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Stamp duty on electronic invoices: List B can be corrected until 10 September

Until 10 September 2026 a taxpayer may correct the list the Italian Revenue Agency has pre-populated with second-quarter invoices on which stamp duty appears to be due. After that date the list is deemed confirmed even as against those who never opened it: the amount appears by 20 September and must be paid by the 30th.

10 September 2026 is not a payment deadline, and that is part of why it goes unnoticed. It is the last day on which a taxpayer may act on List B for the second quarter of 2026, that is, on the set of electronic invoices the Italian Revenue Agency (Agenzia delle entrate) has selected because they meet the conditions for stamp duty although they carry no indication that the duty has been paid. If the taxpayer does not intervene, the list proposed by the Agency is deemed confirmed: the duty is calculated on that basis, the amount due appears on the portal by 20 September and payment must be made by 30 September.

The practical consequence is that silence counts as acceptance, even where the automated selection has included an invoice that is not subject to the duty. It is worth opening the portal before the 10th rather than after the 30th.

When the €2 duty is payable

The charge arises under Article 13(1) of Part One of the Tariff annexed to Presidential Decree No 642 of 26 October 1972, which subjects to stamp duty “invoices, notes, accounts and similar documents recording debits or credits”. The amount is €2 per copy, and it is not to be found in the text of that article: the fixed stamp duty, previously set at €1.81, was reset at €2.00 by Article 7-bis(3) of Decree-Law No 43 of 26 April 2013, inserted by the converting Law No 71 of 24 June 2013. The threshold, by contrast, is still expressed in lire: note 2(a) to the same Article 13 provides that the duty is not payable where the amount does not exceed 150,000 lire, that is €77.47.

The exclusion of supplies carrying VAT is not in Article 13, which says nothing about VAT: it is in Article 6 of the Table, Annex B, which grants an absolute exemption from stamp duty to invoices covering payment of consideration for supplies subject to value added tax and which, for documents where the VAT is not shown, makes the exemption conditional on a statement that the document does relate to consideration for supplies subject to VAT. The rule mainly affects those who do not charge VAT — taxpayers under the Italian flat-rate regime, exempt supplies, supplies outside the scope — while anyone who charges VAT on every line is not normally affected. Among non-taxable supplies, by contrast, the distinction matters: the Agency builds List B only on nature codes N3.5, that is supplies to a regular exporter against a declaration of intent, and N3.6, leaving out codes N3.1 to N3.4, which cover exports, intra-Community supplies, supplies to San Marino and assimilated transactions.

Outside List B does not mean outside the tax. For exports proper the exemption exists and is express: Article 15 of the Table grants an absolute exemption to “invoices issued in connection with exports of goods, pro-forma invoices and copies of invoices to be attached in order to obtain export and import clearance for goods, and claims for the refund of duties refundable on export”. Not so for assimilated transactions: in ruling No 45 of 19 February 2024 the Revenue Agency restated that the exemption applies to invoices “issued in connection with exports of goods” and not to those issued in connection with economic transactions treated as equivalent to exports for VAT purposes and for the related regime alone, such as those covered by Article 8-bis of Presidential Decree No 633 of 1972, where no transaction qualifying as an export takes place — save for ships’ stores and equipment, which are recognised as exempt. Anyone issuing invoices under nature code N3.4 — and, for the same textual reason, though no specific administrative practice addresses the point, under N3.2 — will therefore not find them in List B even though the €2 may be due: it is the same gap that appears shortly below for code N1, and it is handled the same way, by adding the invoice manually.

The amount is fixed and does not depend on what was entered on the invoice: for every document indicating that the duty has been paid, the Agency assesses the duty at €2, whatever value was entered in the “Importo bollo” (stamp duty amount) field of the electronic format. The person liable is the one who issues the document — the supplier, or the customer in the case of self-billed regularisation documents of type TD20 — and nothing prevents the €2 from being recharged to the customer, provided the recharge is shown on the invoice. It is worth recalling that Article 22 of Presidential Decree No 642/1972 extends joint liability for the duty and the penalties to those who receive or accept documents that are not in order: a missing stamp is not the issuer’s problem alone. The same article, however, points to the way out, and it is worth knowing: a party who receives an irregular document in whose creation they took no part is relieved of all liability if, within fifteen days of receipt, they present it to the office and regularise it by paying the duty alone; in that case the infringement is assessed against the offender only.

