Forfettario invoice in Italy: RF19, N2.2, stamp duty and the legal wording

You can tell an invoice under the regime forfettario (Italy’s flat-rate tax regime) by what isn’t on it: no VAT and no withholding tax (ritenuta d’acconto). In their place are a regime code, a nature code, a legal sentence and, almost always, €2 of stamp duty (imposta di bollo). Here you’ll find every field a forfettario’s e-invoice must carry, why it’s needed, and what changes with a foreign client or an invoice issued late.

If the regime is new to you, start with how the regime forfettario works and come back here when you need to issue your first invoice.

Does a forfettario have to issue e-invoices?

Yes. According to the Agenzia delle Entrate, since 1 January 2024 e-invoicing through the SdI (Sistema di Interscambio, the state’s e-invoicing exchange system) has been mandatory for every forfettario, whatever their revenue or fees. The obligation arrived in two stages, under art. 18 of D.L. 36/2022:

The e-invoice goes to Italian companies and professionals and to private customers too. With foreign clients the e-invoice is a choice, as you’ll see further down.

Some of the pages of the Agenzia delle Entrate (the Italian Revenue Agency) on the regime forfetario still say that forfettari «non devono applicare» (do not have to apply) the e-invoicing obligation. That’s the text from before 2022: circolare n. 32/E of 2023 and the Agenzia’s December 2025 guide confirm the obligation for everyone from 2024.

One exception worth knowing: if you provide healthcare services to individuals, you don’t send those invoices through the SdI, to protect the confidentiality of health data.

The fields that set a forfettario’s invoice apart

Name, partita IVA (Italian VAT number), codice fiscale (tax code), number, date, description and amount are the same as on any invoice. What makes it a forfettario’s invoice are these fields:

RF19, the regime code

In the supplier’s block (cedente/prestatore), the RegimeFiscale field takes the value RF19, which the FatturaPA technical specification describes as «Regime forfettario (art.1, c. 54-89, L. 190/2014)» (flat-rate regime). Someone in the regime ordinario (the ordinary regime) uses RF01. In the Agenzia’s free procedure it’s the field «Regime fiscale valido per la fattura che si sta generando» (tax regime valid for the invoice being generated).

N2.2 in place of VAT

On every line of the invoice the VAT rate is 0% and the Natura field is N2.2, «non soggette – altri casi» (outside the scope – other cases). It isn’t an exemption (that’s N4, exempt, esente) and it isn’t a non-taxable transaction (N3, non imponibile): it’s a transaction outside the scope of VAT (non soggetta) because the law on the regime says so.

The legal wording

In the Causale field the Agenzia asks you to give the legal reference for why no VAT appears. The wording it gives in its guide is this:

«Operazione effettuata in regime forfettario ai sensi dell’articolo 1, commi da 54 a 89, della Legge n. 190/2014 e successive modificazioni» (transaction carried out under the flat-rate regime pursuant to article 1, paragraphs 54 to 89, of Law no. 190/2014 as amended)

If you’re a professional, add a second reason, because a client who is a withholding agent (sostituto d’imposta) must not withhold tax from you:

«Operazione non soggetta a ritenuta alla fonte a titolo di acconto ai sensi dell’articolo 1, comma 67, Legge n. 190 del 2014 e successive modificazioni» (transaction not subject to withholding tax on account pursuant to article 1, paragraph 67, of Law no. 190 of 2014 as amended)

In the Fatture e Corrispettivi web procedure (the Agenzia’s free invoicing portal) there’s a template for forfettari with these fields already filled in: you’ll find it under «Fatturazione elettronica e Conservazione» (e-invoicing and archiving), in «Generazione da template» (generate from template).

The €2 marca da bollo on an invoice: when it applies

An invoice that carries no VAT pays stamp duty. What everyone calls an invoice with a marca da bollo (the paper revenue stamp) today has no stamp stuck on it at all: on an e-invoice the stamp is virtual, it’s flagged in the file and paid to the Agenzia every quarter.

According to the Agenzia delle Entrate’s guide on stamp duty, it applies when the total of the line amounts is over €77.47 and the lines have nature N2.1, N2.2, N3.5, N3.6 or N4. For a forfettario, then, almost every invoice over €77.47 has the stamp duty. The amount is always €2 per invoice.

What you do in practice:

1. In the DatiBollo block, set the BolloVirtuale field to «SI» (yes).
2. Include the €2 in the document’s total amount, as the Agenzia says.
3. Pay the quarter’s stamp duty after the Agenzia has worked out the amount.

Every quarter the Agenzia prepares two lists in your personal area in Fatture e Corrispettivi: list A with the invoices where you flagged the stamp duty, and list B with those where it’s missing but seems to be due. You can correct list B by the deadline; after that, the Agenzia works out what’s due.

If the first quarter’s stamp duty is no more than €5,000, you can pay it by 30 September; if the first and second quarters together stay within €5,000, by 30 November. You pay by direct debit from your personal area or with the F24 (the unified payment form), tax codes 2521 to 2524, one per quarter. If a deadline falls on a public holiday it moves to the next working day.

