Understanding Italy’s new legislation for non-EU sellers 

The Italian Tax Authority has introduced new legislation effective April 10, 2025.

This legislation, established under Article 17 of Presidential Decree No. 633/1972, requires a €50,000 bank guarantee from all non-EU/EEA businesses registered in Italy that use a fiscal representative. This must be paid by 14 June 2025 to avoid actions from tax authorities that could result in the deactivation of VAT and VIES numbers.

It also requires a guarantee provided by your fiscal representative.

Let’s explore what this means for non-EU/EEA sellers, the upcoming deadlines, and the steps you can take to ensure compliance.

Who needs to pay the €50k guarantee?

All non-EU/EEA VAT-registered companies and new VAT applicants in Italy using a fiscal representative must meet this requirement.

Who’s exempt?

The EU, UK, Norway, Iceland, and Liechtenstein are outside the scope, but the Italian Revenue may still request guarantee bonds.

Key facts about the new Italian VAT rules

How does this new regulation affect non-EU companies? 

It affects both new and existing VAT-registered businesses selling to Italy from outside the EU/EEA. Under the new legislation, a guarantee of €50,000 is required in one of three forms:

• Bank guarantee  

• Insurance guarantee  

• Direct deposit with the beneficiary, Agenzia delle Entrate (Italian Revenue Agency)

How long is the €50k guarantee valid for?

The guarantee requested from the fiscal representatives remains valid for 36 months.

How does this new regulation affect the fiscal representatives?  

The Italian Revenue Agency requires an insurance guarantee from fiscal representatives. This varies from €30,000 to €2,000,000 based on the number of companies represented. This guarantee is valid for 48 months. It applies to new and existing Italian VAT registrations.

Further reading and official guidance about the individual and fiscal representative guarantees

• Provvedimento del 14 aprile 2025
• Provvedimento del 17 aprile 2025

What are the deadlines for paying this guarantee? 

• 14 JUNE 2025: Deadline for submitting your guarantee to the Italian Tax Office. All existing non-EU VAT-registered companies must meet this requirement by this date. If you haven’t met this deadline, the authorities may give you a 60-day grace period – and you can continue selling in this time.

• 14 AUGUST 2025: Deadline for the Italian Tax Office to review and verify the submitted guarantees.

• 14 SEPTEMBER 2025: Non-compliant businesses will be deregistered. A warning will be issued before this action.

What should you do now? 

• Start the process of obtaining the €50,000 guarantee.

• Prepare the necessary documentation with your regular bank or insurer (note that they do not need to be based in Italy).

• Submit the guarantee, clearly stating the Italian Revenue Agency as the beneficiary. All supporting documents must be translated into Italian and include an Apostille.

❗The Italian Revenue Agency will only accept bank guarantees issued using the template provided on its official website. They’ll reject any modifications to the guarantee letter.

3 strategies for complying with this new rule

Option 1: Provide the €50,000 guarantee and maintain Italian VAT registration (recommended!)

Submit the required €50,000 financial guarantee in the proper format before the deadline to continue VAT registration and local fulfilment in Italy.

Option 2: Obtain an insurance policy in compliance with official Italian standards

To obtain insurance, ensure a recognised insurance provider issues it and follows the official Italian format. The issuing bank or insurer does not have to be Italian, but the documentation must follow the exact required wording and format. If the tax office does not recognise the issuer, it may investigate and potentially reject the guarantee.

Option 3: Direct Deposit of bonds 

Use a direct deposit of €50,000 in Italian government bonds purchased in Italy, following the official format provided by the Italian Tax Office.

What happens if you do nothing? 

We definitely don’t recommend this course of action, because you’ll risk: 

• Losing your Italian VAT number, and a revoked VIES listing that limits intra-EU B2B trade 

• Suspension from Amazon or other marketplaces
• Impacted cross-border sales and the ability to use Amazon’s fulfilment centres

• Audits, penalties, and enforcement by Italian tax authorities 

• Having to re-register for Italian VAT and pay the guarantee anyway 

• A penalty of €50,000 

Non-payers will get a grace period of up to 90 days to respond with a valid guarantee. 
 

Recap: your main takeaways about the new Italian VAT rules 

• The new Italian VAT regulations require a mandatory financial guarantee for €50,000 for non-EU sellers and new VAT applicants in Italy (except in the UK and EEA countries). 

• The deadline to submit this guarantee is June 14, 2025 and it remains valid for 36 months (3 years).
• The regulations also require fiscal representatives to provide a guarantee with a minimum of 48 months’ coverage.

• If you are a non-EU or EEA seller trading or planning to trade in Italy with a fiscal representative, securing the €50,000 guarantee is mandatory.

• Assess which option best suits your business, but doing nothing at all isn’t an option, as it will lead to a penalty of the same amount.

(!) Per tax legislation, this is not mandatory, but the tax office may request this.

The clock is ticking – start the process of securing your guarantee today!