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Inactive VAT numbers in Italy: how ex officio closure works under the Revenue Agency’s measure of 12 October 2026

The Italian Revenue Agency has updated the criteria it uses to identify VAT numbers that show no activity for three years: electronic invoices, electronically transmitted daily takings and tax payments now also count. The notice is sent to the taxpayer’s digital domicile, closure takes effect on the sixtieth day after receipt and, for the first time, the VAT number can be reactivated with retroactive effect.

The Italian Revenue Agency (Agenzia delle entrate) closes a VAT number (partita IVA) ex officio where, on the basis of the information available to it, the holder does not appear to have carried on any business, artistic or professional activity in the previous three years. By a measure of 12 October 2026, ref. No. 277710/2026, the Director of the Agency revised the implementing rules. VAT numbers are now selected through automated checks that also cover data on electronic invoices, electronically transmitted daily takings and tax payments made by the taxpayer. The advance notice is sent to the taxpayer’s digital domicile (domicilio digitale: the certified e-mail address on record), and closure takes effect on the sixtieth day after receipt. Taxpayers who are in fact active therefore have 60 days to prove it with documents; those who have already lost their VAT number can apply for its reactivation, which, if granted, takes effect from the original date of registration.

The legal basis and the implementing measure

The rule is laid down in Article 35(15-quinquies) of Presidential Decree No. 633 of 26 October 1972, as replaced by Article 7-quater(44) of Decree-Law No. 193 of 22 October 2016. It has three elements: the ex officio closure of the VAT numbers of persons who, on the basis of the information held by the Agency, appear not to have carried on any activity in the previous three years; a clause under which the Agency’s powers to audit and assess remain unaffected; and a measure of the Director laying down the criteria and procedures, including forms of advance notice to the taxpayer.

That measure was adopted on 3 December 2019 (ref. No. 1415522/2019). The measure of 12 October 2026 does not create a new obligation: it amends and supplements the 2019 measure. From 1 January 2027, the provision, unchanged in wording, will become Article 68(24) of the consolidated VAT Act (Legislative Decree No. 10 of 19 January 2026), which repeals Article 35 with effect from that date.

What triggers closure is the absence of any actual activity, not the absence of invoices. Invoices, daily takings and payments are the indicators from which the Agency infers possible inactivity; the taxpayer can always prove the contrary.

What has changed since 2019

Under the 2019 measure, the VAT numbers to be closed were selected from among taxpayers who, in the previous three years, had not filed, where required, the VAT return or the income tax return for business or self-employment income. The new measure drops this criterion. VAT numbers are now selected through automated checks on the information available in the Tax Register (Anagrafe tributaria), “including” data on electronic invoices, electronically transmitted daily takings and payments made by the taxpayer through form F24 (riscossione spontanea).

The measure does not disclose the weight given to each item of data, or the thresholds and combinations that lead to selection. It does state, however, that no decision is based solely on the automated checks: automated selection alone is not enough to close a VAT number. Finally, it contains no transitional provisions for notices already sent under the 2019 rules.

Two features of the 2019 rules remain unchanged. First, the procedure is handled centrally. Second, for taxpayers other than individuals, the tax code (codice fiscale) is cancelled together with the VAT number where the Tax Register contains nothing to suggest that the entity is still operating. For a company or partnership, this is the most sensitive aspect.

The notice: digital domicile, secure personal area, IO app

Under the 2019 rules, the advance notice was sent by registered post. It is now sent, in this order:

• to the digital domicile of the VAT number holder, that is, the certified e-mail (PEC) address recorded in the public lists (Article 60-ter of Presidential Decree No. 600 of 29 September 1973);
• failing that, to the digital domicile of the holder’s representative;
• only where neither exists, by registered post with acknowledgement of receipt to the tax domicile recorded in the Tax Register.

The notice can also be viewed in the taxpayer’s online tax file (Cassetto fiscale), in the section L’Agenzia scrive, and its availability is announced by an alert in the secure personal area and by a message on the IO app. In practice, the notice will mostly arrive by PEC: if the mailbox is not read, or is no longer monitored, the taxpayer may learn of the closure only once it has taken effect.

The 60-day window: responding before closure

Closure of the VAT number takes effect on the sixtieth day after receipt of the notice. Where delivery is not possible, the measure refers instead to the date on which the notice is made available in the secure personal area. Here the text can be read in two ways: closure on the sixtieth day after that date, or on that date itself. Until the Agency clarifies the point, the prudent course is to assume the stricter reading and respond at once.

Within 60 days of receipt of the notice, a taxpayer who considers the closure unlawful may contact any local office of the Agency to explain why they are still an active taxable person for VAT purposes. For companies, partnerships and other entities, the same route can be used to object to the cancellation of the tax code. The Agency’s information sheet lists three channels: the Consegna documenti (document submission) service in the secure personal area; a PEC message to any Provincial Directorate with the subject line Risposta a comunicazione di chiusura della Partita IVA (Reply to notice of closure of VAT number); or submission in person or through a delegate, by appointment.

The measure does not specify which documents to provide. Taxpayers should produce objective evidence (contracts, quotations and orders, purchase invoices relating to the activity, authorisations and registrations, returns filed and accounting records), since what must be shown is that the activity is actually carried on, not merely that they intend to resume it.

Reactivation with retroactive effect

This is the most significant change. Once the 60 days have passed, the taxpayer may submit to any local office a reasoned request for the reactivation of the VAT number and, for taxpayers other than individuals, of the tax code as well. After examining the arguments and the documents produced, the office may reactivate the VAT number and, where applicable, the tax code. Reactivation takes effect from the original date of registration for VAT, or from the original date on which the tax code was assigned, “without interruption”.

