The esterometro is the Agenzia delle Entrate's nickname for the duty, set by Art. 1(3-bis) D.Lgs. 127/2015, to send electronically the data on supplies made to and received from persons not established in Italy. The Italian company reports; a foreign parent with no Italian establishment does not. Since 1 July 2022 the data go through the Sistema di Interscambio (SdI).
This page sets out what the statute requires. Applying it to one company's invoices is work for an English-speaking tax advisor for a foreign-owned Italian company.
What is the esterometro?
Esterometro is not a word of the statute. It is the name the Agenzia delle Entrate, the Italian Revenue Agency, gives in its own FAQ to the duty in Art. 1(3-bis) D.Lgs. 127/2015, which concerns operazioni transfrontaliere, cross-border transactions. In English the same duty is the reporting of cross-border invoice data.
The rule is short. VAT persons send the Agenzia, by electronic means, the data on supplies of goods and services they make to, and receive from, persons not established in Italy. The 2017 amendments that wrote the paragraph apply to invoices issued from 1 January 2019.
The duty carries no tax of its own. The only state money in the topic is the penalty for omitted or wrong data, set out below. How the data travel is a separate question, answered in the section on the channel.
Who has to report it: the foreign parent or the Italian company?
The reporters are "the VAT persons of comma 3", and comma 3 covers supplies between persons resident or established in Italy (Art. 1(3-bis) D.Lgs. 127/2015). So the Italian S.r.l. reports from its first cross-border invoice. The foreign parent with no Italian establishment does not report as such.
The parent still matters. Its invoice to the S.r.l., for a recharge or a management fee, is the S.r.l.'s purchase from a person not established in Italy, and the S.r.l. reports it. Whether the parent is treated as Italian-resident in the first place is a different tax question, covered in our guide on when Italy treats a foreign company as Italian-resident.
One case stays open. A foreign company that only holds an Italian VAT number, by direct identification or through a fiscal representative, is not an Italian-resident or established person on the wording of the statute. No source we read says whether it must report, so this page does not say that such a company is exempt.
Which cross-border transactions are in scope?
Scope is wider than the Intrastat lists. The Agenzia reads the duty as covering every supply to and from a person not established in Italy, with no further limit.
A sale to a customer abroad. An invoice to a customer not established in Italy is in scope.
A purchase from a supplier abroad. A management recharge from the parent, a software subscription or advertising bought from a foreign supplier is a purchase from a person not established in Italy.
EU and non-EU counterparties alike. The country of the counterparty does not change the duty; being outside Italy does.
A business or a consumer. On the Agenzia's reading in Circolare 26/E of 13 July 2022, the other party may be either, without further limits.
Goods and services both. The statute names supplies of goods and supplies of services, so a service invoice is reported as a goods invoice is.
Livigno and Campione d'Italia. The Agenzia counts sales to these two municipalities as cross-border operations for this duty.
What is excluded from the report?
Several operations fall outside the report, and one ceiling decides where the line runs. Over-reporting costs time; under-reporting costs the penalty below.
- Operations covered by a customs declaration (bolletta doganale) (Art. 1(3-bis) D.Lgs. 127/2015).
- Operations for which e-invoices were issued or received through the SdI under comma 3.
- Purchases outside the territorial scope of Italian VAT (Arts. 7 to 7-octies D.P.R. 633/1972), only up to EUR 5,000 per single operation.
- The Agenzia reads that EUR 5,000 as including any tax (Circolare 26/E of 13 July 2022).
- Tax-free retail invoices to non-EU travellers issued through the OTELLO platform.
- A purchase outside Italian VAT above EUR 5,000, VAT included, is reported.
How are the data sent now, and is the quarterly filing gone?
The old rule was a quarterly filing. It applied until operations of 30 June 2022. For operations from 1 July 2022 the statute requires the data to go through the SdI, the Agenzia's invoice exchange, in the e-invoice format, transaction by transaction. The new date was set by Art. 5(14-ter) D.L. 146/2021, which moved the earlier 1 January 2022 start. Our guide to electronic invoicing in Italy covers the SdI itself.
