Article 1 (909) of law no. 205 dated 27 December 2017 (so called Budget Law 2018) states that, starting from 1st January 2019, it becomes compulsory to use electronic invoicing "for selling goods and providing services between resident, stable or identified subjects in the territory of the Italian State".
Starting from the above-indicated date any invoices prepared in non-electronic format or transmitted in a manner different from the Interchange System (SDI) will be considered to have not been issued.
With the above indicated law it is, therefore, no longer possible to issue not only invoices in paper form, but also invoices with an electronic format differing from the one envisaged by the Interchange System (for example it is no longer sufficient to transmit the invoice through company websites like the Web EDI one adopted by Enel).
In the light of what is indicated above, from 1st January 2019 the Italian companies of the Enel Group (list annexed) will have to receive invoices in electronic format issued exclusively using the SDI and according to the format envisaged in the in relations between private users as per the technical specifications published on the website of the Italian Revenue Office (www.fatturapa.gov.it).
However, Enel, with the aim of maintaining its virtuous digital relations and electronic transmission of the invoices sent through the Portal, has deemed it opportune to offer the suppliers of the Enel companies present in the Web EDI portal, a free intermediary service with the Revenue Office; all of this without changing the current process of using the Web EDI Portal, including the current responsibility of the subject selling the asset or rendering the service.
As a consequence, all the invoices transmitted on the portal and issued with invoice date from 1st January 2019 against Enel companies will be produced by Enel in the name of and on behalf of the supplier on XML data log (transmission format FPR12 - invoice to private customers - ver. 1.2 requested by the SDI), transmitted to the SDI and made available to the suppliers along with the receipt of correct issue or SDI rejection.
On the other hand, the invoices that will be transmitted directly by the suppliers to the Interchange System SDI, (therefore, not using the Enel Purchases Portal EDI Web service), will naturally be considered valid by Enel and thus covered.
In this case, as per contractual clauses in progress, the xml data log must report:
- the data of the Purchase Order (see technical specifications of the Revenue Office Tag XML SDI 2.1.2 “Purchase Order Data”)
- the data of the authorisation to payment for the provision of services (see XML Tag SDI 2.1.5 “Receipt Data”)
- the DDT data for the supplies (see XML Tag SDI 2.1.8 “DDT Data”)
The data of the authorisation to payment are anyway published in the new Section of the Suppliers Portal that you are invited to consult.
In absence of the data indicated above, the invoice cannot be processed and therefore a credit note will be requested.
It will not be necessary to indicate the recipient code or the certified email address of the Enel Company insofar as the Companies of the Enel group, through the registration service of the Revenue Office, have linked their own VAT number to their telematic address (Recipient Code of 7 figures identifying a Web Service channel) where to always receive all the e-invoices, regardless of the telematic address that the supplier indicates in the e-invoice.
Therefore, the suppliers are invited to produce the e-invoice starting from 01.01.2019, indicating the recipient code 0000000 (7 zeroes) in the XML file without sending any request aimed at obtaining the recipient code or the certified email address of the Enel Companies in the list.
In order to not invalidate the process, we ask you to always indicate the VAT number of the Customer Enel company (see annexed list) in the relevant field of the XML data log and to not use the field of the tax code.
Finally, it is hereby specified that when sending the first invoice through the WEB EDI portal with date of issue starting from 01.01.2019, the Master user must accept the electronic transmission agreement of the invoices to the SDI in the name of and on behalf of you through the disclaimer proposed by the EDI web system (the request of consent complies with the principles recommended by the General Data Protection Regulation (GDPR) adopted by the EU with effect from 25th May 2018).
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