pre-filled VAT registers and returns.
Europe is converging on Italy, and the ViDA reforms will eventually require Italy to align in turn.
Who It Reaches Inside the Business
| Function | What the Italian regime asks of them |
|---|---|
| Billing and AR | Invoices through the SdI within twelve days; rejections resent within five |
| Accounts payable | Integration documents for foreign and reverse-charge purchases; TD29 for irregular supplier invoices |
| Retail | Daily receipts transmitted; terminals linked to registers |
| Tax and GL | Archiving, and reconciliation to pre-filled registers as they arrive |
How the SdI Works: Receipts Decide When an Invoice Exists
The SdI sits between supplier and customer. It receives the invoice, checks it, and either delivers it or rejects it, and the receipts it returns determine the invoice’s legal status. An invoice rejected by the SdI has, legally, not been issued.
The Three Possible Outcomes
| Outcome | What it means | What to do |
|---|---|---|
| Delivery receipt | Delivered to the customer; the invoice is issued | Nothing — record the status |
| Could not deliver | Checks passed but delivery failed; the invoice is still issued and left in the customer’s area on the tax portal | Tell the customer it is available there |
| Rejection (scarto) | Failed the checks; the invoice is not issued | Correct and resend within five days, same number and date |
Deadlines
Issued within twelve days of the transaction.
Within five days, keeping number and date. A rejection noticed at month-end is already a late invoice.
By the 15th of the following month, for supplies documented during the month.
Direct Channel or Intermediary?
A direct accredited channel needs accreditation and a technical channel of your own, and gives full control with full responsibility, for Italy only.
An intermediary carries the set-up, control depends on the provider’s integration, and it often covers other mandates too.
The Receiving Side
Supplier invoices arrive through the SdI at the recipient code or certified email address registered for the company.
An invoice the SdI could not deliver is still issued, and still sits in the tax portal waiting, so the inbound route needs monitoring as much as the outbound one.
Twenty-Nine Codes, Each with Its Own Rules
Italy distinguishes documents by type code, and the type decides the tax treatment and the deadlines. The range has grown from the basic invoice and credit note to cover reverse charge, self-invoicing, regularisation and, since 2025, the buyer's report of an irregular supplier invoice.
Invoices, advances, credit and debit notes, professional fee notes.
Simplified invoices and their credit and debit notes.
Reverse-charge integration and self-invoices: domestic, foreign services, intra-EU goods and specific goods.
Regularisation, VAT-warehouse extractions, deferred invoices, asset sales, self-consumption, San Marino.
New from April 2025: the buyer's report of an omitted or irregular supplier invoice.
The code determines how the authority reads the document and, increasingly, how it appears in the pre-filled registers. A correct document with the wrong type code is, for these purposes, a wrong document.
Cross-Border through the SdI
Foreign services, intra-EU goods and specific goods
By the 15th of the month after receipt of the invoice or the transaction.
Domestic reverse charge
Within the month of receipt, or later within fifteen days of receipt.
The separate cross-border report was abolished in 2022. Transactions with foreign counterparties are now reported through the SdI using the same XML: outbound invoices to foreign customers, and integration documents for foreign purchases.
Accounts Payable Is Now an Issuer
Integration documents are created by the buyer. Every foreign purchase invoice and every domestic reverse-charge invoice generates a document AP must send through the SdI on time. In many companies, this is the least controlled part of Italian compliance.
TD29 in Practice
If a supplier fails to issue an invoice, or issues an irregular one, the buyer must now report it through the SdI with its own document type, replacing the previous separate procedure. It requires AP to recognise the situation, decide, and act within the deadline: a process, not only a code.
What Changed in 2025–26
Specifications, penalties and adjacent rules: six changes worth having in the system and in the calendar.
Penalty reform
Omitted or late invoice: 70% of the VAT involved, with a minimum, and a fixed range where the VAT settlement was not affected. Non-taxable or exempt transactions: a percentage of the amount. Reverse-charge failures: a fixed range per breach.
Specification 1.9
TD29 for irregular supplier invoices, a regime code for the EU cross-border SME exemption, and revised codes.
Healthcare to individuals
Permanently barred from the SdI; the data goes to the national health-card system instead.
