COD
Cash on Delivery Rules in Italy: Cash Limit, Surcharges
Cash on delivery touches more rules than it seems, from the legal cash limit to the ban on charging more to customers who choose it, through to invoices and VAT. A single compliance mistake can cost thousands of euros in fines, operational blocks, and tax problems.
TL;DR: In Italy, cash payments of €5,000 or more are banned, so a cash-on-delivery payment in cash can reach at most €4,999.99, and your carrier can set a lower limit in your contract. Charging more to customers who choose cash on delivery exposes you to a fine from the Italian Competition Authority (AGCM), even if the surcharge is disclosed. This guide covers limits, customer information, invoices and VAT, with an operational compliance checklist.
This guide breaks down the current regulations, practical implications for online sellers, and concrete actions to ensure full compliance.
The regulatory framework: where COD regulation comes from
Cash on delivery, known as "contrassegno" in Italy, is governed by an overlapping set of rules spanning consumer protection, anti-money laundering regulation, and tax legislation.
The primary regulatory sources are:
- Legislative Decree 231/2007 (anti-money laundering) and subsequent amendments, which sets limits on cash usage in Article 49
- 2023 Budget Law (Law 197/2022), which raised the threshold of the ban to €5,000 from January 1, 2023
- Consumer Code (Legislative Decree 206/2005), governing consumer rights in ecommerce, from the information due before purchase (Article 49) to the ban on charging for the use of a payment method (Article 62, which refers to Article 3 of Legislative Decree 11/2010)
- Tax regulations (Presidential Decree 633/1972 and Legislative Decree 127/2015; from January 1, 2027, the VAT Consolidation Act, Legislative Decree 10/2026), governing invoices, daily receipts and VAT on sales, COD sales included
For ecommerce merchants, the challenge is not just knowing these rules but applying them operationally in a context where collections happen through carriers, reconciliation timelines vary, and volumes can be high.
Warehouse in Campania, shipping across Italy
Payment limits: how much can you collect via COD
The legal limit: €4,999.99 in cash
Since January 1, 2023, Italian law has banned transfers of cash of €5,000 or more between different parties, whether individuals or companies (Article 49, paragraphs 1 and 3-bis, of Legislative Decree 231/2007). A cash-on-delivery payment made in cash can therefore reach at most €4,999.99. Anyone who breaks the ban faces an administrative fine of €1,000 to €50,000 (Article 63, paragraphs 1 and 1-ter).
On top of this come the carrier's rules, set in your contract, which can be stricter (the table below shows what the main carriers state). The limit that applies to you is the one in your contract.
What counts as a "single transaction"
A critical point is the definition of a transaction. Two genuinely separate orders remain two separate transactions. If, however, one order is split into several orders or shipments to stay below the threshold, that is the artificial splitting Article 49 expressly prohibits, because what counts is the total value transferred.
Practical rule: each ecommerce order corresponds to one transaction. If the order amount exceeds the carrier's limit, or reaches €5,000, cash payment on delivery should not be offered for that order.
Carrier limit comparison table
| Carrier | COD paid in cash | Other methods and notes |
|---|---|---|
| BRT | within the legal threshold of €5,000 | above it, only a cashier's check made out to BRT; no amount limit for shipments within Italy |
| Poste Italiane (Poste Delivery Business) | up to €2,999.99 per shipment | check made out to the sender, cash or cards within the set limits |
| GLS | maximum amount not stated | cash, bank check, cashier's check or postal check |
| Amazon Shipping | COD not listed among its services | COD orders need another carrier |
Data read in October 2026 in BRT's FAQ, the Poste Delivery Business product sheets (September 2026 edition), GLS's cash-on-delivery service page and Amazon Shipping's FAQ. Limits may vary based on specific merchant-carrier agreements. Always verify your current contract terms.
Merchant obligations: what you need to do to stay compliant
1. Payment traceability
Every COD collection must be traceable and reconcilable. This means the merchant must be able to demonstrate, for every COD order:
- Date and amount of collection
- Identity of the carrier that performed the collection
- Reference to the corresponding ecommerce order
- Date of credit to the merchant's account
Manual reconciliation (the classic spreadsheet cross-referenced with the carrier's statement) is not prohibited, but it is error-prone, and as volumes grow it becomes hard to keep in order. With high volumes, a tool that automates it, at least in part, pays off.
