Italy is at the forefront of introducing Continuous Transaction Control (CTC) in the EU and continues to lead. Other European countries are looking for inspiration in Italy for their local CTC implementations. Even before the introduction of the severance e-invoicing system in 2018, the country had strict requirements for electronic archiving of documents. These documents include e-invoices. The rules for the retention of electronic documents have been fairly stable since 2013. However, the new set of rules is due to be implemented on June 7, 2021 by the Italian Digital Agency (AGID).

What will be the new rules set in June 2021?

The new guidelines must be followed by taxpayers who store electronic documents in accordance with Italian law. Retention of these documents includes instructions on how to create, manage, and store such files. According to the AGID, the guidelines contain a static and flexible set of annexes, which suggests that the Italian government will update the annexes with some frequency. 

Among the updates regarding the e-document archive is the introduction of new standards and references. They refer to newer already existing standards. An example of the latter category is the recently revised UNI 11386, which aims to ensure interoperability in the maintenance process.

Another change introduced by the new guidelines concerns the metadata that must be associated with e-documents. To meet this requirement, AGID has published an appendix devoted to this topic, which includes the method of creating the e-document and the type, version and author of the document.

AGID also modified bureaucratic regulations. The new regulation clarifies that entrepreneurs can delegate the role of maintenance manager to a company with the appropriate competences and knowledge to perform the duties of a maintenance manager.

It is worth noting that the guidelines go beyond e-archiving and introduce new technical specifications for the dematerialisation of paper documents into electronic form. While most invoices have to be issued electronically via the SDI platform, it is still possible to issue and receive paper invoices for cross-border flows to and from Italy. Therefore, companies must follow the new rules when dematerializing the flow of documents.

While many taxpayers initially expected Italian e-archive requirements to lose their relevance with the introduction of the e-invoicing mandate. Instead, it has become obvious to the larger Italian companies that it is more important than ever to have stronger evidence to support their transactions. In Italy, the only way to satisfy the tax authority is keeping an electronic archive in accordance with the regulations for storing electronic documents.