Special archiving requirements for Italy (conservazione sostitutiva)
The Italian mandate for electronic invoicing contains an additional set of requirements for archiving, called conservazione sostitutiva. These requirements are not present in other countries and are not part of the standard scope of SAP Document Compliance.
According to the Italian law, there are two possible options to cover this requirement:
- Procure a third-party provider. The list of available accredited high-quality providers can be found on the website of AGID.
- Since January 2019, it is also possible to use the free service provided by SOGEI (the provider from the Italian tax agency). Go to the government portal, select Fatturazione elettronica and look for the free service for digital archiving. This service is as compliant as the third-party offerings.
If you choose to enable this requirement through a third-party provider, the Document Compliance solution offers two options: build the integration on the backend or use the communication platform.
Integration with third-party on the backend
The integration on the backend enables automatically executing the necessary steps to send the relevant files (invoices and related messages) to the provider before executing the usual archiving. This can be accomplished using a BAdI delivered with the following notes:
Prerequisites of Archiving BAdI for Italy:
- Notes 2828767 and 2810826
Archiving BAdI notes for Italy:
- 2832913 – eDocument Italy: Prerequisite for SAP Note 2814431
- 2814431 – eDocument Italy: Enhancements
- 2870763 & 2170013 – Documentation
Integration with third-party on the communication platform
During the communication of the invoices using SAP Cloud Platform Integration Suite, additional steps can be executed by the communication platform. For example: the digital signature is done by calling an external provider before finally sending the invoice to the web service of the tax authorities. The same approach can be taken for archiving. The delivered integration packages for Italy can be modified to send the invoices to an archiving third-party service after they are accepted by the tax authorities. The process orchestration and which messages need to be exchanged are defined by each service provider.