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Logical link between RT and payment collection tools: the new guidance from the Revenue Agency

Regulatory framework and purpose
The 2025 Budget Law (Law No. 207/2024, Art. 1, paragraphs 74–77) introduced, from 1 January 2026, two distinct obligations for merchants:
• Obligation to indicate in the commercial document whether payment was made in cash or by electronic means.
• Obligation of logical linking between the Telematic Registrars (RT) and the collection tools used (POS, SoftPOS, Satispay, and other electronic payment instruments).
The purpose is to ensure consistency between the revenue data stored/transmitted by the RTs and the electronic transaction data communicated by acquirers, enabling cross-checks by the Tax Administration.
Sanctions предусмотрed
Failure to link POS–RT: from 1,000 to 4,000 euros payable by the Merchant.
Failure to store/transmit: 100 euros for each violation, up to a maximum of 1,000 euros per quarter, always payable by the Merchant.
Scope of application
The link is MANDATORY in the following cases:
• The POS is used to collect revenue certified with a commercial document (RT or Online Commercial Document).
• The POS is used both for transactions with a commercial document and for transactions outside the scope of VAT (e.g. sale of tobacco products, monopoly goods).
• The POS is used both for transactions with a commercial document and for transactions with an invoice.
• The POS is used both for transactions with a commercial document and for fuel sales or via vending machines.
The link is NOT REQUIRED if the POS is used exclusively for:
• Transactions exempt from the obligation of electronic storage/transmission (pursuant to Art. 1, Ministerial Decree of 10 May 2019).
• Sales through vending machines (vending machine), fuel sales and electric vehicle charging.
• Sales documented exclusively with an invoice.
Guiding criterion: if the POS is used ALSO for transactions subject to a commercial document, the link must always be registered.
Devices involved
The term “POS” includes any hardware or software device, physical or virtual, acquired through a merchant acquiring agreement with an acquirer:
- Physical POS (including SoftPOS): identified by Terminal ID + Acquirer Tax Code + Acquirer Name.
- Virtual POS (payments via internet/app): identified only by Acquirer Tax Code + Acquirer Name (no Terminal ID).
The obligation to link concerns:
Telematic Registrars (RT) and RT Servers
Web procedure “Online Commercial Document” (for example the Smart Receipts of A-Cube)
Software solutions (currently not yet available on the market).
Linking method
The required link is not physical but logical, i.e. it consists of a communication made through a web procedure on the Agency's "Invoices and Receipts" portal (read the operational guide here the operational guide here) without any need to replace or adapt the devices already in use.
The communication is made once only and, thereafter, only in the event of new items or changes compared with what has already been communicated.
Start-up phase – POS already in use in January 2026
Within 45 days from 5 March 2026
(the procedure will be available in the “Invoices and Receipts” portal from that date)
Operational phase – New POS or changes
Between day 6 and the last day of the second month following the change event.
e.g. a POS activated in March 2026 must be communicated by 31 May 2026.
The IT procedure
Access available from 5 March 2026:
from the “Invoices and Receipts” portal → “Receipts” section → “Managers and Merchants” → “Device linking – POS”.
The procedure is pre-filled with:
The POS data communicated monthly by acquirers.
The RTs active in the reference period (which corresponds to the second month preceding the linking month).
The point-by-point mode provides two variants depending on the number of active RTs:
Simplified (up to 5 RTs): registration by ticking pre-filled lists on a single screen. Select the RT serial number, the POS to associate and enter the address of the sales outlet.
Standard (more than 5 RTs): search using filters by acquirer or Terminal ID and selection of the POS to link.
For merchants with many devices, the bulk mode allows you to:
Download a pre-filled CSV file with the data of active POS.
Populate the CSV file with the data of the RTs to be linked.
Upload the completed CSV file.
The “Bulk requests history” function allows you to check any errors.
The bulk mode does not allow adding POS not present in the system: in that case, manual entry via the point-by-point procedure is required.
For merchants using the web procedure “Online Commercial Document” (Smart Receipts):
The link must be carried out directly in the web procedure, in the new section “Support functions” → “Association of electronic payment instruments”.
This operation CANNOT be delegated: it must be carried out personally by the merchant.
If the link has not been carried out, the procedure will display an information message when the commercial document is issued.
From here it is then possible to query the associations between POS and Online Commercial Document, already communicated, carry out a new association via the Insert link, button, and view the POS for which no association is yet recorded(Unlinked POS button)
Resources and support
The Italian Revenue Agency has made available:
An operational guide published in the “Electronic invoicing and telematic receipts” area of the institutional website.
Help pages with explanatory screens, accessible from the “Invoices and Receipts” portal via the “Info and support” service.
The usual technical and administrative support channels.
The ruling procedure for complex interpretative matters.
Updated FAQs (still in the publication phase).