List A and List B: what the Agency does in the taxpayer’s place

Since 2021 the calculation has no longer been left to the taxpayer. Article 12-novies of Decree-Law No 34 of 30 April 2019, the Decree of the Ministry of Economy and Finance of 4 December 2020 and the Order of the Director of the Revenue Agency of 4 February 2021 have built an automated mechanism. Each calendar quarter the Agency processes the invoices that passed through the Interchange System (Sistema di Interscambio, or SdI) without rejection and, by the 15th day of the first month following the quarter, makes two lists available on the “Fatture e corrispettivi” (Invoices and Payments) portal.

List A, which cannot be modified, contains the invoices where the taxpayer has already indicated payment of the duty by setting the “Bollo virtuale” (virtual stamp) field to “SI” (yes). List B, which can be modified, contains the invoices that lack that indication but for which the obligation is detected all the same. It is on the second list that the taxpayer’s intervention is concentrated: they may remove the invoices that in their view do not meet the conditions and add those that should carry the duty but appear on neither list. Changes may be repeated: the Agency computes the duty on the last version submitted.

Two practical points make the difference between reading the list and not being able to open it. The first concerns who acts: the authorised intermediary referred to in Article 3(3) of Presidential Decree No 322/1998 may consult and amend the lists only if granted authorisation for the “Consultazione e acquisizione delle fatture elettroniche o dei loro duplicati informatici” (consultation and retrieval of electronic invoices or their digital duplicates) service or the “Consultazione dei dati rilevanti ai fini IVA” (consultation of VAT-relevant data) service: without that authorisation the accountant sees nothing, and the check falls to the taxpayer. The second concerns volume: besides the item-by-item mode, which works row by row in the table, there is a bulk mode allowing the list to be downloaded as one or more XML files, amended and uploaded again, with a processing report identifying any rejected lines.

Invoices that are added must meet three conditions: they must have been transmitted to the Interchange System and processed without rejection, they must have been issued by the taxpayer as supplier (or, for TD20 self-billed documents, as customer) and they must relate to that quarter, not to the preceding or the following one.

How List B is built, and why it must be read

The selection is automated and works on the data in the XML file. An invoice ends up in List B where three conditions are met together: the sum of the amounts in the “Prezzo totale” (total price) fields exceeds €77.47; the “Natura” (VAT nature) field contains one of the codes N2.1 and N2.2 (supplies outside the scope), N3.5 and N3.6 (non-taxable supplies) or N4 (exempt supplies); and the code signalling that the duty does not apply is absent. The threshold is measured on the “Prezzo totale” fields (2.2.1.11) of the ordinary invoice and the “Importo” field (2.2.2) of the simplified one.

That first condition, however, is wider than the charging rule, and this is where most corrections arise. The sum taken into account covers every line of the document, including those subject to VAT; the duty, on the other hand, under the VAT-or-stamp alternative laid down in Article 6 of the Table, is payable only where the amounts not subject to VAT exceed €77.47 on their own. The Agency says so itself: on invoices documenting several transactions, some of which are not subject to VAT, the duty applies if the sum of the components not subject to VAT exceeds €77.47 (Resolution No 98/E of 3 July 2001, cited in ruling No 45 of 19 February 2024). An invoice with €500 of taxable supplies and €20 of exempt supplies therefore appears in List B without belonging there: it is the single most common line to remove.