The data travel by the same channels as an e-invoice: the Agenzia's free web tool, software or an app, a certified email (PEC) to the SdI, or an intermediary's accredited channel (Agenzia delle Entrate guide). The Agenzia's own tools need SPID, CIE, CNS or Fisconline/Entratel credentials.
How a director who lives abroad obtains those credentials, and what mandate an intermediary needs, is open on our sources, so we give no duration. The director's tax code is a separate matter, covered in our guide on the tax code for directors.
One trap is worth dating. The Agenzia's own FAQ category on cross-border invoices still holds answers written before 1 July 2022 that offer a separate cross-border communication as an alternative. For operations from 1 July 2022 the statute requires the SdI, so that alternative is not available for them.
What are the deadlines for sales and for purchases?
Sales abroad are reported within the invoicing deadline of the sale. That deadline is 12 days from the operation in general (Art. 21(4) D.P.R. 633/1972), and the 15th of the following month for services to EU taxable persons under Art. 7-ter. Purchases from abroad are reported by the 15th of the month after receipt of the document or after the operation (Art. 1(3-bis)(b) D.Lgs. 127/2015).
- Invoice by the invoicing deadline: 12 days in general (Art. 21(4) D.P.R. 633/1972)
- Then either an e-invoice through the SdI with code
XXXXXXX, or the data file
- The Italian buyer applies reverse charge (inversione contabile)
- Then a TD17, TD18 or TD19 file by the 15th of the month after receipt or after the operation
- EUR 2 per invoice, at most EUR 400 a month
- Halved, at most EUR 200 a month, if sent or corrected within 15 days (Art. 11(2-quater) D.Lgs. 471/1997)
Circolare 26/E gives two worked cases. An intra-EU sale of goods invoiced by the 15th of the following month is reported by that 15th, even if the invoice is issued earlier. A purchase whose document does not arrive in time is reported by the 15th of the month after the operation, dated under Art. 6(6) D.P.R. 633/1972.
Which document carries a purchase: TD17, TD18 or TD19?
Purchase-side data travel in an SdI file whose type depends on what was bought. The three codes a new S.r.l. meets first are TD17, TD18 and TD19, listed in the technical specifications (Allegato A, version 1.9) of the Agenzia.
The three purchase-side document codes, what each covers and the term.
| Code | What it covers | Supplier | Term | Basis |
|---|---|---|---|---|
| TD17 | Integration or self-invoice for services bought abroad | Supplier not established in Italy | 15th of the month after receipt or after the operation | Art. 1(3-bis) D.Lgs. 127/2015; Agenzia FAQ |
| TD18 | Integration for intra-EU goods | EU supplier | Same | Art. 1(3-bis) D.Lgs. 127/2015; Agenzia FAQ |
| TD19 | Integration or self-invoice for goods under Art. 17(2) D.P.R. 633/1972 | Non-resident supplier | Same | Art. 1(3-bis) D.Lgs. 127/2015; Allegato A v1.9 |
Source: Agenzia delle Entrate, FAQ on cross-border invoices, and Allegato A to the technical specifications, version 1.9.
For an intra-EU purchase the data may be sent as an e-invoice of type TD18. For a non-EU purchase a self-invoice (autofattura) can be issued instead of the esterometro. The Italian buyer accounts for the VAT under reverse charge (inversione contabile), because Art. 17(2) D.P.R. 633/1972 has the obligations fulfilled by the Italian buyer.
Cross-border invoices already coming in?
Tell us which foreign suppliers and customers your Italian company deals with. We map each to a document type and a date.
How does a sale to a foreign customer work?
A sales e-invoice sent through the SdI with the recipient code (codice destinatario) XXXXXXX avoids sending the esterometro for that invoice. It does not avoid the Intrastat lists (modelli INTRA), which are a separate duty with their own rules; this page gives no Intrastat threshold. Without that code, the S.r.l. sends the data within the invoicing deadline of the sale, as set out above.
