Missed invoicing and reverse-charge breaches — penalties and voluntary correction after the 2024 reform

Summary

A 27 July 2026 analysis examines how omitted or late invoicing and reverse-charge (inversione contabile) breaches follow distinct penalty regimes under the reform in force since 1 September 2024 (Legislative Decree No. 87/2024). They are autonomous violations under Article 6 of Legislative Decree 471/1997: invoicing obligations fall on the supplier, while under reverse charge the customer must integrate, register and account for the VAT—so each attracts its own sanctions depending on who erred and how. [commercial…matico.com], [studiopizzano.it]
For taxable transactions, an omitted invoice is ordinarily penalised at 70% of the VAT (minimum €300); where it does not affect the VAT settlement, the fine is €250–€2,000. Failure to apply the domestic reverse charge is punished at €500–€10,000, or 5% of the taxable base (minimum €1,000) where the transaction is absent from the accounts. Wrongly charging ordinary VAT instead of reverse charge triggers fixed penalties with joint supplier–customer liability, and undue deduction attracts 70%. [commercial…matico.com], [studiopizzano.it]
The reform also lengthened the regularisation window to 90 days and, from 1 April 2025, made the distinction between document types TD29 and TD20 mandatory. In fraud contexts, all mitigation is lost and proportional penalties return in full (90%–180% of the tax). Italian case law confirms reverse-charge omissions are substantive (not merely formal) breaches, and that invoicing penalties do not absorb infedele-dichiarazione penalties—so businesses should apply ravvedimento operoso carefully to limit exposure. [commercial…matico.com], [lexced.com]