The selection has the opposite flaw as well, and that is the one that costs. The processing looks only at the nature codes listed above: an invoice carrying amounts excluded from the VAT base under code N1 — typically disbursements recharged to the client under Article 15 of Presidential Decree No 633/1972 — appears on neither list. On those amounts the duty is, as a rule, payable. In ruling No 491 of 20 July 2021 the Revenue Agency held that where part of the amount charged “does not constitute consideration for a transaction subject to VAT, but rather sums received in respect of expenses to be incurred in the name and on behalf of the client”, the VAT-or-stamp alternative in Article 6 of the Table does not operate and the general rule in Article 13(1) of the Tariff applies, with its €2.

There is an exception, and it is very common in professional practice: where the sums advanced under Article 15(1)(3) of Presidential Decree No 633/1972 concern taxes owed by the client (stamp duties, government concession fees, chamber of commerce dues, registry and court filing fees, the unified court fee and the like), Article 5 of Table B may apply, which exempts from stamp duty documents relating to the collection and refund of taxes. The dividing line, then, is not whether the sum falls outside VAT but what it is: an advance of a tax owed by the client, and the exemption applies; any other disbursement, and the duty is due, with the invoice to be added to List B by hand. Here too the €77.47 threshold is measured on the amounts not subject to VAT alone. This is the point at which the convenience of a pre-populated list turns into its opposite.

The code signalling non-application — the third of the conditions set out above — is entered in the “Altri dati gestionali” (other management data) block, “Tipo dato” (data type) field. It takes the value NB1 for insurance documents, where stamp duty is absorbed by insurance tax; NB2 for documents issued by a third-sector body; NB3 for documents between a bank and an account holder, where the duty is absorbed by the duty charged on the account statement. One detail should not be overlooked: the “Altri dati gestionali” block exists only in the ordinary invoice format, so anyone who needs to signal non-application cannot use the simplified invoice, at least for those supplies.

Excluded from List B are the reverse-charge integration documents and self-billed documents of types TD16, TD17, TD18 and TD19, and TD28 for purchases from San Marino with VAT, together with invoices issued under the special regimes coded RF05 to RF11 (salt and tobacco, matches, publishing, public telephony, transport and parking tickets, entertainment and gaming, travel agencies). TD20 self-billed regularisation documents, by contrast, do appear on a list, but not on List B: where they indicate that the duty has been paid they go into the customer’s List A only, and the same holds for TD16 documents indicating payment. A TD20 can enter List B only by manual addition, on the conditions already set out.

There is then a third exclusion, twin to the one for code N1 and just as treacherous: also left out of List B are the documents issued using the ordinary invoice format to report cross-border transactions, those carrying the value “XXXXXXX” in the “Codice destinatario” (recipient code) field. Anyone invoicing foreign operators under nature code N2.1 above €77.47 will find nothing in the list, though the €2 may well be due. The remedy is the same: add them to List B by hand, and the Agency confirms that documents added in this way are then taken into account in calculating the duty.

Allocation to a quarter follows its own rule as well: what counts is the delivery date shown on the receipt issued by the Interchange System, not the invoice date, and for undelivered invoices the date on which the document was made available, as stated in the non-delivery receipt. An invoice dated 30 June and delivered on 1 July belongs to the third quarter. The same rule applies to invoices to public authorities, with one clarification: neither the date of acceptance nor the notice that the acceptance period has expired is relevant.

The calendar, quarter by quarter

The general rule is that changes to List B must be made by the last day of the month following the quarter concerned. The second quarter is the exception: the 31 July deadline moves to 10 September, and with it the date on which the portal displays the amount due moves to 20 September.

First quarter: lists available on 15 April, changes by 30 April, amount displayed by 15 May, payment by 31 May. Second quarter: lists on 15 July, changes by 10 September, amount by 20 September, payment by 30 September. Third quarter: lists on 15 October, changes by 31 October, amount by 15 November, payment by 30 November. Fourth quarter: lists on 15 January, changes by 31 January, amount by 15 February, payment by 28 February of the following year, a deadline that moves to 29 February in leap years. If a payment deadline falls on a Saturday or a non-working day it moves to the first following working day, under the general rule for payments made with the F24 form (Article 18(1) of Legislative Decree No 241/1997): that already happened in 2026 for the first quarter, whose 31 May deadline, a Sunday, moved to 1 June. It is not needed for the second quarter, because 30 September 2026 is a Wednesday.

