How to challenge tax collection notices notified via PEC is a topic that interests more and more citizens and entrepreneurs. With the growing use of certified email (PEC) for official communications, it is important to understand what to do when receiving a payment notice in this way. In this simple and updated guide, we will explain when and how it is possible to appeal, what the Court of Cassation says, and what your rights are.
Many taxpayers do not know that the notification via PEC can be challenged in certain specific cases, for example if the email inbox is full or if the PEC address is not active. We will also see what the Agenzia delle Entrate – Riscossione must do to make a notification valid and which errors can invalidate it.
Table of Contents
What does it mean to receive a tax collection notice via PEC?
Tax collection notices are official documents with which the Agenzia delle Entrate – Riscossione requests payment of unpaid taxes, duties or penalties. In recent years, these documents are increasingly sent via PEC, especially if the recipient (such as a company or freelancer) is required to have a PEC address.
But what happens if the recipient does not correctly receive the PEC? Is the notification still valid? The answer depends on the reason why the PEC did not reach its destination.
What did the Court of Cassation say in 2025?
The Court of Cassation, with ordinance no. 3703 of February 13, 2025, clarified what the Agenzia delle Entrate – Riscossione must do when a notification via PEC fails. Here is the principle expressed:
- If the recipient’s PEC inbox is full, the Agency must repeat the sending after at least 7 days. Only in this case is a second attempt mandatory.
- If instead the PEC address is invalid or inactive, it is not mandatory to resend the notice.
This means that only a full inbox requires a second sending. In other cases, the notification can be considered valid even if the taxpayer has not read it.
How to challenge tax collection notices notified via PEC: when is it possible?
Challenging is possible only in certain cases. Let’s see together when you can appeal:
| Reason for challenge | Possible to challenge? | Actions required from the Agency |
| PEC inbox full | ✅ Yes | Must repeat sending after 7 days |
| PEC inactive | ❌ No | No second sending required |
| PEC invalid | ❌ No | No second sending required |
| Document not authentic | ✅ Yes | You must prove it does not come from the authority |
| Lack of digital signature | ❌ No | PDF format is considered valid |
Which formats are valid? PDF or p7m?
Another common doubt is whether the notice must be sent in digitally signed format (.p7m) or if a normal PDF is sufficient.
The Cassation responded with ordinance no. 30922 of December 3, 2024:
✅ The PDF format is valid, even if not digitally signed.
❌ The .p7m format is not mandatory, as long as the document comes from an official source (such as the Agenzia delle Entrate – Riscossione) and is readable.
What if the notice arrives and I don’t notice it?
It often happens that a taxpayer does not notice having received a notice via PEC, perhaps because the inbox is full or not checked. Unfortunately, the law considers the notification valid, even if the recipient has not opened it, except in the cases indicated above.
For this reason, it is important to always keep the PEC inbox under control, especially if you are a freelancer or a small business.
Table: what to do and when
| Day | What happens | What to do |
| 0 | First PEC sending by the Agency | Check receipt |
| +7 | If PEC was full, mandatory new sending | Check PEC and paper mail |
| +60 | Deadline for appeal (in some cases) | Evaluate whether to challenge |
| +180 | Possible start of collection actions | Act immediately |
How to challenge tax collection notices notified via PEC: do you need an expert
Italian tax and fiscal legislation is among the most complex in Europe. Often, even those who have had a business or company for years do not know how to proceed in front of a telematic notification.
At Studio Lombardo Larosi, we offer professional assistance to help you correctly interpret the regulations and understand if you can appeal. We analyze your situation, verify the validity of the notification and support you in preparing the appeal or in resolving the position.
👉 The law is complicated, but you are not alone.
We can do it for you – Ask for our support
If you have been notified a tax notice via PEC and you don’t know what to do, we can help you. We have direct experience in this type of procedures and know all the correct steps to avoid errors.
- Analyze the notification
- Verify if there are grounds to challenge it
- Prepare the appeal
- Communicate with the Agency on your behalf
💼 If you want to avoid problems with the Tax Authority and protect your company, rely on those who do this job every day.
Our service of assistance in tax appeals and legal representation.
At Studio Lombardo & Larosi we offer complete services in the field of tax appeals and tax amnesty.
We provide comprehensive support for tax appeals and tax disputes in Italy, accompanying clients during the appeal phases, tax audits and negotiations with tax authorities. Our services include litigation, requests for installment plans and extrajudicial mediation.
Appeals and disputes with Italian tax authorities
Strategic advice during tax audits and assessment and enforcement actions
Requests for installment plans and negotiation of repayment plans
Extrajudicial mediation and legal consulting support in tax appeals
Thanks to collaboration with affiliated legal professionals, we offer tailored assistance to businesses and individuals, ensuring effective strategies in relations with the Agenzia delle Entrate and the Agenzia della Riscossione.
Common errors to avoid when searching how to challenge tax collection notices notified via PEC
Many taxpayers make the mistake of not acting immediately when they discover they have received a notice via PEC. Others search online for how to challenge tax collection notices notified via PEC, but end up following outdated or unreliable advice. The risk is losing the deadlines for appeal, or submitting an incorrect opposition that is therefore useless. For this reason, it is essential to rely on a professional who knows the regulations well and can help you understand what concrete possibilities you have to defend yourself.
Where to find reliable information on how to challenge tax collection notices notified via PEC
If you are looking for precise and updated information on how to challenge tax collection notices notified via PEC, it is important to know that not all online sources are reliable. Some sites publish generic content or not updated to the latest rulings, such as those of the Cassation in 2024 and 2025. We at Studio Lombardo Larosi constantly monitor jurisprudence and tax news, to offer our clients concrete solutions perfectly in line with the law. Your defense starts with correct information, and that is exactly what we guarantee you every day.
Conclusion
How to challenge tax collection notices notified via PEC is a very common question today, given the digitization of tax communications. Not all notifications are valid and the law provides specific protections for the taxpayer, but technical knowledge and timeliness are needed.
Relying on professionals is often the best choice to avoid errors and not risk higher penalties. We at Studio Lombardo Larosi are by your side for any clarification and for the complete management of the case.
Contact us for more information
Have you received a tax collection notice via PEC?
Do you have doubts about the validity of the notification?
Don’t know if you still have time to appeal?
📞 We will respond as soon as possible for a free preliminary consultation.
Together, we will evaluate if you can challenge the notice and what your rights are.