Operations covered by a customs declaration need no data file. For sales to Livigno and Campione d'Italia, an SdI invoice with code 0000000 and a copy to the customer replaces the data. Tax-free retail invoices issued through OTELLO need nothing.
What does the first month of a foreign-owned S.r.l. look like, invoice by invoice?
Take an S.r.l. owned and run from abroad. "The Italian company" is the reporter and "the foreign parent" is the owner abroad. Each row below is one invoice the company meets in its first month.
Six invoices of a foreign-owned S.r.l., the document or data each needs and the term.
| Invoice | Direction | Document or data | Term | Basis |
|---|---|---|---|---|
| Recharge or management fee from the foreign parent | Purchase | TD17 through the SdI; reverse charge | 15th of the month after receipt or after the operation | Art. 1(3-bis)(b) D.Lgs. 127/2015; Art. 17(2) D.P.R. 633/1972 |
| Cloud or advertising subscription from a foreign supplier | Purchase | TD17 through the SdI | Same | Agenzia FAQ; Art. 1(3-bis)(b) D.Lgs. 127/2015 |
| Goods from an EU supplier | Purchase | TD18 through the SdI | Same | Agenzia FAQ |
| Goods from a non-resident supplier already in Italy | Purchase | TD19 through the SdI | Same | Art. 17(2) D.P.R. 633/1972; Allegato A v1.9 |
| Sale to a foreign customer | Sale | E-invoice with XXXXXXX, or the data file | Invoicing deadline of the sale; 12 days in general | Art. 21(4) D.P.R. 633/1972; Agenzia FAQ |
| Hotel or service consumed abroad | Purchase | Not reported if each operation is EUR 5,000 or less, VAT included; reported above | Same as other purchases | Art. 1(3-bis) D.Lgs. 127/2015; Circolare 26/E |
Source: Agenzia delle Entrate, FAQ on cross-border invoices and Circolare 26/E of 13 July 2022; D.Lgs. 127/2015; D.P.R. 633/1972.
The reverse-charge VAT on a foreign supplier's invoice to an Italian business is accounted for by the Italian buyer. Late reverse-charge VAT is a separate breach under Arts. 6 and 13 D.Lgs. 471/1997, treated in the next section.
What is the penalty, and is VAT a separate matter?
The only state money in the topic is the penalty. Sending through the SdI or the Agenzia's own tools costs nothing from the state. For operations from 1 July 2022 the penalty is set by Art. 11(2-quater) D.Lgs. 471/1997, in force in this text to 31 December 2026.
The penalty for omitted or wrong data, its halving and the separate VAT breach.
| Case | Penalty | Cap | Basis |
|---|---|---|---|
| Omitted, incomplete or inexact data | EUR 2 per invoice | EUR 400 a month | Art. 11(2-quater) D.Lgs. 471/1997 |
| Data sent or corrected within 15 days of the deadline | Halved | EUR 200 a month | Art. 11(2-quater) D.Lgs. 471/1997 |
| Several invoices | Art. 12 D.Lgs. 472/1997 does not apply, so each invoice counts | The monthly caps above | Art. 11(2-quater) D.Lgs. 471/1997 |
| Late reverse-charge VAT or late self-invoicing | A separate breach under Arts. 6 and 13 D.Lgs. 471/1997 | Not part of the data penalty | Circolare 26/E |
Source: D.Lgs. 471/1997, Art. 11(2-quater); Agenzia delle Entrate, Circolare 26/E of 13 July 2022.
The cap is monthly and every invoice counts. A company that leaves out each reverse-charge purchase over a year faces up to EUR 400 a month for the data alone, and the VAT breach, if any, comes on top. Paying the VAT on time does not cure missing data. The page makes no claim about how often the Agenzia assesses the penalty.
What if a file is missed or wrong?