A word on early payment: counting in one quarter the duty on invoices that belong to the next is not an infringement, but it creates a permanent gap between what has been paid and what the Agency has calculated, which then has to be justified quarter after quarter. Better to stay with the delivery-date rule.

The €5,000 threshold allows a deferral, not an exemption

Article 17(1-bis) of Decree-Law No 124 of 26 October 2019, as amended by Article 3(4) of Decree-Law No 73 of 21 June 2022, allows two deferrals. If the amount due for the first quarter is below €5,000, payment may be made by 30 September together with that of the second quarter. If the combined amount for the first and second quarters is below €5,000, payment may wait until 30 November. A word on the wording: the provision says “below”, whereas the Agency’s guide, in a note to the table, says “does not exceed”. At exactly €5,000 the statutory text does not allow the deferral, and in a borderline case it is wiser to follow the statute. These are in any event options, not exemptions: the liability remains, and the tax codes to be used remain those of the quarters to which the duty relates.

How to pay

The simplest route is the dedicated function on the “Fatture e corrispettivi” portal, which allows a direct debit and which, where payment is late, calculates the penalty and interest for voluntary correction (ravvedimento operoso) automatically. Alternatively the F24 form is filed electronically using the tax codes established by Revenue Agency Resolution No 42/E of 9 April 2019: 2521 for the first quarter, 2522 for the second, 2523 for the third, 2524 for the fourth, 2525 for penalties and 2526 for interest.

If the payment is not made

A delay does not go unnoticed, because the Agency knows exactly the amount it has calculated. Where payment is late, omitted or insufficient, the Agency sends a communication setting out the duty, the penalty reduced to one third and interest: if the taxpayer pays within thirty days of receipt the position is closed, otherwise the sums are entered on the tax roll on a final basis. Assistance and any recalculation can be requested through the CIVIS service dedicated to communications on stamp duty for electronic invoices.

Before the communication arrives, voluntary correction under Article 13 of Legislative Decree No 472 of 18 December 1997 remains available. The reference penalty is that under Article 13(1) of Legislative Decree No 471 of 18 December 1997; Legislative Decree No 87 of 14 June 2024 reduced it from 30 to 25 per cent for infringements committed from 1 September 2024 (Article 5 of that decree). The two statutory reductions apply in sequence, not as alternatives: where the delay does not exceed ninety days the penalty falls by half, to 12.5 per cent; where it does not exceed fifteen days that 12.5 per cent is further reduced to one fifteenth for each day, that is 0.8333 per cent per day. The reductions available under voluntary correction then apply on top of those figures.

What changes on 1 January 2027

The whole framework just described has an expiry date of its own. Article 204(1)(c) of the annex to Legislative Decree No 123 of 1 August 2025 — the consolidated act on registration tax and other indirect taxes — repeals Articles 1 to 6, 8 to 23, 30 to 33 and 38 to 42 of Presidential Decree No 642/1972, together with the Tariff in Annex A and the Table in Annex B; letters (hhh) and (iii) of the same article repeal Article 12-novies of Decree-Law No 34/2019 and Article 17(1-bis) of Decree-Law No 124/2019. All of this takes effect from the date set by Article 205, which is 1 January 2027: the original date, 1 January 2026, was deferred by Article 4(5) of Decree-Law No 200 of 31 December 2025, converted with amendments by Law No 26 of 27 February 2026. Legislative Decree No 471/1997, the source of the penalty, likewise gives way from that same date to the consolidated act on tax penalties, Legislative Decree No 173 of 5 November 2024.

