Tax Observatory › VAT and compliance › Daily takings by software solution: twelve hours without a connection and the till stops

Daily takings by software solution: twelve hours without a connection and the till stops

The technical specifications for the software solution for daily takings were updated to version 1.4 on 7 August 2026. The time limit for loss of connection between the point of issue and the processing point has been extended to twelve hours: once it expires, the point of issue automatically closes the till, enters the “out of service” state and stops issuing commercial documents. The treatment of meal vouchers and the minimum requirements for management documents also change, the QR code display function is removed, and the possibility of cloud architectures and the scope of the ISO certifications are clarified.

The software solution (soluzione software) is the tool through which an Italian retailer may store and transmit daily takings without an electronic cash register (registratore telematico). It is provided for by Article 24 of Legislative Decree No 1 of 8 January 2024, for the data referred to in Article 2(1) of Legislative Decree No 127 of 5 August 2015; the technical rules are set out in the Order of the Director of the Italian Revenue Agency of 7 March 2025, protocol no. 111204, and in the technical specifications annexed to it.

Those specifications have been updated. Version 1.4 is dated 7 August 2026 and replaces version 1.3 of 18 December 2025. The version table lists six changes: the option for the treatment of meal vouchers; the extension of the time limit for loss of connection between the point of issue and the processing point; the removal of the QR code display function; minimum requirements for management documents; a clarification on the possibility of cloud architectures; and the scope of the ISO certifications.

It is worth saying at once what the update is not. It does not introduce any obligation to adopt the software solution, it sets no compliance deadline for the retailer and it provides for no transitional regime. Alignment with the new version is a matter for the manufacturer (Produttore), which applies for approval of the amended version, where appropriate by way of a self-certification submitted for the Agency’s opinion. A change of version does not, as a rule, require the service provider (Erogatore) to be accredited afresh, unless the changes render the interoperability tests no longer valid.

Two modules, two sets of responsibilities

The solution consists of two modules. Fiscal Module 1 is the application installed on the till device — smart POS, personal computer, tablet — or made available in the cloud: that device is the point of issue (Punto di Emissione). Fiscal Module 2 resides on a system that communicates via web services with the Revenue Agency’s receiving system (sistema di accoglienza) and is the processing point (Punto di Elaborazione), operated by the service provider.

The relationship between points of issue and physical tills is regulated: each till must be connected to a single point of issue; a point of issue may serve several tills provided that they are all located in the same outlet and are not separately managed; and each outlet must have at least one point of issue. This is the first item that bears on the cost of any set-up with more than one till.

The retailer is not a bystander. They must be accredited on the Revenue Agency’s Fatture e Corrispettivi (Invoices and Daily Takings) portal, including through an intermediary holding the relevant delegation, declaring the category “Esercente con soluzione software” (retailer using a software solution), and must enrol each of their points of issue, obtaining a signing certificate for each one. A retailer already accredited may use the software solution either in place of or alongside their electronic cash registers: the choice is free and the two tools may coexist.

Twelve hours without a connection, then the till stops

It falls to the point of issue and the processing point, through functions provided by the manufacturer, to check that while the till is open the communication between them is not interrupted for longer than twelve hours. Once that limit expires, the point of issue automatically closes the till and the Journal file, immediately enters the “out of service” state and no longer allows new commercial documents to be issued. The processing point, on its own initiative, immediately reports the out-of-service status to the Revenue Agency.

It should be stated precisely that this is an extension: the version table describes the change as an “extension of the time limit for loss of connection between PEM and PEL” (that is, between the point of issue and the processing point), that is, a relaxation compared with earlier versions of the specifications rather than a new constraint. Nor is the block imposed without warning: among the information the point of issue must be able to display is a message that fewer than ten minutes remain before it is blocked.

When communication is restored the sequence is set: the point of issue transfers the documents still outstanding and the Journal file closed as a result of the interruption, leaves the out-of-service state and reports this to the processing point, which in turn informs the Agency; the processing point produces and transmits the daily takings and returns the hash string that allows the till to be reopened. It is worth remembering, with an on-site inspection in mind, that the point of issue stores the detailed transaction data for forty-eight hours from the opening of the till and in any event until the data are transferred to the processing point.

When the connection does not come back: emergency register and offline procedure

The outlet does not close. If the point of issue fails or is blocked, the retailer records the sums received in the emergency register and promptly reports the problem to the service provider operating the processing point; at the end of the working day, and until the device is repaired, replaced or operational again, they may also send that provider the tax data noted in the register.

Where the connection cannot be restored, an offline procedure is available: the point of issue offers a function that closes the till, signs the Journal file and transfers to a separate device — a USB stick, a handheld terminal — the documents not yet sent together with the closed and signed Journal; the processing point, once those documents are uploaded, produces the daily takings and generates the seed for opening the new Journal, which the point of issue collects when the connection returns. The specifications state the purpose expressly: to allow transmission “within the time limits laid down by law so as not to incur penalties for late transmission of the daily takings”.

