Italy E-Invoicing for Foreign Businesses: FatturaPA and Cross-Border Guide 2026
Complete guide for foreign businesses with Italian VAT registrations. FatturaPA requirements, SDI submission, conservazione sostitutiva, and cross-border invoice handling.
Italy E-Invoicing for Foreign Businesses: FatturaPA and Cross-Border Guide 2026
Italy's FatturaPA mandate has been live since 2019 โ making it the world's longest-running mandatory B2B e-invoicing system. But many foreign businesses with Italian operations are still unclear about exactly which transactions require FatturaPA, how to submit through SDI, and what to do about cross-border invoices.
This guide answers those questions specifically for non-Italian businesses operating in Italy or invoicing Italian customers.
Who This Guide Is For
- EU companies with Italian VAT registrations
- Non-EU companies with Italian permanent establishments (stabile organizzazione)
- Foreign businesses invoicing Italian companies under the Italian reverse charge mechanism
- E-commerce businesses with Italian B2C customers
Which Transactions Require FatturaPA?
The short answer: FatturaPA is required for transactions between Italian VAT-registered entities for Italian domestic business.
FatturaPA Required For:
- B2B invoices between two Italian VAT numbers, regardless of where the companies are headquartered
- B2G invoices to Italian public authorities (regardless of the issuer's country)
- A German company with an Italian VAT number invoicing an Italian business entity โ FatturaPA required
- An Italian business issuing invoices in Italy, even if the customer's parent company is foreign โ FatturaPA required
FatturaPA NOT Required For:
- Invoices from an Italian entity to a non-Italian EU customer (cross-border B2B) โ Not required (Peppol or local format instead)
- Invoices from a non-Italian entity without an Italian VAT number โ Not required
- Invoices to Italian non-VAT-registered consumers (B2C) โ these use a separate "corrispettivi telematici" system
How SDI Works for Foreign Businesses
If you have an Italian VAT number, you must submit domestic Italian invoices through SDI (Sistema di Interscambio) โ exactly as Italian businesses do.
Option 1: Use an Italian SDI Intermediary
Most practical for foreign businesses. An Italian-certified SDI intermediary (intermediario SDI) submits invoices to the SDI on your behalf. You provide invoice data via their platform or API; they handle the SDI submission and return the reference number.
Common SDI intermediaries used by foreign businesses:
- Aruba โ most established, enterprise-grade infrastructure
- TeamSystem โ popular with Italian accountants
- Zucchetti โ used by large multinationals with Italian operations
- Agyo (Agyo.io) โ API-first, popular with tech-forward multinationals
Option 2: Integrate Your ERP with SDI API Directly
Large enterprises (typically those with dedicated Italian IT teams) integrate their ERP directly with the SDI API. This requires:
- Italian SPID (digital identity) or CNS (smart card) authentication
- PEC (Posta Elettronica Certificata) mailbox for SDI communication
- XML generation capability for FatturaPA 1.3 schema
SAP S/4HANA, Oracle Cloud, and Microsoft Dynamics 365 Finance all have Italian SDI modules. Verify your version includes the latest FatturaPA 1.3 support.
Option 3: Use the Agenzia delle Entrate Portal (Low Volume)
For very low invoice volumes, the free government portal (fatture-e-corrispettivi.agenziaentrate.gov.it) allows manual FatturaPA creation and submission. Not practical for more than 10โ20 invoices per year.
The FatturaPA XML Fields Foreign Businesses Often Miss
Codice Destinatario (7-character routing code)
This is the field that tells SDI where to route the invoice. Get it from your Italian customer before sending.
| Recipient type | What to use |
|---|---|
| Business with a specific code | Use their 7-digit code |
| Business using PEC email | Use their PEC email address in the campo PEC field |
| Business without a code | Use 0000000 (seven zeros) as fallback โ not ideal |
| Italian public authority | Use the IPA (Indice PA) code โ mandatory for B2G |
Codice Fiscale vs. Partita IVA
Foreign businesses often confuse these:
- Partita IVA = Italian VAT number (format: IT + 11 digits) โ required for all VAT-registered entities
- Codice Fiscale = Italian tax code โ 16-character alphanumeric for individuals, same as Partita IVA for companies
Your Italian SDI intermediary will typically handle these fields if you provide your Italian VAT number.
Tipo Documento (Invoice Type)
| Code | Meaning |
|---|---|
| TD01 | Standard invoice (most common) |
| TD04 | Credit note |
| TD07 | Simplified invoice (under โฌ400) |
| TD17 | Reverse charge โ services from non-EU |
| TD19 | Reverse charge โ goods import |
Foreign businesses providing services to Italian customers under the reverse charge mechanism typically use TD17.
Cross-Border Invoices: What Format?
For invoices from Italy to other EU countries (cross-border B2B), FatturaPA is not required. You can use:
- Peppol BIS 3.0 โ if the customer's country uses Peppol (Germany, Netherlands, Belgium, etc.)
- XRechnung โ if the customer is a German business specifically requesting it
- Factur-X / ZUGFeRD โ if the customer is French
- Standard PDF โ still legally valid for cross-border B2B (until ViDA's 2030 DRR mandate changes this)
The practical recommendation: get a Peppol access point if you regularly invoice across EU borders. One Peppol ID lets you send invoices in multiple EU formats.
Conservazione Sostitutiva for Foreign Businesses
All FatturaPA invoices must be digitally preserved for 10 years under Italy's conservazione sostitutiva rules. This applies to foreign businesses with Italian VAT registrations too.
Good news: if you use an Italian SDI intermediary (Aruba, TeamSystem, etc.), conservazione is typically included in their service and handled automatically. Verify this in your service contract.
If you manage SDI submission yourself, you need a separate AGID-accredited conservazione provider.
Common Issues for Foreign Businesses
"Our invoice was rejected with error code PA04"
PA04 means the recipient's Codice Destinatario is unknown or inactive. Solution: Contact your Italian customer to confirm their correct code. Also check for typos โ the 7-character code is case-sensitive.
"SDI says the invoice is consegnata but the customer says they didn't receive it"
"Consegnata" means SDI delivered it to the recipient's SDI intermediary. If the customer doesn't see it, the issue is on their side (their intermediary may not have notified them). Solution: Give them the SDI progressive number and ask them to check their intermediary's portal.
"We can't get SPID/CNS for SDI direct access as a foreign entity"
SPID (Italian digital identity) is available to EU citizens and some non-EU nationals, but not always to foreign legal entities. Solution: Use a certified SDI intermediary rather than direct SDI API access. This is the standard approach for multinational companies.
Recommended Setup for Foreign Businesses
| Scenario | Recommended approach |
|---|---|
| < 100 Italian invoices/year | Use Aruba or Fattura24 โ low cost, easy to set up |
| 100โ1000 Italian invoices/year | TeamSystem or Zucchetti via Italian accountant |
| > 1000 invoices/year | SAP/Oracle/Dynamics Italian localisation or Agyo API |
| Italian subsidiary with local staff | Full Italian accounting software (Zucchetti, TeamSystem) |