Challenges, opportunities, and ambiguities in the regulatory framework for the digitization of transport documents
Innovation
Technology
Consulting
18 November 2025
Vincenzo Gioia
Vincenzo Gioia
- Technology, Work and Society
Introduction
In an economy increasingly geared toward digitization and automation of logistics processes, adopting the Digital Transport Document (DDTD) is a crucial step toward operational efficiency and transparency. However, unlike electronic invoicing, which became mandatory in 2019, the digital DDT remains optional. This regulatory choice creates operational uncertainty for companies, hindering a smooth and comprehensive transition to digital document workflows.
A non-binding regulatory framework
One of the main obstacles to the spread of digital DDTs in Italy is the absence of a clear and binding regulation. Unlike electronic invoicing, which is mandatory, the digital DDT remains optional, creating uncertainty among businesses. The Italian Civil Code1, the Digital Administration Code (CAD2), and AgID3’s guidelines provide a general framework, but it is not always sufficient to guide operational choices due to ambiguities in areas such as:
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Accepted digital formats for DDTs
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Full legal validity of digital versions
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Legal weight of advanced electronic signatures in the event of disputes
This regulatory uncertainty contributes significantly to companies’ hesitation in fully adopting digital solutions for transport document management, often pushing them toward inefficient hybrid solutions.
To be legally valid for fiscal and evidentiary purposes, digital DDTs must meet specific technical and regulatory requirements. In Italy, the legal validity of digital documents is defined by a legislative framework including:
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Law No. 59/1997 (“Bassanini 1”): First introduced the legal validity of digital documents for creation, storage, presentation, and transmission
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Presidential Decree 513/1997: Regulates digital signatures, ensuring integrity, authenticity, and non-repudiation
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Digital Administration Code (CAD, Legislative Decree 82/2005 and subsequent amendments): Governs the management and preservation of digital documents, stating that they have full legal value if they meet authenticity, integrity, reliability, readability, and retrievability requirements
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Ministerial Decree of June 17, 2014: Defines technical standards for the compliant storage of fiscally relevant digital documents, including DDTs
The application of a digital signature (or qualified electronic signature) to a DDT guarantees its authenticity and integrity, equating the digital document to its paper counterpart even in legal disputes (Article 2702 of the Civil Code). Secure transmission methods (e.g., certified email or Peppol networks) and delivery logs strengthen the document’s evidentiary value.
The Italian Revenue Agency clarified in Circular No. 36/E of December 6, 2006, that digital preservation of DDTs is allowed even without the recipient’s signature, provided delivery can be proven (e.g., via tracking systems or electronic delivery receipts).
The conservation of digital DDTs must comply with both civil and tax regulations:
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Civil Code Article 2220: Requires documents to be preserved for ten years from the last recorded entry
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Presidential Decree 633/1972, Article 39: Requires preservation until the conclusion of any tax inspections
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Legislative Decree 471/1997: Provides penalties from €1,000 to €8,000 for failure to preserve fiscally relevant documents
According to the CAD and AgID guidelines (Article 71 CAD, in force since January 1, 2022), digital preservation must ensure:
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Authenticity: Certainty about the identity of the document’s creator
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Integrity: Unaltered state of the document over time
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Reliability: Ability to verify source and document validity
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Readability: Accessibility of content throughout the retention period
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Retrievability: Secure, fast access to the document and its metadata
Conclusion
Toward full document process digitization
The analysis of the regulatory framework for Digital Transport Documents shows that, despite progress in business process digitization, significant barriers remain to fully adopting digital solutions in logistics and supply chains.
The lack of a clear regulatory mandate, combined with legal and technical ambiguities, creates a climate of uncertainty that leads many companies to maintain hybrid processes—undermining many of the potential benefits of digitization. While understandable, this cautious approach hinders innovation and the operational efficiency of Italy’s economic system.
To overcome these issues, the following actions are recommended:
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Targeted legislation that clearly defines DDT digital requirements, possibly introducing a gradual mandate similar to electronic invoicing
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Detailed technical guidelines from the Revenue Agency and AgID to help businesses choose the most appropriate solutions
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Tax incentives or administrative simplifications for companies that fully digitize their processes
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Training and awareness programs for SMEs, which often lack the resources and skills to handle these changes independently
Complete digitization of the logistics document cycle is not just a technical or regulatory requirement—it is a strategic opportunity to increase the competitiveness of the Italian production system. In a global context where logistics speed and efficiency are increasingly crucial, adopting advanced digital tools prepares companies for future challenges and enables new business models.
Forward-thinking companies should not wait for a regulatory mandate, but treat digital DDT adoption as a strategic investment to optimize processes, reduce operational costs, and enhance customer service—positioning themselves at the forefront of a rapidly evolving digital market.
1The relevant article is Article 2220 of the Italian Civil Code, which governs the retention of accounting documents, including Transport Documents (DDTs). It establishes a mandatory retention period of 10 years, starting from the date of the last recorded entry.
2 The Italian Digital Administration Code (CAD) governs the management and retention of digital documents, including digital Transport Documents (DDTs). Specifically, the CAD sets out the requirements for the legal validity and long-term digital preservation (“conservazione sostitutiva”) of electronic documents, ensuring that digital DDTs hold full legal value when properly managed.
3 The AgID (Agency for Digital Italy) guidelines provide technical and operational instructions for the compliant digital preservation of documents, including digital Transport Documents (DDTs), in accordance with the CAD (Digital Administration Code) and the Ministerial Decree of June 17, 2014. These guidelines ensure that digital documents retain legal validity and are stored securely and remain accessible over time.
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