In September 2020, the Italian Digitization Agency (Agenzia per l'Italia Digitale- AGID) introduced new "Guidelines on the Formation, Management and Preservation of Computerized Documents", which were due to be enforced as of June 7th, 2021. The new guidelines contain a static text and six flexible annexes, more adaptable to the dynamic changes in technology. In this way the Italian government sought to create a single legislative framework for the issuance, registry, management, and archiving of electronic documents, including e-invoices.
However, on May 18th, 2021, AGID announced that the new e-document regulations will come into force on January 1st, 2022. What is more, amendments to the guidelines as well as annexes 5 and 6 regarding metadata and communication between AOO of Registered Administrative Documents were introduced. The guidelines will update the technical rules of the Digital Administration Code (DAC).
The regulations affect the issuance and storage of e-invoices, and must be followed by taxpayers who store e-invoices under Italian law. New guidelines extensively regulate e-invoice storage infrastructure and the role of the Conservation Manager, who is responsible for the preservation of electronic documents. The regulations in question state that this particular role may be outsourced.
According to Italian law, e-documents are only valid if they are properly stored, or rather preserved. In order to properly preserve an e-document, it must be mapped to an “archive package”, hashed, signed and timestamped, all before the e-document is archived. Additionally, an auditor must be able to find and retrieve e-invoices using certain metadata, such as type of document or tax identification number.
Due to the concerns issued by local organizations, AGID modified metadata requirements. An extensive list of metadata fields to be stored with e-invoices and e-documents in general was set forth to ensure flexibility and improve interoperability and transparency. Descriptions of some fields were corrected, and new pieces of metadata were added.
In other words, companies are required to update their internal procedures of e-invoice archiving to ensure compliance and interoperability in the preservation process.