2. Tax documentation
COD sales follow the same tax rules as any online sale to a consumer.
- Invoicing: for the Italian Revenue Agency (Agenzia delle Entrate), an online sale of goods delivered by a carrier is a mail-order sale (ruling no. 198 of 2019), so an invoice is not mandatory unless the customer asks for it by the time of the transaction (Presidential Decree 633/1972, Article 22). If you issue one, it is electronic (Legislative Decree 127/2015, Article 1, paragraph 3)
- VAT: on a sale of goods, VAT is due when you ship or deliver (Presidential Decree 633/1972, Article 6), even if the carrier pays the collected amount to you later
- Recording: sales without an invoice are entered every day in the daily receipts register (registro dei corrispettivi, Presidential Decree 633/1972, Article 24), and the carrier's payment is a cash movement to match to the order
An often-overlooked point is the refused package. If you had already issued an invoice and the sale falls through, you correct it with a credit note (nota di variazione, Presidential Decree 633/1972, Article 26). But a refusal on its own is not a withdrawal. According to the European Commission, refusing delivery or not picking the goods up at the post office does not count as a valid statement of withdrawal (2021 guidance on Directive 2011/83/EU, section 5.3). Talk to the customer, who may want a new delivery, and record how the order is closed. What to do with the parcel is covered in the guide to refused parcels and failed deliveries, the withdrawal rules in the one on returns regulations. Each refusal creates administrative work, yet another reason to reduce COD refusals with a pre-shipping verification system.
3. Consumer information
The Italian Consumer Code requires merchants to inform customers, before purchase, of the total price including shipping costs and of the payment and delivery arrangements (Article 49, paragraph 1). For cash on delivery, this means stating three things.
- The total price, shipping costs included, which stays the same when paying cash on delivery (Article 49, paragraph 1, letter e, and Article 62 of the Italian Consumer Code)
- Payment methods accepted at delivery (cash, check or card, depending on the carrier)
- Amount limits for COD
Charging more to customers who choose cash on delivery exposes you to a fine. Article 62 of the Italian Consumer Code prohibits charging consumers fees for the payment method, and for the Italian Competition Authority (AGCM) the ban also covers purchases paid cash on delivery (press release of October 14, 2016). Disclosing the surcharge before purchase is not enough, because the violation lies in the surcharge itself, as the Authority repeated in 2025 when it fined a surcharge on PayPal payments (decision PS12934). The carrier's COD fee remains a cost for the store, to be recovered in the selling price, the same for everyone. The same goes for a discount reserved for customers who pay in advance, because since 2018 the law no longer provides for discounts linked to the payment method (Italy's Council of State, judgment no. 2733 of 2026).
Anti-money laundering: what applies to an online store
The Fourth and Fifth Anti-Money Laundering Directives
European anti-money laundering legislation (Directives 2015/849 and 2018/843) is transposed into Italian law in Legislative Decree 231/2007 and subsequent amendments. The heaviest obligations, namely customer due diligence, data retention and suspicious transaction reporting, apply to the "obliged entities" listed in Article 3. These are banks, Poste Italiane, payment institutions, professionals such as accountants and notaries, and some operators, for example those dealing in gold, antiques or works of art. An online store selling ordinary products is not on the list.
For an online store, three points remain.
- No artificial splitting: it is not permitted to divide a payment into multiple transactions to stay below the threshold (Article 49, paragraph 1)
- Suspicious orders: reporting to Italy's Financial Intelligence Unit (UIF) is up to the obliged entities (Article 35). Repeated orders from the same customer with amounts just below the threshold should still be stopped, because they may be prohibited splitting
- Data retention: the store must keep its accounting records and invoices for ten years (Italian Civil Code, Article 2220). The ten years under anti-money laundering rules (Article 31 of Legislative Decree 231/2007) apply to obliged entities
In practice, the carrier collects on your behalf. The cash ban, however, concerns the payment between your customer and you, so checking it is also your job.
Concrete risks for the merchant
For a store, the concrete risks are two.
