New POS data reporting requirements in Italy

What you need to know

• From January 1, 2026, PSPs must report POS transaction data monthly to the Italian Revenue Agency via the SID system.
• Reports must be encrypted, digitally signed, and include new data fields.
• There are three submission types: ordinary, replacement, and cancellation.
• The Agency will provide annual summaries for reconciliation; stricter compliance checks will apply.

What you need to do

• Update systems to capture and report all required data fields.
• Ensure SID accreditation and secure data transmission processes.
• Set up procedures for timely error correction and managing different submission types.
• Prepare for annual reconciliations and train staff on new compliance requirements.

The Italian Revenue Agency’s Provision No. 142285/2025 of 21 March 2025, together with its four technical annexes and the related guidance published in the following days, introduces a major revision of the reporting obligations for payment service providers (PSPs or acquirers) regarding data on electronic payment instruments made available to merchants and the daily totals of transactions carried out through such instruments.

Moving from the experience of the existing reporting system via PagoPA S.p.A., certain potential improvements have been identified with respect to the content of the reports. Starting from 1 January 2026, the reporting process will undergo significant changes in terms of channels, content, timing, and control mechanisms. PSPs should already be taking steps to ensure compliance and operational readiness.

Direct submission via SID

Until 31 December 2025, data transmission continues via PagoPA S.p.A.

From the January 2026 reporting period, PSPs must submit data directly to the Italian Revenue Agency through the Data Exchange System (SID).

Accreditation to SID – including encryption and signature certificates, and a valid PEC address – is now a mandatory technical prerequisite. Submissions will only be accepted if files are encrypted, compressed, and digitally signed using the Agency’s official control software available in the SID reserved area.

Monthly reporting with a built-in “grace window”

Reports remain monthly, due by the last business day of the following month. Saturdays are non-working days, and transmissions made by the last calendar day of the month will still be considered on time.

If the receipt indicates total or partial errors, PSPs have five business days to resubmit the rejected records.

Expanded reporting perimeter (Code “TRA26”)

The mandatory data set is broadened. PSPs must now report, in addition to basic identifiers and transaction totals:

1. the unique code of the merchant acquiring contract;
2. the relationship ID (code “96” of the Financial Accounts Register);
3. the unique POS identifier;
4. POS type (00 = physical, 01 = e-commerce);
5. transaction type (00 = payment, 01 = refund);
6. currency (fixed value “978”); and
7. PSP ABI code or tax ID in the header record.

Files must follow the “Comunicazione Transato” XML layout, with fixed-length records (349/350 bytes) structured into header (type “0”), detail (type “1”), and trailer (type “9”). Each submission is labelled with the code “TRA26”.

Correction and replacement logic

The new framework introduces a structured filing typology:

1. Ordinary filing (Type = 0) for the first submission;
2. Replacement filing (Type = 1) to fully correct an already accepted file;
3. Cancellation filing (Type = 2) to delete a previously validated file.

For types 1 and 2, PSPs must reference the original file protocol number; otherwise, the entire submission will be rejected.

Receipt management and correction deadlines

A transmission is deemed completed only once a positive receipt is issued.

Receipts may indicate:

1. code 000 – fully accepted and on time;
2. code 100 – accepted but late;
3. codes 002–020 – rejected, with reasons detailed.

Rejected records must be identified and corrected within five business days.

Annual “data consistency snapshot”

The Agency will, within the first quarter of each year, make available a consolidated dataset summarising the transactions reported during the previous year (“fotografia di consistenza”). PSPs must reconcile this with their internal data and, where discrepancies are found, submit corrective or replacement communications.

Immediate next steps

PSPs should:

• ensure SID accreditation is completed and technically validated;
• update back-office systems to include the new mandatory fields;
• implement file validation and encryption procedures before transmission;
• design error-handling workflows to meet the five-day resubmission rule;
• establish periodic data-quality checks to align reported data with internal records and the future annual snapshot;
• train relevant staff on new transmission logic, error codes, and corrective actions.

Compliance and penalties

No new penalties have been introduced, but the obligation derives from Article 22(5) of Decree-Law No. 124/2019. Failure to submit, or incomplete submission, may trigger sanctions under Legislative Decree No. 471/1997 on reporting obligations to the Tax Registry (Anagrafe Tributaria).

The reported data will feed into the Agency’s monitoring of electronic payment compliance; significant inconsistencies may also impact assessments under Article 18 of Decree-Law No. 36/2022 (refusal of electronic payments).

In practice, PSPs should treat this as a strategic compliance upgrade: technical adaptation to the SID platform, structured monthly reporting, and alignment of internal transaction data with the new government validation mechanisms are essential to avoid rejections, delays, or discrepancies once the new regime becomes mandatory in 2026.