The statute gives a halved penalty for a quick correction. These steps follow what the law and the Agenzia's circolare say.
Find the missed or wrong operation
Compare the SdI files and receipts with the foreign invoices received and issued in the month.
Send or correct the data within 15 days of the deadline
This halves the penalty, to at most EUR 200 a month.
Check the VAT side separately
A late reverse-charge entry or a late self-invoice is its own breach.
Keep the corrected file and the SdI receipt
The files and receipts are the Agenzia's proof that the duty was met.
Note that every failure leads to one provision
Omitted, incomplete and inexact data all lead to the Art. 11(2-quater) penalty.
What changes on 1 January 2027?
The statute moves. Art. 1 D.Lgs. 127/2015 is shown as repealed from 1 January 2027 by D.Lgs. 19 January 2026, n. 10, the consolidated VAT act. Art. 11 D.Lgs. 471/1997 is shown as repealed from the same date by D.Lgs. 5 November 2024, n. 173, as amended by D.L. 31 December 2025, n. 200. The Normattiva page for the first article now carries the repeal from 1 January 2027.
- Amendments apply2017 amendmentsFrom 1 January 2019, invoices issued
- Last quarterly filingOperations to 30 June 2022
- SdI becomes the channelFrom 1 July 2022
- Current text endsArt. 1 D.Lgs. 127/2015 and Art. 11 D.Lgs. 471/199731 December 2026
- Both articles repealedReplaced by consolidated acts1 January 2027
- Successor rulesNot read
We have not read the successor articles. So this page prints no 2027 article number and no 2027 figure, and it does not say whether the EUR 5,000 exclusion, the 15th of the month or the penalty figures carry over. Check the two consolidated acts before relying on any figure here after 31 December 2026.
What does a founder abroad need in place?
Each item below is a condition of the duty, not a choice of route.
- Italian credentials for the legal representative, or a mandate to an intermediary.
- A sending channel that reaches the SdI.
- A list of foreign customers and suppliers, since every counterparty not established in Italy is in scope.
- The document type for each purchase: TD17, TD18 or TD19.
- A calendar of invoicing terms for sales and the 15th for purchases.
- Reverse-charge VAT accounted for on foreign suppliers' invoices.
- The SdI files and receipts kept as proof; see our digital archiving overview for storage rules.
- Employer registrations are separate: see registering as an employer with INPS.
- A check of the successor articles after 31 December 2026.
- Whoever sends the files, software or an enrolled intermediary, is a helper only: the liability stays with the company.
From our practice
We list the foreign counterparties with the owner and match each to a document type and a date. We then pass the calendar to whoever sends the files. The parent's recharge is the item we look for first, because it comes from the owner and is the easiest to miss. We do not send the files ourselves.
Sources
Every statement above rests on one of these eight pages, each read in the text in force on the date shown.
- Art. 1 D.Lgs. 127/2015, Normattiva: the duty, exclusions, SdI channel and deadlines; text in force from 12 August 2026 to 31 December 2026.
- Art. 11 D.Lgs. 471/1997, Normattiva: the penalty and its halving; text in force from 12 August 2026 to 31 December 2026.
- Art. 21 D.P.R. 633/1972, Normattiva: the 12-day invoicing term; text in force from 21 April 2026 to 31 December 2026.
- Art. 17 D.P.R. 633/1972, Normattiva: reverse charge; text in force from 2 August 2025 to 31 December 2026.
- Agenzia delle Entrate, FAQ on cross-border invoices: the nickname,
XXXXXXX, Livigno, TD18, self-invoices, tax-free invoices. - Agenzia delle Entrate, how to send an e-invoice to the customer: sending channels and the credentials its tools need.
- Agenzia delle Entrate, Circolare 26/E of 13 July 2022: the Agenzia's reading on the EUR 5,000 with VAT, worked deadlines, proof and the separate VAT breach.
- Art. 1 D.Lgs. 127/2015, text from 1 January 2027, Normattiva: the repeal from that date.