Those time limits are twelve days from the date on which the transaction is carried out, under Article 2(6-ter) of Legislative Decree No 127/2015. A second technical deadline runs alongside it: the till must be closed within twenty-four hours of opening and, where closing occurs after midnight on the day of opening, the Journal data must be correctly split between the daily takings files — the specifications provide a dedicated element for the change of day. The detail matters on days straddling a VAT settlement period, and it concerns above all licensed premises — bars, restaurants and the like — that close after midnight.

What is at stake

The specifications set out two outcomes of an inspection. Where the data are not stored in the processing point, the retailer is served with an official report of findings (a “processo verbale di constatazione”) for failure to issue fiscal certification, under Article 6(3) of Legislative Decree No 471 of 18 December 1997. Where, in turn, inspectors from the Revenue Agency or the Guardia di Finanza (the Italian tax police) are not put in a position to acquire the data — for instance because of a prolonged unavailability of the provider’s services — the report is for the failure or irregular operation of the fiscal recording device (misuratore fiscale) — a category that also covers the software solution —, in breach of the same provision.

This is where the practical significance of the emergency register lies: keeping it is what distinguishes a documented technical outage from a failure to certify takings. Two further cases should be borne in mind alongside that one: late transmission of the data is penalised under Article 11(2-quinquies), and the suspension of the licence or of the authorisation to trade is the ancillary penalty laid down by Article 12(2) of the same decree. As regards the amounts, we do not quote figures: Articles 6, 11 and 12 of Legislative Decree No 471 of 18 December 1997 were revised by Legislative Decree No 87 of 14 June 2024, with effect for infringements committed from 1 September 2024, and the applicable amount must be checked against the text in force at the time of the infringement. That said, the amount is not the only point to watch: the outage that triggers the infringement may be caused by a party — the service provider — other than the person on whom the penalty falls, who remains the retailer. A contract can mitigate that asymmetry, but not remove it.

Meal vouchers: an option with a constrained effective date

The option for the treatment of meal vouchers is exercised in the configuration data of the point of issue, recording the date and time from which it takes effect. Activation and deactivation take effect from the moment of the choice, subject to one precise limit: if at least one commercial document against which meal vouchers were accepted has already been issued in the current month, the effect is deferred to the first day of the following month.

Where the option is active, meal vouchers are accepted only for transactions taxed at 10 per cent whose amount inclusive of VAT is equal to or greater than the total face value of the vouchers received. The value of the vouchers net of VAT is entered in the <NonRiscossoServizi> field of the summary block for the 10 per cent rate, and the <RifNormativo> field of the same block is set to “TICKET”; the same value is carried into the daily takings file. The single-rate constraint is not a formality: a retailer who accepts meal vouchers against supplies taxed at different rates — the ordinary case in food retailing — will find no answer in the option. The specifications do not govern that situation: in our view the ordinary treatment of amounts not collected continues to apply to those transactions.

The check is automatic. The <Sede> block of the Journal carries the status of the option as at the opening date and, where the option is not active, the processing point verifies that the “TICKET” reference does not appear in any of the commercial documents received: if it finds it, it sends the Agency a notification, which may lead to targeted inspections. Finally, it is useful to know that the current status of the option, together with the date and time from which activation or deactivation takes effect, is already shown in the daily closing management document: the record exists and does not have to be created separately.

Cloud allowed, hosting within the Union, certifications to be maintained

Version 1.4 clarifies that both modules may be made available in the cloud. Location, however, is not a matter of indifference: the processing point and, where it is in the cloud, the point of issue must be located within the European Union. The security requirements remain: TLS 1.2 and mutual authentication with an X.509 certificate when APIs are called, a private data-exchange protocol between the two points, and checks on the signatures of individual documents.

On certifications the update goes further than the phrase “scope of application” suggests, but it has to be read by distinguishing between the parties involved. In the approval process for the solution, the ISO 9001 and ISO 27001 certifications are registered by the manufacturer, must have a scope covering the activity carried on and must remain valid throughout the life of the software solution; if they do not remain valid, the fiscal guarantees of every software solution registered by that manufacturer lapse. The same certifications are required of the service provider at accreditation: the authorisation code for the combination of solution and processing point is assigned only once the Agency has verified that they have been submitted and are correct and valid. It is therefore not enough to ask a supplier whether it holds the certifications: the useful question is who holds them, with what scope and with what expiry. It can also be checked upstream that the solution offered appears among those approved, since the Agency publishes the approval orders on its website and maintains the register of approved solutions.

Management documents and the QR code

Management documents must show in the heading the wording “Documento gestionale”, the processing date, the serial number of the point of issue, the identifier of the software solution and an identification number made up of the number of the scheduled daily closing and the document’s sequential number. They are issued as PDF files signed in PAdES format with the signing certificate of the processing point or of the point of issue, which guarantees their authenticity and integrity.

