Switching to Direct Registration in Italy (Avoiding the Bank Guarantee)

What this article covers

Some clients registered for Italian VAT through a fiscal representative can avoid the €50,000 guarantee (bank or insurance surety) requirement altogether by switching to direct registration. This article explains who is eligible, what direct registration means in practice, and how the switch works.

Why does this option exist?

The €50,000 guarantee only applies to non-EU/EEA businesses that are registered for Italian VAT through a fiscal representative and wish to register or remain registered in VIES. Italian VAT law also allows businesses established in the EU, the UK, or Norway to register for VAT directly, without appointing a fiscal representative. Because the guarantee requirement is tied specifically to fiscal representation, a business that registers directly is not subject to it — regardless of whether it trades cross-border or holds VIES status.

Who is eligible to switch?

A client is eligible for direct registration if all of the following apply:

• The company is currently registered for Italian VAT through a fiscal representative.

• The company is established in an EU member state, the United Kingdom, or Norway.

• The company does not have another reason to require fiscal representation (e.g. no other non-EU establishment driving the requirement).

Clients established outside the EU/UK/Norway are not eligible for direct registration and must use a fiscal representative — for these clients, the bank guarantee remains a requirement (see “Italian VAT Bank Guarantee — What You Need to Know”).

What does the switch involve?

Moving from fiscal representation to direct registration involves three steps:

• Deregistration of the existing Italian VAT number held through the fiscal representative. A deregistration fee applies for this step — your account manager will confirm the exact amount.

• New direct registration submitted in the company’s own name, resulting in a new Italian VAT number. The previous codice fiscale is retained as part of this process — only the VAT number changes, not the codice fiscale.

• Transition support from Taxually to make sure ongoing filing obligations and any open periods are handled correctly across the change.

Because this results in a new VAT number, clients should be aware that:

• The previous VAT number is closed and can no longer be used on invoices once the change takes effect.

• Marketplaces (e.g. Amazon) and accounting systems need to be updated with the new VAT number.

• VIES status under the new number is reinstated as part of the direct registration, without any guarantee requirement.

• The annual VAT return for the deregistration year still has to be filed for both VAT numbers in the same return.

Ensuring continuity between the old and new VAT ID

To avoid a compliance gap between the two registrations, Taxually helps determine the right timing for the new direct registration relative to the deregistration of the old VAT number. Continuity between the old and new VAT ID depends on the codice fiscale staying the same across both — as long as this is the case, a safe general guideline is to submit the new registration within 30 days of the deregistration; any transactions falling in between can still be reported retroactively once the new registration is active. Please note that the 30 days is only a guideline and not a strict legal requirement as the new VAT ID can be requested beyond this point. It isn’t possible to request a specific start date for the new VAT number — the Italian Tax Authority sets this as the date the registration request is submitted — so Taxually will advise on timing to help keep any gap within this window.

Why would a client choose this over the bank guarantee?

Direct registration avoids the bank guarantee obligation entirely — there is no €2,800 insurance premium and no ongoing guarantee to maintain. It may suit clients who are eligible and who would prefer not to take on the bank guarantee process. It’s not automatically the better option for every eligible client, however: clients should weigh the practical impact of a new VAT number (re-issuing invoices, updating marketplace listings, notifying customers) against the cost of the guarantee before deciding.

Frequently asked questions

Will I lose my current Italian VAT number?

Yes. Direct registration requires deregistering the existing VAT number and issuing a new one. Your codice fiscale, however, is retained — it does not change as part of this process.

What is the codice fiscale, and why does it matter that it stays the same?

The codice fiscale is the Italian tax identification code assigned to your company by the Tax Authority. It’s separate from the VAT number itself, and it’s what identifies your business across your dealings with the Tax Authority — including annual return filings — independently of which VAT number happens to be active at a given time. Keeping the same codice fiscale across the deregistration and the new direct registration is what ties the two VAT numbers together as a continuation of the same underlying tax record, which is why it matters for continuity. If the codice fiscale were to change instead, the old and new registration would be treated as two entirely separate entities, with a strict cutoff at the deregistration date and two separate annual filings required.

Is there a fee for switching to direct registration?

There is no bank guarantee premium under direct registration. A deregistration fee does apply for closing the existing VAT number, though, and any applicable registration or service fees will be confirmed separately by your account manager.

Can I switch back to fiscal representation later?

Yes, but switching back would mean the bank guarantee requirement applies again. Please contact us if your circumstances change.

What if I’m not eligible for direct registration?

If your company is established outside the EU, UK, or Norway, you’ll need to remain with a fiscal representative and arrange the bank guarantee. See the related article below for details.

Related articles

• Italian VAT Bank Guarantee — What You Need to Know

• How Taxually Supports You with the Italian VIES Bank Guarantee

ℹ Informational content only. This article is for general information and does not constitute tax or legal advice. For questions about your specific situation, please contact the Taxually support team.