Sorry this mail is in English, but the only Italian I can write is with Google Translate
We are a company with several divisions in Italy. We know that starting from 1/1 we have to send all their B2B-invoices electronically.
We still have (a lot of) questions. Up until now, we are able to generate our invoices in the FatturaPA xml-format.
Our questions are (answers in Italian are ok !) :
To send the invoices to our Italian customers, we have to send them to the SDI and SDI sends them to our customers. Is this correct ?
If we have a customer from e.g. Germany and we have to send them an invoice (or we have to receive one from Germany), does this invoice also needs to be sent through the SDI in FatturaPA-format ? Or is it only between Italian companies ?
Because we send a lot of invoices, we want to do the sending ourselves, making use of an FTP-channel (this because external parties ask yearly 2500 euro per division, which is rediculous ??? Or is it very difficult to set up such an FTP-channel ???)
If we use the ftp-service, the zip-file with the invoice has to be signed (not the invoice xml itself). Is this true ?
Where can we get a signing certificate ? Can somebody give me a CORRECT link where to obtain it because it is not very clear where you can request such a signing certificate or which we have to request.
Or do we receive the certificate when registering the channel because the pdf-documentation says: “The interoperability test is begun starting from the delivery of the signature and encryption certificates to the Entity.”
in the documentation I found: “per i canali accreditati in ricezione la procedura si conclude con la richiesta del codice destinatario o dei codici destinatario (fino ad un massimo di 100). La richiesta del codice (o dei codici) destinatario è disponibile sul sito www.fatturapa.gov.it, al percorso “Home - Strumenti - Gestire il canale”. Per richiedere il codice o i codici destinatario è necessario fare l’upload del file richiestaAccreditamento.zip.p7m generato dal Sistema e reso disponibile al richiedente all’avvio della procedura di accreditamento.”
Are these the codes that have to be used by our suppliers when they send an invoice to us (for making the distinction between the different divisions) or are they used for something else ?
Is it true that the different divisions can make use of the same registered channel ?
Only invoices between Italian companies must be sent by mean of the SDI.
2500€ is not ridicolous because you also need to store your documents in a digital preservation system compliant with the Italian regulation (DPCM 3/12/2013, DMEF 17/06/2014, DPCM 13/11/2014). Usually the price includes this service.
That said, it’s not difficult to setup a SDIFTP (via SFTP) or a SDICoop (via SOAP web services) channel. It’s only a bit cumbersome to manage all the technical details with a government agency as a counterpart.
No, it isn’t. ETSI compliant CaDES o XaDES signature must be applied on each XML file. However only B2G invoices must be signed. For B2B invoices signature is optional.
The certificate that is referred here is the one that provides mutual TLS authentication for the communication channel, not the one that you use to sign invoices.
These codes are used to send invoices to your channel, then you can differentiate among different divisions by inspecting the content of the invoice. So, yes different divisions can make use of the same registered channel using the same code.
I’ve few questions about electronic invoicing too. Adding it here.
Currently our invoices has information about discounts, line items, tax information, seller(our merchant) information with VAT number, buyer(merchant’s customers) information(some of them don’t have VAT number), Date when the invoice is raised, Payment status(if the invoice is paid by charging the card or not). I understand that we have to get the PEC address or the Recipient code of the customer, apart form this what other information should we get?
Why should the Business customer register the recipient code(of intermediary) or the PEC address in the Revenue agency website? Link here for registration. Once it is registered here, where will the Electronic invoices go? Does it go to the Software hub of intermediaries recipient code or to the Revenue agency?
What is the workflow of B2B and B2C?
I believe that B2C customers will not a VAT number, in that case, what information should be collected from them?
From our system, it is possible to void a invoice and delete a invoice. How do we send the voided invoice to the SDI?
Some merchants charge their customers immediately after the invoice is raised (if the payment details are available for the customer). In this case, should the invoice tell SDI that this invoice is paid?
Does electronic invoice have details about the payment status of the invoice? meaning if the invoice is paid or payment is due?
We have a customer portal, where the merchants customer logs in and can download the digital pdf file of the invoice. For italy (B2B and B2C), can the normal digital pdf(not the electronic invoice) be made available for them to download?
Should the supplier also hold the copy of the electronic invoice(this is important because, we will not be sending the invoice to SDI, it will be the intermediary).
Our merchants can customize the invoice by adding logos and other information in the Invoice. Can merchants still send a normal digital pdf to the customer via email directly, after sending the electronic invoice through SDI? (I know it is invalid).
It would be of great help, if you could help me understand this. Thank you so much.
I will try to answer your questions. This is the way I would do it. Not sure if it is the correct way (I am not an expert but also have to send Italian invoices).
PEC address of the customer is only necessary if you want to deliver the invoice to your customer’s certified electronic mailbox (CEM or PEC). I think it is also sufficient if you only have the CodiceFiscale of the customer. The SDI will deliver the invoice to your customer the way your customer wants (so you don’t have to figure out what they want).
All companies in Italy have to register themselves. If they are not registered, they can’t receive invoices. You have to send the invoices to the SDI and the SDI passes the invoices to your customers on the channel they want (PEC/FTP/…)
B2C: as before. I don’t think the B2C invoices must be sent to the SDI. I think they must be sent directly to your customers.
see 3.
You can send different types of invoices (TipoDocumento: invoice, deposit/advance on invoice, deposit/advance on fee, credit note, debit note, fee, self-invoicing)
No, there are no guidelines for sending information regarding the payment.
No, see 6.
Yes, this is possible but these invoices are not “legal”. I also think it is better to also send your customers the invoice in pdf format as every company has their own way of invoicing goods/services and in the fatturapa format there are not many fields for the detail info of the goods/services.
There is a digital preservation obligation. The invoices are then stored for a number of years with a registered partner.
You can do this but these invoices are not “legal”. See 8.