- Cash above the threshold: administrative fine of €1,000 to €50,000 (Article 63, paragraphs 1 and 1-ter, of Legislative Decree 231/2007)
- Surcharge for cash on delivery: an AGCM fine for breaching Article 62 of the Italian Consumer Code, as in the 2016 and 2025 cases mentioned above
Fines for failing to report or to retain anti-money laundering data apply to obliged entities instead. These penalties make clear why compliance is not optional. A single order paid in cash above the threshold is enough.
Tax implications of cash on delivery
VAT and the taxable event
With cash on delivery, the customer pays when receiving the parcel. For VAT, however, a different moment counts. A sale of goods is deemed made upon delivery or shipment, and VAT is due from then (Presidential Decree 633/1972, Article 6). If you issue an invoice or collect the price earlier, that date counts, for the amount invoiced or paid. This is why for a prepaid order the payment usually counts, and for cash on delivery the shipment.
VAT cash accounting (IVA per cassa), which moves VAT to the time of payment for businesses with turnover up to €2 million, applies only to sales to businesses and professionals (Decree-Law 83/2012, Article 32-bis). For consumer sales paid cash on delivery, VAT stays tied to shipment or delivery. From January 1, 2027, these rules move into the VAT Consolidation Act (Legislative Decree 10/2026, Articles 24, 77, 81, 87, 92 and 132), with the same content. Tax choices should be made with your accountant, and this article is not tax advice.
Accounting and reconciliation
The reconciliation of COD collections with the carrier is one of the most critical and underestimated processes. Payment timelines vary from carrier to carrier. These are the ones the carriers state in October 2026.
| Carrier | Payment of collected amounts |
|---|---|
| BRT | cash collections, daily by bank transfer or every 15 days by check (assegno di traenza); a check made out to you, visible within 7 business days of collection |
| Poste Italiane (Poste Delivery Business) | within 5 business days of delivery |
| GLS | not stated on the service page, to be agreed in the contract |
With 200 COD orders per month, for example, you have to match each carrier payment to the orders it contains, accounting for refusals, storage holds, and partial collections. Without an automated system, errors are easy to make.
Compliance checklist for ecommerce merchants
This operational checklist summarizes the regulatory obligations related to COD. Use it as a periodic verification tool.
Limits and configuration
- Checkout blocks COD paid in cash from €5,000 and above the carrier's threshold
- No possibility of artificial order splitting exists
- COD limit is configured for each carrier used
- The price is the same with any payment method, cash on delivery included
Tax documentation
- Sales are entered in the daily receipts register, with an electronic invoice if the customer asks for one
- In case of refusal, an invoice already issued is corrected with a credit note
- Carrier payments are matched to orders in the accounts
- VAT on COD sales is tied to the shipment or delivery date
Anti-money laundering
- Accounting records and invoices are kept for ten years
- There is a check on repeated orders with amounts just below the threshold
- COD orders with obviously false data are not accepted without verification
Reconciliation
- A reconciliation process exists between carrier collections and orders
- Discrepancies are identified and resolved within 30 days
- COD financial flows are separated and traceable in the income statement
Consumer information
- COD terms are visible in the terms of sale
- At checkout, cash on delivery adds no costs to the total
- Payment methods accepted at delivery are specified
How Tissquad can help
Tissquad handles logistics for cash-on-delivery orders for ecommerce brands, from its warehouse in Campania, near Naples. We usually pay out cash-on-delivery collections every week, together with a summary of what was collected, to match against the orders in your accounts. You also get access to the warehouse and shipping panel. Before shipping, we check the address and, on request, confirm cash-on-delivery orders by phone, in Italian. More on how we work on our cash on delivery service page.
Want to work out how to organize cash on delivery in your store? Request a call with our team, the first one is free.
Frequently asked questions
Is COD mandatory for Italian ecommerce stores?
No. No Italian law requires an ecommerce store to offer cash on delivery. It is a commercial choice made by the merchant. Cash paid on delivery accounts for 1.6% of all online purchases by Italians (Netcomm, NetRetail 2026), but in stores that offer cash on delivery almost one order in five is paid that way (2022 data from an Italian shipping software provider). If your audience uses it, removing it can cost you orders.
Can I charge a surcharge for COD?
