News · Business taxation · – 12 October 2026

Dormant VAT numbers: new criteria for ex officio closure and retroactive reactivation

TOPIC
The measure of 12 October 2026 identifies dormant VAT numbers also on the basis of invoices, electronic receipts and payments, sends the notice to the digital address and allows retroactive reactivation.

Art. 35, paragraph 15-quinquies, of Presidential Decree 633/1972, as replaced by art. 7-quater, paragraph 44, of Decree-Law 193/2016, converted into law by Law 225/2016, empowers the Agenzia delle entrate (Italian Revenue Agency) to close ex officio the VAT numbers of persons who, on the basis of the data available to it, do not appear to have carried on any business, artistic or professional activity in the three preceding years. The measure of 12 October 2026, ref. no. 277710/2026, rewrites several points of the measure of 3 December 2019, ref. no. 1415522/2019. Selection, previously based on failure to file VAT returns or business or self-employment income returns over the three-year period, now relies on automated checks of data in the Anagrafe tributaria (tax register), including data on electronic invoices, electronically transmitted receipts and payments made by the taxpayer (versamenti spontanei). The prior notice is sent to the digital address under art. 60-ter of Presidential Decree 600/1973 or, failing that, to that of the representative, and otherwise by registered post; it can be viewed in the Cassetto fiscale (online tax account), section “L’Agenzia scrive”, with an alert in the secure personal area and through the App IO, which the consolidated version of the measure limits to recipients who are natural persons. Closure takes effect from the sixtieth day after receipt or, if delivery fails, from the date the notice is made available in the secure personal area; the text does not clarify whether the sixty-day period also applies in that case, which remains in our view the only reading consistent with the right to object.

Dealings with the tax office take place in two stages. Within sixty days of receipt the taxpayer may apply to any local office to object, showing that it is still carrying on its activity; after that period it may submit a reasoned request for reactivation, which the office may grant with effect from the original opening date, without interruption. For persons other than natural persons with no evidence of activity, closure entails the extinction of the tax identification number (codice fiscale), which may be reactivated with effect from the original date of assignment. Under the 2019 text the office could only close the file on the notice or reject the request. Adding invoicing and payment flows to return data particularly exposes property-holding companies with no business activity and protracted liquidations with no outgoing invoices: for these, a timely objection is advisable, since reactivation is left to the office’s assessment and is not a matter of entitlement. The procedure must not be confused with closure for risk under paragraphs 15-bis and 15-bis.1, which entails the EUR 3,000 penalty under art. 11, paragraph 7-quater, of Legislative Decree 471/1997 and a guarantee of at least EUR 50,000 for a new VAT number (paragraph 15-bis.2). Failure to file a declaration of cessation is no longer penalised by art. 5, paragraph 6, of Legislative Decree 471/1997.

IN PRACTICE
The adviser assisting the taxpayer should monitor the digital address, the Cassetto fiscale and the App IO and, once the notice is received, file with a local office within sixty days evidence of activity: contracts, invoices, registers, bank transactions. After closure, a reasoned request for reactivation is required, supported by documentation on the activity carried on in the three-year period. The delivery receipt of the notice, from which the sixty days run, should be kept. The measure does not, however, state an effective date of its own or deal with notices already sent. As from 1 January 2027 ex officio closure will be governed by art. 68, paragraph 24, of Legislative Decree 10/2026; closure for risk and the guarantee by paragraphs 19, 20 and 21 of the same article; penalties by art. 30, paragraph 11, and art. 36, paragraph 14, of Legislative Decree 173/2024; the digital address by art. 268 of the Consolidated Act (testo unico) approved by Legislative Decree 141/2026.

Summary note by the CommercialistiAvvocati network, based on specialised legal and practice sources. The text does not reproduce original contributions and does not constitute professional advice.

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