Two words of caution. The measure states that the office “may” reactivate: the outcome is not automatic and depends on the evidence. Furthermore, in our view, because reactivation operates without interruption, the obligations for the intervening period still apply: reactivation restores the VAT number but does not relieve the taxpayer of the returns and payments that should have been made in the meantime.

Penalties, and how closure differs from other procedures

Failure to notify the cessation of activity is not penalised. Article 7-quater(45) of Decree-Law No. 193/2016 removed cessation from the infringements covered by Article 5(6) of Legislative Decree No. 471 of 18 December 1997. That provision now imposes a penalty of €500 to €2,000 only where the commencement of an activity, or a change to it, is not notified or is notified inaccurately. Closure for inactivity therefore does not lead to any penalty.

It must, however, be distinguished from two procedures with very different consequences:

• cessation ordered where checks on the taxpayer’s data have an unfavourable outcome, or on the basis of risk profiles (Article 35(15-bis) and (15-bis.1)), which carries the €3,000 penalty under Article 11(7-quater) of Legislative Decree No. 471/1997; moreover, if the same taxpayer later applies for a new VAT number, including as legal representative of a company or other entity set up after the cessation, they must provide an insurance or bank guarantee with a term of three years and for an amount of not less than €50,000;
• removal from the VIES database after four consecutive quarters without recapitulative statements (Article 35(7-bis)), which does not close the VAT number but means that the taxpayer can no longer operate as a taxable person in intra-EU transactions.

Closure for inactivity entails neither the penalty nor the guarantee. Equally, it neither certifies that the taxpayer was inactive nor closes past tax years to further audit or assessment: the law expressly preserves the Agency’s powers to audit and assess.

Active taxpayers at risk of being treated as inactive

Under the new criteria, some taxpayers who are in fact operating may leave little trace in the electronic data flows and should take particular care:

• healthcare professionals, whose flow of electronic invoices issued may be empty even though they are working normally: the law prohibits them from issuing electronic invoices for services whose data are sent to the Health Card System (Sistema tessera sanitaria) and, more generally, for healthcare services provided to individuals (Article 10-bis of Decree-Law No. 119 of 23 October 2018 and Article 9-bis(2) of Decree-Law No. 135 of 14 December 2018);
• businesses in liquidation, where sales of assets become infrequent but the VAT number must remain open until the liquidation is completed (Article 35(4));
• activities with a long start-up phase, which for several years record only purchases;
• property or holding companies or partnerships with few output transactions, for which the risk concerns not only the VAT number but also the tax code.

In these cases, it is advisable to keep the documents proving the activity in good order and, above all, to monitor the PEC mailbox.

Closure on the taxpayer’s own initiative

Anyone who ceases their activity must file a notification of cessation of activity (dichiarazione di cessazione) within 30 days of cessation (Article 35(3)); for businesses, the period runs from the completion of the liquidation (Article 35(4)). Individuals use form AA9, while companies, partnerships and other entities use form AA7; taxpayers entered in the Business Register (registro delle imprese) or in the Economic and Administrative Index (REA) may file the notification with the Business Register office (Article 35(8)). Failure to do so is not penalised, but closure on the taxpayer’s own initiative records the actual date of cessation, allows the final VAT return to be prepared in good time and keeps the taxpayer out of the ex officio procedure, with its time limits and notices.

In practice

• Check that the digital domicile of the sole proprietorship, company or partnership is correct and that the PEC mailbox is read regularly; check the L’Agenzia scrive section of the Cassetto fiscale periodically.
• If there is little activity on the VAT number but the business is genuine, now start collecting the contracts, quotations, purchase invoices and returns that prove it.
• On receiving the notice, respond to a local office immediately, and in any event within 60 days, with documents rather than mere statements of intent.
• If the VAT number has already been closed, submit a reasoned request for reactivation and bear in mind that the obligations for the intervening period still apply.
• If the activity has genuinely ceased, file the notification of cessation within the time limit, without waiting for the ex officio procedure.

Frequently asked questions

I have received the notice but I am working normally: what should I do?

Within 60 days of receipt, respond to any local office of the Italian Revenue Agency, including through the Consegna documenti service or by PEC, providing evidence of the activity you carry on. If you do not respond, your VAT number will be closed on the sixtieth day.

My VAT number has already been closed: can I recover it?

Yes, by submitting a reasoned request for reactivation. If the office accepts it, the VAT number is reactivated with effect from the original date of registration, without interruption; acceptance is not automatic and depends on the documents provided.

If I do not close a VAT number I no longer use, will I be penalised?

Not for failing to close it as such: since 2016, failure to notify the cessation of activity has not been penalised, although notification is mandatory. As long as the VAT number remains open, however, the filing obligations continue to apply, and failure to meet them is penalised under the rules applicable to each obligation; if the activity has ceased, it is therefore advisable to close the VAT number on your own initiative.

Sources

Article 35(3), (4), (7-bis), (8), (15-bis), (15-bis.1), (15-bis.2) and (15-quinquies) of Presidential Decree No. 633 of 26 October 1972; from 1 January 2027, Article 68 of Legislative Decree No. 10 of 19 January 2026 (consolidated VAT Act).

Article 7-quater(44) and (45) of Decree-Law No. 193 of 22 October 2016, converted into law by Law No. 225 of 1 December 2016.

Article 5(6) and Article 11(7-quater) of Legislative Decree No. 471 of 18 December 1997.

Article 60-ter of Presidential Decree No. 600 of 29 September 1973.

Article 10-bis of Decree-Law No. 119 of 23 October 2018; Article 9-bis(2) of Decree-Law No. 135 of 14 December 2018.

Italian Revenue Agency, measures of the Director of 3 December 2019, ref. No. 1415522/2019, and of 12 October 2026, ref. No. 277710/2026; information sheet La chiusura d’ufficio della partita Iva.