No, the risk of a fine is high. Article 62 of the Italian Consumer Code prohibits charging consumers fees for using a payment method, and the Italian Competition Authority (AGCM) has stated that the ban also covers purchases paid cash on delivery. Disclosing it before purchase does not make it lawful, nor does calling it a COD fee or a handling fee. The carrier's cost belongs in the selling price. This article is not legal advice.
What happens if a COD order exceeds the legal limit?
If an order of €5,000 or more is paid in cash to the carrier, it breaches the ban in Article 49 of Legislative Decree 231/2007, with an administrative fine of €1,000 to €50,000 (Article 63). Do not assume the carrier will prevent it. Poste Delivery Business states €2,999.99 in cash per shipment, while BRT collects cash up to the legal threshold and above it asks for a cashier's check. Block COD paid in cash at checkout.
How should I handle COD refusals from a tax perspective?
If you already issued an invoice and the sale falls through, you correct it with a credit note (Presidential Decree 633/1972, Article 26; from 2027, Article 92 of the VAT Consolidation Act). The one-year limit applies only if the sale is cancelled by a later agreement between the parties, so check your case with your accountant. A refusal on its own is not a withdrawal, so talk to the customer before closing the order. It is yet another reason for a pre-shipping verification system that helps reduce refusals.
Are COD regulations different for B2B sales?
Partly. The cash limit is the same, because Article 49 of Legislative Decree 231/2007 applies to transfers between any parties, businesses included. The Consumer Code protections, such as mandatory information and withdrawal, apply only to consumers. A business customer usually asks for an invoice, which is electronic between parties resident or established in Italy, and sellers with turnover up to €2 million can use VAT cash accounting.
Warehouse in Campania, shipping across Italy
Sources
26
- Normattiva, Legislative Decree 231/2007, Article 49 (in Italian), 2023
- Normattiva, Legislative Decree 231/2007, Article 63, cash penalties (in Italian), 2019
- Normattiva, Legislative Decree 231/2007, Article 3, obliged entities (in Italian), 2026
- Normattiva, Legislative Decree 231/2007, Article 31, record keeping (in Italian), 2019
- Normattiva, Legislative Decree 231/2007, Article 35, suspicious transaction reports (in Italian), 2017
- Normattiva, Italian Civil Code, Article 2220 (in Italian), 1994
- Normattiva, Italian Consumer Code, Article 49 (in Italian), 2026
- Normattiva, Italian Consumer Code, Article 62 (in Italian), 2014
- Normattiva, Legislative Decree 11/2010, Article 3 (in Italian), 2018
- AGCM, press release on payment surcharges (in Italian), 2016
- AGCM, Bulletin no. 42, decision PS12934 (in Italian), 2025
- European Commission, Guidance 2021/C 525/01 on the Consumer Rights Directive, 2021
- Agenzia delle Entrate, ruling no. 198 on ecommerce receipts (in Italian), 2019
- Normattiva, Presidential Decree 633/1972, Article 6, text in force in October 2026 (in Italian)
- Normattiva, Presidential Decree 633/1972, Article 22, text in force in October 2026 (in Italian)
- Normattiva, Presidential Decree 633/1972, Article 24, text in force in October 2026 (in Italian)
- Normattiva, Presidential Decree 633/1972, Article 26, text in force in October 2026 (in Italian)
- Normattiva, Decree-Law 83/2012, Article 32-bis, VAT cash accounting, text in force in October 2026 (in Italian)
- Normattiva, Legislative Decree 127/2015, Article 1, electronic invoicing, text in force in October 2026 (in Italian)
- Normattiva, VAT Consolidation Act (Testo unico IVA), Legislative Decree 10/2026, applies from 2027 (in Italian), 2026
- BRT, Frequently asked questions (in Italian), 2026
- Poste Italiane, Poste Delivery Business, national product sheets (in Italian), 2026
- GLS Italy, CODService, cash-on-delivery service (in Italian), 2026
- Amazon Shipping Italy, Frequently asked questions (in Italian), 2026
- Consorzio Netcomm, NetRetail 2026 (in Italian), 2026
- Qapla', Quali sistemi di pagamento scegliere per il proprio eCommerce (in Italian), 2023