They serve an exclusively internal purpose and may not be handed to customers, consistently with what is already laid down for the management receipts of fiscal recording devices (Ministerial Decree of 23 March 1983, Annex A, points 1.4 and 2.12(I), as inserted by the Ministerial Decree of 19 June 1984). It is a distinction easily lost at the counter: a management document is not a commercial document and does not certify the transaction towards the customer. We looked at the commercial document in electronic form in The electronic commercial document: what the omnibus decree actually provides.

As for the removal announced in the version table, it concerns the QR code display function. The two-dimensional code on the commercial document, provided for verification and control purposes and for entry into the instant receipt lottery, remains governed by the specifications and their annexes.

In practice

Anyone who is considering the move to a software solution, or who has already made it, has a number of checks to distribute among the parties involved. The service provider should confirm that its solution is aligned with version 1.4, explain how the twelve-hour limit, the lock warning and the offline procedure are handled, and produce its own ISO certifications as submitted at accreditation, stating the scope and expiry of those registered by the manufacturer of the solution adopted. The retailer is responsible for accreditation on the Fatture e Corrispettivi portal and for the enrolment of every point of issue, with its signing certificate. Staff at the till must be instructed on what to do if the device is blocked and on where the emergency register is kept.

It is worth leaving a documentary trail: the list of registered points of issue with their serial numbers, the daily closing management documents showing the status and effective date of the meal-voucher option, the messages sent to the service provider during downtime, and the entries in the emergency register. These are the items that, in the event of an inspection, connect the cash actually received in the period to the daily takings transmitted.

A final word of caution concerns contracts. If the relationship with the service provider ends as regards the transmission services alone, the provider must still keep the verification component active and manage the pre-existing documentation. If the termination also covers retention and audit, the provider must supply the retailer with the documents stored up to the last transmission received from the point of issue; from that moment compliant retention — which falls to the provider under the Ministerial Decree of 17 June 2014 — reverts to the retailer, who must notify the Agency, through the provider, that they hold the documentation themselves, and remote audit services cease to be available. The format of the handover is already settled: one or more “Archivio” files in zip format prepared in accordance with the Agency’s guidelines. A clause referring to that format and fixing the time limits spares the retailer from discovering this at the moment of the switch. The same section of the contract is the place for the service levels the specifications impose on the processing point when the Agency asks for data: fifteen minutes for information up to one year old, eight hours from one to three years, forty-eight hours from three to five, and five days beyond five years and up to the assessment time limits.

Frequently asked questions

Does the software solution replace the electronic cash register?

No; nor is it compulsory. As a matter of law it is a tool added to those already regulated by the Order of the Director of the Revenue Agency of 28 October 2016; for the individual retailer the choice is free, since a retailer already accredited may use it in place of or alongside their electronic cash registers. A retailer who keeps the electronic cash register continues to follow the rules governing that device, including those on the link with electronic payment instruments, which we discussed in Card terminals and electronic cash registers: the 5 per cent tolerance.

Does moving to a software solution mean I no longer have to link the card terminal?

The statutory obligation is not disapplied. The specifications for the software solution leave the technical arrangements for storing and transmitting information on electronic payments to subsequent regulatory provisions: those technical rules, for this tool, have not been issued to date. It is a point to revisit once they are published.

If the connection is down for more than twelve hours, must I close the outlet?

No. The point of issue enters the out-of-service state and stops issuing commercial documents, but trading continues using the emergency register, with a prompt notification to the service provider and the subsequent communication of the tax data recorded. If the connection cannot be restored, the offline procedure is used, which allows the takings to be transmitted within the statutory time limits.

Can the meal-voucher option be activated mid-month?

It may be exercised at any time and takes effect from the moment of the choice; if, however, at least one commercial document against which meal vouchers were accepted has already been issued in the current month, the effect runs from the first day of the following month. The date and time from which it takes effect must be recorded in the configuration data of the point of issue.

Sources

Italian Revenue Agency, Technical specifications version 1.4 of 7 August 2026, “Soluzione software per la memorizzazione e la trasmissione telematica dei corrispettivi”, version table and paragraphs on the architecture of the solution, accreditation of the retailer, interaction between the point of issue and the tills, configuration of the point of issue, emergency and offline procedures, management documents, security, verification and retention; Order of the Director of the Revenue Agency of 7 March 2025, protocol no. 111204; Legislative Decree No 1 of 8 January 2024, Article 24 (Official Gazette No 9 of 12 January 2024); Legislative Decree No 127 of 5 August 2015, Articles 2(1) and 2(6-ter); Legislative Decree No 471 of 18 December 1997, Articles 6, 11 and 12, in the version in force following Legislative Decree No 87 of 14 June 2024; Order of the Director of the Revenue Agency of 28 October 2016; Order of the Director of the Revenue Agency of 5 November 2018, as amended, on delegations to intermediaries (the “Accreditamento e censimento dispositivi” service); Ministerial Decree of 23 March 1983, Annex A, points 1.4 and 2.12(I), as inserted by the Ministerial Decree of 19 June 1984; Ministerial Decree of 17 June 2014 on compliant retention.