If you pay late, the web procedure works out the penalty and interest under ravvedimento operoso (voluntary correction with reduced penalties). A forgotten stamp duty doesn’t disappear: if you don’t flag it yourself, the invoice ends up on list B and the stamp duty is worked out for you anyway.

The 4% INPS surcharge

If you’re a professional registered with the INPS (Italy’s social security institute) Gestione Separata (the separate fund for professionals), art. 1, comma 212, of L. 662/1996 lets you charge your client 4% of your gross fees: the 4% INPS surcharge (rivalsa INPS). It’s an option, not an obligation: you can apply it or not.

If you apply it, on the invoice you fill in the DatiCassaPrevidenziale block with fund type TC22 (INPS) and the 4% rate. The surcharge isn’t a contribution you pay on the client’s behalf: it’s added to your fee, and you pay your Gestione Separata contributions yourself, as always. How those contributions work is in INPS contributions for a partita IVA.

The surcharge doesn’t concern artisans and traders, nor professionals with a professional pension fund (cassa professionale) of their own, who follow their fund’s rules.

Foreign clients

With a client who is neither resident nor established in Italy, the e-invoice is optional. You have two routes:

• Issue an e-invoice anyway through the SdI with recipient code (codice destinatario) XXXXXXX (seven Xs). In the IdPaese field put the client’s country code, in the IdCodice field their tax identifier (up to 28 characters), and in the postcode (CAP) the value 00000.
• Issue a non-electronic invoice and report the transaction to the Agenzia with the cross-border transactions report (the so-called esterometro).

With the first route you avoid the separate report, because the data reaches the Agenzia with the invoice. Code RF19 and the legal wording stay. What changes is the line’s nature, which depends on the transaction: a service to a foreign company doesn’t follow the rules of goods sold to a private customer. The Agenzia refers to paragraph 4.1.2 of circolare n. 10/E of 2016 for the obligations with non-residents: this is the case where it’s worth talking to a commercialista (accountant) before the first invoice.

An invoice to a foreign client also pays the €2 stamp duty if it’s over €77.47 and the nature is one of those listed above.

What happens with a late invoice

An invoice is issued within twelve days of the transaction. Today the rule is in art. 21 of DPR 633/1972; from 1 January 2027 it moves to art. 72 of the new consolidated VAT act (Testo unico IVA, D.Lgs. 10/2026), with the same time limit.

If in the same month you carry out several transactions with the same client and they’re documented, for example by a delivery note (documento di trasporto), you can issue a single deferred invoice by the 15th of the following month.

Three things to know when an invoice is late or comes back:

• Rejected by the SdI. In law, a rejected invoice was never issued. Fix the error and send it again: the Agenzia advises using the same date and number as the rejected one.
• Issued after the time limit. It’s a breach punished with an administrative penalty, which can be reduced with ravvedimento operoso. Ask your commercialista for the exact amount in your case.
• Not delivered. If the SdI can’t deliver it, it makes it available to the client in their personal area and sends you a receipt saying delivery wasn’t possible. For you the invoice is issued; let the client know by email or phone. To know which code to ask the client for, read what the SdI code is.

An issued invoice isn’t a paid invoice. If the due date passes without a bank transfer, the steps to follow are in payment reminder for an invoice.

Summary: the rule in one line

Every forfettario invoice goes through the SdI (except, if you like, one to a foreign client), carries RF19 and N2.2 in place of VAT, the wording of art. 1, commi 54–89, L. 190/2014, and €2 of virtual stamp duty above €77.47. If you’re a professional in the Gestione Separata you can add the 4% INPS surcharge. The rest is the same as any invoice: numbered, dated and issued within twelve days.

A well-made invoice is a clear conversation with your client: they know what they’re paying for, and you know everything is in order.
💜💙 Your BravoLisa Team

This article is for general information purposes only and does not constitute professional tax, legal, or accounting advice. Every situation is different — consult a qualified professional (tax adviser, accountant, or lawyer) for advice specific to your circumstances. BravoLisa does not accept liability for decisions made based on this information.

Last updated: September 2026. Rates and thresholds can change: always check with the Agenzia delle Entrate, INPS or the relevant authority.

Sources (9)

Verified on 30 September 2026

1. Agenzia delle Entrate — La fattura elettronica e i servizi gratuiti dell'Agenzia delle Entrate (guida, dicembre 2025)
2. Agenzia delle Entrate — Fattura elettronica per i forfettari
3. Agenzia delle Entrate — Circolare n. 32/E del 5 dicembre 2023 (regime forfetario)
4. Agenzia delle Entrate — L'imposta di bollo sulle fatture elettroniche (guida, giugno 2026)
5. Agenzia delle Entrate — Regime forfetario: Semplificazioni e adempimenti
6. Agenzia delle Entrate — FAQ fatturazione elettronica: compilazione della fattura elettronica
7. FatturaPA — Specifiche tecniche del formato FatturaPA, versione 1.4
8. Normattiva — Legge 23 dicembre 1996, n. 662, art. 1, comma 212
9. Gazzetta Ufficiale — D.Lgs. 19 gennaio 2026, n. 10 (Testo unico IVA)