Split payment
Extended to 30 June 2029; FTSE MIB companies excluded since July 2025.
Card terminals linked to cash registers
Each payment terminal associated with the electronic register that transmits receipts. Terminals already active had until April 2026.
Specification 1.9.1
A new rejection where a VAT group's tax code is used instead of a participating member's, a new value for amateur sports pay, and more recipient codes per provider.
The VAT-Group Rejection
Specification 1.9.1 rejects an invoice carrying the VAT group's tax code in the field that should hold the participating member's. Groups that configured a single code across members will see invoices rejected, and therefore not issued, until the mapping is corrected. A narrow change with a sharp consequence.
Specifications as a Recurring Project
Two versions in fourteen months is the new normal. Read the change notes when published, not when effective; apply SAP notes in a test system and run real cases; check new rejection codes against your data; and go live before the effective date, not on it.
Receipts, Archiving, Pre-Filling and the European Horizon
E-invoicing is only one part. Around the SdI, other obligations have grown that use the same data, and the direction is clear: the authority starts from its data, and you reconcile to it.
Electronic Receipts
Retailers transmit daily B2C receipts electronically through registered cash registers. Since January 2026 each card terminal must be linked to the register that transmits those receipts, and new terminals must be linked within a set period after activation.
Legal Archiving
Electronic invoices and related documents, in compliant storage, within three months of the income-tax return deadline for the year, kept for ten years. Through a certified provider, or the tax agency’s free service for those who sign up.
The Pre-Filled VAT Return
Using the invoice data it already holds, the tax agency prepares draft VAT registers, periodic reports and the annual return. In 2026 this remains experimental and limited to certain categories, excluding VAT groups and special regimes, with wider coverage planned from tax year 2027.
Public-Health Procurement
Orders to national health-service bodies must be electronic, over Peppol, since 2020–21. Suppliers to Italian healthcare therefore run a second, order-level electronic flow alongside the SdI.
The European Horizon
Italy's current EU derogation for mandatory e-invoicing expires
ViDA removes the need for derogations, but Italy has not officially stated how it will formalise its position. A point to watch rather than to act on: the domestic regime is expected to continue.
Digital reporting of intra-EU B2B transactions under ViDA
Domestic systems that predate 2024 must align with the EU framework
What It Means for Your SAP System
SAP addresses the Italian requirements through SAP Document and Reporting Compliance, whose electronic-document framework generates the XML, exchanges it with the SdI through a direct channel or an intermediary, and returns receipts to the source document. The framework exists on SAP S/4HANA and classic SAP ERP alike: the platform is rarely the constraint. The constraint in Italy is keeping it current, because specification changes arrive through SAP notes that must be applied and tested.
What “Good” Means
| Area | What “good” means |
|---|---|
| Specification | Version 1.9.1 applied and tested, with a process for the next one |
| VAT groups | Member tax codes mapped correctly to avoid the new rejection |
| Rejections | Seen the same day and resent within five days |
| Integration documents | TD16–TD19 generated from AP postings by rule, on time |
| TD29 | A process for irregular supplier invoices, not only a document type |
| Inbound | Supplier invoices received, matched and posted; undelivered ones retrieved from the portal |
| Archiving | Compliant storage fed automatically, within the deadline |
Where Italian Landscapes Are Usually Weakest
Integration documents created manually, often late.
Specification updates applied only after rejections.
Rejections found at month-end, when the invoice is already late.
Archiving handled as a yearly batch, near the deadline.
A Design Sequence
Specification 1.9.1 and the VAT-group mapping
Rejections mean invoices do not exist.
AP documents
TD16–TD19 by rule, and a TD29 process.
Monitoring
Rejections and undelivered invoices, owned daily.
Reconciliation
Ready for pre-filled registers from 2027.
Five Questions for Whoever Supports Your System
- When was 1.9.1 applied, and how many rejections have we had since?
- How are integration documents produced — by rule from AP, or by hand?
- What is our process for TD29?
- How quickly are rejections resent, and who owns them?
- How will we reconcile to the pre-filled registers when they reach us?
A Health Check: Fourteen Questions, and What a Poor Answer Costs
Italian implementations are usually the oldest in a group's portfolio and the most trusted. That trust is deserved on the outbound side. It is rarely deserved on the buyer's side, where most of the regime's growth has happened since go-live.