The mechanism survives: Article 152 of the consolidated act reproduces the integration and communication procedure and keeps the €5,000 deferral threshold, recasting the deferral as a cross-reference to the deadlines of the following quarter. One point merely moves house, and it is better known in advance than misread. In the text applicable from 1 January 2027, Legislative Decree No 141 of 5 August 2026 deletes the words “reduced to one third,” from Article 152, leaving the cross-reference to the penalty under Article 38(1) of Legislative Decree No 173/2024; the same decree, however, inserts into the consolidated act on penalties a new Article 52-bis which, having reproduced the same case, provides that “the penalty under the first sentence is reduced to one third if the taxpayer pays, in whole or in part, the sums due within thirty days of receipt of the communication”. The reduction therefore survives: what changes is the provision that contains it, not the benefit. The first deadline to fall beyond that line is the fourth quarter of 2026, payable on 28 February 2027, when the consolidated act will already be in force.

The most common case: the flat-rate taxpayer

Taxpayers under the Italian flat-rate regime issue invoices without VAT under nature code N2.2 and, above the €77.47 threshold, the duty is payable. Two euros for every invoice, not per client and not per year: anyone issuing many small invoices may find themselves paying, each quarter, more than they expected. It is also the group of taxpayers that opens the portal least often, because the duty appears in no periodic VAT settlement and no other filing serves as a reminder. Our guide to electronic invoicing covers the underlying obligations, while the scope of the regime is set out on the page for flat-rate taxpayers.

There is a further point that flat-rate taxpayers almost always discover too late. Where the €2 is recharged to the client, the Agency treats it as forming part of the fee or the turnover: Revenue Agency ruling No 428 of 12 August 2022 concludes that the recharged duty “takes on the nature of turnover or fees and contributes to the flat-rate computation of the income” subject to the substitute tax. And since Article 1(54)(a) of Law No 190/2014 anchors the €85,000 limit to turnover earned and fees received, that characterisation also bears on the computation of the threshold. The recharged duty must be shown separately on the invoice, but it is not a neutral pass-through: the profitability coefficient and the substitute tax apply to it. Anyone issuing many small invoices would do well to decide once and for all whether to recharge it or absorb it, rather than alternating.

In practice

By 10 September: open “Fatture e corrispettivi”, read List B for the second quarter line by line, remove the invoices that do not meet the conditions and add those that should carry the duty but do not appear. In the absence of any change, the list is taken as confirmed.

From 20 September: check the amount calculated by the Agency against your own figure. By 30 September: pay, either from the portal or by F24 under code 2522, adding the first quarter if the deferral has been used.

To keep on file: the reason for every invoice removed from List B, because removal does not have to be justified at the time but will have to be if the Agency carries out an audit. To fix for the future: if the same invoices reappear every quarter, the problem lies upstream, in how the electronic format is completed, and that is where it should be solved.

If 10 September has passed

Once the deadline has gone, not everything is lost, but the instrument changes: a request for review under the Agency’s own powers of self-review (autotutela) remains available, to be filed with the competent local office under Articles 10-quater and 10-quinquies of Law No 212/2000. It is worth knowing that it suspends neither collection nor time limits. The Agency’s June 2026 guide devotes a chapter to what happens to the lists once the request is granted: where it is granted, the invoices no longer subject to the duty are excluded, the original List A is amended accordingly, those taken out of List B are moved to the “Fatture escluse da Elenco B in autotutela” (invoices excluded from List B on self-review) tab, and the note on the individual invoice changes from “BOLLO SI” to “BOLLO NO”, with the result that the certificate of payment is no longer available for that document. It is a longer and less automatic route than a click by 10 September, and for that reason it should be kept as a remedy, not treated as an alternative.

Frequently asked questions

I have already paid the second-quarter duty: can I still change the list?

No. Where payment is made before the deadline for changes expires, the payment blocks any further intervention on the list. It is therefore advisable to examine the list before making payment.

If I remove an invoice from List B, do I have to explain why?

Not at that moment: the removal is carried out without attaching anything. The reasons must be supplied if the Agency carries out an audit, which means they have to be prepared and kept now, while the basis for the choice can still be reconstructed.

What happens if I never open the portal?

List B as proposed by the Agency is deemed confirmed and the duty is calculated on that basis. In the absence of payment the Agency sends the communication with the duty, the penalty reduced to one third and interest; the thirty days to pay run from receipt.