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F.A.Q. FatturaPA File (the public administration invoice file)

What are the features of the signature certificate necessary to sign the FatturaPA file?

The signature certificate required to sign the FatturaPA file must be a certified signature certificate, i.e. issued to an individual on presentation of an identity document. The certified signature certificate can be requested from those on the list of authorised certifiers published on the "Agenzia per l'Italia Digitale" [Agency for Digital Italy] website. The Exchange System accepts the following signature formats:

  • CAdES-BES (CMS Advanced Electronic Signatures) with a structure compliant with the public specifications ETSI TS 101 733 V1.7.4, as set out in the appropriate legislation from 1 September 2010,
  • XAdES-BES (XML Advanced Electronic Signatures), with a structure compliant with the public specifications ETSI TS 101 903 version 1.4.1, as set out in the appropriate legislation from 1 September 2010. The only method accepted for this type of signature is the “enveloped” method. In addition the XAdES signature must have the Reference element with URI=“” or with URI=“#iddoc” where iddoc is the identity code of the document to be signed: the URI attribute cannot be omitted from the Reference elements.

If I use an Intermediary for the electronic invoicing service, who must digitally sign the document?

This question is answered by the so-called 'VAT Decree' (Presidential Decree 633/72, article 21, subsection 1): “For each taxable transaction, the subject who sells the object or who performs the service issues an invoice, also in the form of a note, account, fee or similar, or, it always remaining his/her responsibility, ensures that it is issued on his/her behalf by the intermediary, by the principal or by a third party”.
Therefore, if you use an intermediary for the issue of the invoice (issue and not simple transmission), this intermediary, as the issuing subject, must digitally sign the document, although the responsibility towards the tax authority remains that of the seller/provider.

Is there a relationship between the unique progressive number which is included in the name of the file to be transmitted to the Exchange System and the ProgressivoInvio [progressive transmission number] field of the FatturaPA file which must obligatorily be completed in the DatiTrasmissione [transmission data] block?

No, there is no relationship; the former only has the purpose of differentiating the name of the FatturaPA files transmitted to the Exchange System by the same subject, while the second represents the file identity for use by the transmitter.

Can the unique progressive number, which accompanies the identity of the transmitting subject, contain gaps and can different formats be used? (e.g. ITAAABBB00C11D222E_a0001, ITAAABBB00C11D222E_003, ITAAABBB00C11D222E_B0001)

The progressive number which is part of the name of the FatturaPA file to be transmitted to the Exchange System need not necessarily be strictly progressive, and its composition may vary.

In the DatiTrasmissione block, who is understood as the 'transmitting subject'?

The transmitting subject ('soggetto trasmittente') is the subject who physically transmits the FatturaPA file to the Exchange System (it may be the supplier or a subject appointed by the latter to make the transmission). It must be noted that the 'ProgressivoInvio' field refers to the unique progressive number that the transmitting subject assigns to each file that it forwards to the Exchange System.

What must I do in the case of information which doesn’t fit in any of the obligatory fields of the PA Invoice form but which is obligatory for other legal provisions or instructions (e.g. contract and order references, which must be included on the invoice according to art. 191 of Consolidated Act 267/2000 of the laws disciplining Local Bodies)?

the obligatory Electronic Invoicing rules for invoicing toward the PA cannot alter the legislative framework in force regarding tax and/or administrative issues. Some fields, although optional according to the specifications of the “Fattura PA” format can be considered by the single administrations as binding for the payment, on the basis of specific provisions or contractual agreements. In other words, an invoice that is not rejected by the Exchange System could be refused by a single client administration because it does not have all the specific information (which is optional for the Exchange System).