The Fourteen Questions
| # | Question | If the answer is unclear |
|---|---|---|
| 1 | Are we on specification 1.9.1? | Rejections under rules you have not implemented |
| 2 | Are VAT-group member codes mapped correctly? | Invoices rejected, and therefore not issued |
| 3 | How many rejections last month, and how old? | Late invoices and penalty exposure |
| 4 | Are rejections resent within five days? | The same invoice number, now late |
| 5 | Are TD17–TD19 sent by the 15th? | Cross-border reporting breaches |
| 6 | Are TD16 documents generated on time? | Reverse-charge penalties per breach |
| 7 | Do we have a TD29 process? | Irregular supplier invoices unreported |
| 8 | Are undelivered supplier invoices retrieved? | Invoices issued to you that you never booked |
| 9 | Is archiving automatic and on time? | A yearly scramble, and sanctions |
| 10 | Are card terminals linked to registers? | A 2026 obligation missed in retail |
| 11 | Could we reconcile to pre-filled registers? | Differences found by the authority first |
| 12 | Who adopts each new specification? | Learning about changes through rejections |
| 13 | Is split payment applied to the right public customers? | VAT collected that the customer should have paid directly |
| 14 | Do health-service orders arrive over Peppol? | A second electronic flow nobody monitors |
Questions 2, 5 and 6 are the ones to fix first: the first causes invoices not to exist, and the other two carry penalties on every document missed. Question 11 is the one to start on now, because the pre-filled registers widen from 2027.
The First Thirty Days
Rejections since May, by code
AP-side document timeliness, TD29 and inbound retrieval
Owners and a specification plan
What We Typically Find
- Outbound invoicing reliable, as it has been for years
- AP-side documents — TD16 to TD19 — prepared by hand
- Specification updates applied reactively
- No design yet for TD29 or for pre-filled registers
How 30 Advisory Can Help
A founder-led boutique specialised in SAP DRC & e-invoicing compliance, S/4HANA Finance optimisation and CFO/CIO strategic advisory, with delivery experience in Italy alongside Türkiye and Spain. Italian e-invoicing is rarely broken: it is usually a little behind, and the gaps sit on the buyer's side.
Italian health check, two to three weeks
Against the fourteen questions: specification level, VAT-group mapping, rejections by code since May 2026, AP-side documents, TD29, archiving and receipts. Output: a prioritised gap list and a readiness view for 2027–2030.
Both sides of the regime controlled
1.9.1 applied, integration documents generated from AP by rule, a TD29 process, rejection ownership and automated archiving.
Run and legal change
Each new specification adopted on a plan, pre-filled registers reconciled, and the design aligned with ViDA as it arrives.
A Sensible First Step
Ask for two numbers: rejections since 15 May by code, and TD17–TD19 documents sent after the 15th over the last quarter. Together they show whether the regime has kept up with you, or you with it.
If You Are Ahead
If 1.9.1 is live, AP documents are generated by rule and rejections are owned, there is little to do, and we will tell you that. We are not your tax adviser: we work alongside the people who are.
Founder-led
Finance + SAP DRC depth
Multi-country: Italy, Türkiye, Spain
Boutique agility
Sources consulted 25 September 2026: VATupdate briefing documents on the Italian regime (2025–2026); PwC Italia and PMI.it on specification 1.9.1; FiscoeTasse, Fiscomania, Edotto, InformazioneFiscale and other practitioner sources on document types, deadlines, receipts, archiving, pre-filled returns, penalties and split payment; vatcalc on ViDA; AgID on public-health orders. The Agenzia delle Entrate and FatturaPA sites could not be accessed directly. SAP behaviour from the SAP Help Portal and partner commentary.
Prepared by 30 Advisory, September 2026 (status at 25 September 2026). Information only — not legal or tax advice. Secondary sources differ on some details, including the publication dates of specifications and the wording of cross-border deadlines; confirm the position for your entity with the Agenzia delle Entrate or a qualified adviser before acting.
Not Sure What This Means for Your SAP Landscape?
We'll review your specification level, your rejections and the buyer's side of your SAP landscape against the Italian regime in a 1-hour diagnostic session.
Schedule Assessment (1 hour)