CUP in e-invoices: New functions of the Revenue 2025 regulation

Learn how to integrate or modify CUP to your e-invoice with the October 12, 2025 revenue provision that simplifies incentivized purchases.

How to combine cups on invoices for a lower purchase price

Posted on December 11, 2025

In this article:

An intervention expected by professionals, businesses and public administrations involved in the management of electronic invoices linked to public incentives has arrived, thanks to provision no. 563301 of the Revenue Agency of December 10, 2025.

The purpose of this document is to eliminate operational difficulties arising from the obligation, effective June 1, 2023, to specify a Uniform Project Code (CUP) on invoices for goods and services financed through donations, concessions or public subsidies.

Despite the regulatory provision, the implementation of the CUP proved difficult in daily practice: many invoices were issued without reporting the code or marked it incorrectly, causing problems in accounting, reporting and incentive control.In response to these critical issues, provision 563301/2025 introduces a new digital tool that allows the acquirer or client - and its authorized intermediary - to merge or correct the CUP even after sending the invoice to the exchange system (SdI).

The cup is ready

The obligation to indicate the Unique Project Code (CUP) on electronic invoices is derived from article 5, paragraph 6, of Legislative Decree No. 13 of 2023, which introduced transparency and traceability of expenses financed with public funds.

The rule stipulates that all invoices related to the acquisition of goods and services subject to incentives for productive activities - provided by the public administration or third parties acting on their behalf - must have a CUP related to the financial plan.

The coverage, established by Law No. 3 of January 16, 2003, represents a unique distinction that accompanies the entire life of a public investment.Its inclusion in tax documents plays a key role in ensuring:

- Clear tracking of financial costs;

- coordination of reporting with organizational delivery;

- participation due to districts under the established qualification;

- Dealing with constraints established by financial instruments, including PNRR and local funds.

Although the responsibility is clear, many important problems were highlighted in practical application: the cup was not available without a request, or was reported by official error or error.In the absence of a formal correction mechanism, it has caused problems in accounting and management procedures as well as potential conflicts in the regulatory process.

It is precisely in the context of that law 563301 dated December 10, 2025, through a new digital service available to the Revenue Agency, it provides a structured solution to properly manage the cup even with reforms.

How to integrate CUP in electronic invoices

The central point of Regulation No. 563301 of December 10, 2025 is the introduction of a dedicated digital tool that allows the recipient or client to integrate or improve the unit project code (CUP) in electronic invoices related to purchases financed with public incentives.This is an important operational milestone, because until now, with the inevitable administrative complications, the supplier had to reissue or correct the invoice.

A web service on the "Bills and Fees" platform

The Tax Administration has made available a new functionality that can be accessed from the reserved part of the “Accounts and Commissions” portal.

Through this service, the recipient/customer - or assigned intermediary - can:

- select the electronic invoice received via SdI;

- check if CUP is already present:

- Because it was reported by the supplier, or

- because it is already integrated through the same service;

- Insert the missing cup if not indicated by the provider;

- Change of incorrect CUP, correction of information reported at the time of issue.

- Confirm the operation, make the integration part of the documentation available for control, consultations and administrative processes.

Please note: Invoice is non-replaceable and non-reissuable.The agency digitally links the integration to the original XML file, creating an authority and cross-reference in case of audits.

Who can use the service?

Access to the function is allowed:

- For the acquirer / buyer who is an interested person to show the correct attribution of insentivzing expenses;

- To authorized intermediaries, "To consult and obtain electronic invoices or their electronic duplicates".

This makes the tool also usable by professional firms or consultants who manage tax and administrative obligations on behalf of clients.

Which invoices can be included

L’integrazione del CUP può essere effettuata solo per le fatture la cui data operazione è successiva al 31 maggio 2023, ossia da quando l’obbligo di indicazione del CUP è diventato operativo.

- Electronic invoice received through SDI,

- Refers to goods or services that are the subject of public incentives,

- regardless of whether the cup is present at the time of issue or not.

Operational benefits of the new process

The new method introduced by the agency offers several advantages:

- Eliminate administrative flow, avoiding the request to the supplier to return the supplier;

- Ensuring the correct tracking of costs related to the financing project;

- reduces the risk of violations in reporting to funding bodies or tax control;

- Ensures greater transparency in the management of public finances and incentives for productive activities.

The actual existence of the service is announced by the historical agency through a special notice, but the operational basis has already been determined and allows operators to introduce new methods of operation.

All benefits and daily work have been added

The introduction of the web service for integrating or correcting the Uniform Project Code in electronic invoices represents a significant change in the administrative management of public incentives.Regulation No. 563301/2025 produces, in fact, immediate and concrete effects on companies, intermediaries and public administrations, clearly improving the flow of information and the quality of data transmitted through the exchange system.

1. Simplification of administrative procedures

The possibility to add or modify the cup without asking the seller again for the invoice reduces time, errors and intermediate steps.

For companies and consultants:

- minor management of contacts with suppliers;

- Small seller to complete and end the reissue;

- More streamlined accounting processes.

The original invoice remains valid and unchanged, and the additional information is officially related to the system of the revenue agency.

2. Greater certainty in governance and reporting

The correct indication of the cup is an important element of the relevant tests:

- Eligibility of expenses.

- correct attribution to the funded project;

Consistency with the actions that provide or confer motivation.

The joint agency that emerges and by providing the right way and facilitates control by the previous authorities, including those that manage Pnrr funds and European funds.

3. Reducing the risk of disorder

Thanks to the new system:

- Errors due to missing or misaligned cups are reduced.

- Many reasons for non-compliance with document checks have been eliminated.

- Prevents non-incentive expenses from becoming "unremembered" due to simple formal errors.

This contributes to greater operational security for companies and professionals who can demonstrate the link between invoicing and published plans.

4. Support for intermediaries and optimization of flows

Delegated partners can access the service directly, presenting complete process results to customers.

New system:

- Consolidate the invoice flow in one platform;

- makes data collection and organization more efficient;

- Reduce manual control and resolution work.

5. Benefits for public administrators

For suppliers and public administration, availability of harmonized invoices even after issuance:

- improve the quality of information about sponsored projects;

- enables monitoring of public use;

- Enables fast and digital checks;

- Contribute to greater transparency in the use of public funds.

6. A step towards the full digitization of tax procedures

These provisions follow the line of evolution of Italian tax policy: moving more activities to the digital level, reducing the burden and duplication of paperwork, centralizing information in the systems of revenue bodies.

The new possibility to integrate relevant data after the fact represents the evolution of electronic invoices, turning them into documents that can be enriched in a controlled and certified way even after they have been issued.

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