Certification and Legislation
An Italian Experience of Fiscal Software Certification
Isabella Biscoglio, Giuseppe Lami, Eda Marchetti and Gianluca Trentanni
Institute of Information Science and Technologies “Alessandro Faedo” of the National Research Council, Pisa, Italy
Keywords: Certification, Legislation, Fiscal Meters, Cash Register.
Abstract: The paper introduces the Italian Fiscal Software Certification scenario. Some concepts about certification
are illustrated. The cash registers, as specific kind of Fiscal Meter, are described and their adopted
certification process based on Italian legislation requirements is presented as well. Finally, the new related
technological challenges are discussed.
1 INTRODUCTION
In an increasingly competitive global market, the
achievement of a certification by independent and
reliable bodies could be an instrument of great
economical and social benefit. The written assurance
that a product, process or service is compliant with
the requirements expressed by international
standards or national legislation, can represent an
added value expendable in the economical
agreements as well as an improvement of the
product, process or service quality. In some
commercial environments the certification is
mandatory before the product is marketed. This is
the case of the fiscal meters, i.e electronic devices
for storing, managing and tracing commercial
transactions. Usually the available fiscal meters can
be classified into two different entities: cash
registers and automated ticketing systems. In this
paper, only the former will be considered.
Currently many European countries are
introducing specific legislations to rule the
commercial transactions. Italy has been one of the
first adopting a specific set of laws that regulates the
fiscal transactions by means of the use of fiscal
meters (L. 18, 1983), becoming a reference for the
rest of the European countries. Usually the cash
registers certification process involves Universities
and research institutions in activities of inspection,
evaluation and control of the hardware and software
components in order to verify the compliance
against legislation requirements. In Italy the System
and Software Evaluation Centre (SSEC) of the
National Research Council has been working for a
couple of decades in the 3rd party software products
and processes assessment/improvement and
certification. Regarding to the cash registers, the
certification against the Italian fiscal legislation is
provided on behalf of the Italian Finances
Department.
In this context, the purposes of this paper are
outlined as follows: 1) Providing an overview of the
Italian experience of the fiscal software certification;
2) Describing the certification process by its
activities 3) Highlighting the challenges implied by
the technological evolution; 4) Presenting an early
work in progress on the storage of the quantitative
data about the certifications already performed.
In the following, an overview of the certification
and background main concepts are provided. In
Sections 3 the SSEC experience in the certification
process is presented and in Section 4 some questions
on technological evolution against legislation are
discussed and conclusions are provided.
2 FISCAL SOFTWARE
CERTIFICATION
In this section, some general concepts about
certification are introduced by pointing out the key
roles and the activities involved in any certification
process. Subsequently, the particular case of cash
register certification is shown.
2.1 Certification Scenario
About certification, the most relevant topics are
174
Biscoglio I., Lami G., Marchetti E. and Trentanni G..
Certification and Legislation - An Italian Experience of Fiscal Software Certification.
DOI: 10.5220/0005558901740179
In Proceedings of the 10th International Conference on Software Engineering and Applications (ICSOFT-EA-2015), pages 174-179
ISBN: 978-989-758-114-4
Copyright
c
2015 SCITEPRESS (Science and Technology Publications, Lda.)
related to the terms, the involved actors, the objects
to be certified and the requirements against which
the objects should be certified.
2.1.1 Basic Concepts
According to the related ISO (ISO/IEC Guide 2,
1996), the certification is: “a procedure by which a
third party gives written assurance that a product,
process or service conforms to specified
requirements”. Such “assurance” can be given as a
result of an activity, namely “conformity
assessment”, defined in the same Guide but
perfected by the standard (ISO/IEC DIS 17000,
2004) as follows: “an activity that provides
demonstration that specified requirements relating
to a product, process, system, person or body are
fulfilled”.
Notice that nothing such as a guarantee is
desired. Usually the intended demonstration
represents the “confidence” (not the “proof”) that the
requirements have been fulfilled: certification cannot
give a guarantee, but can only increment the
confidence on the certification target objects.
2.1.2 Actors, Requirements and Objects of
the Certification
The most important involved actors are the
certification body and the accreditation body.
A certification body is an organism with internal
rules, human/infrastructure resource and skill to
perform certification procedures. To make the
results of certification comparable and then get
broad consensus about, the internal rules themselves
might be required to be conformant to defined
standards. In such a case, certification bodies can be
“accredited” that is, declared capable of performing
certification, upon periodical surveillance, by special
organisms called accreditation bodies. This is
compatible with the above definition of conformity
assessment.
Strictly speaking, a certification body does not need
to be accredited, but the accreditation is important to
increase the value of the certification, and then the
value of the certified object. Currently the
accreditation bodies are not so many (average is
one-two per country, against tens or hundreds of
certification bodies, generally specialized per
product category), so they can accredit each other by
executing periodical conformity assessments as
“peer reviews” upon their activities.
Other actors involved in certification are those who
want to give confidence on the object of certification
(over certification and accreditation bodies also
suppliers, sellers, standard makers…) and who want
to get confidence on the object of certification
(customers, users, end users, government…).
Therefore entities and relationships among different
actors can vary depending on wanted consensus
about their acts and on other opportunities.
Requirements, as mentioned in the definitions given
for certification, may be expressed in terms of
standards or legislation. Again, this is aimed at
increasing confidence on certification, since
standards are designed to be commonly accepted
reference models, allowing certification bodies to
express comparable and repeatable results. This in
turn facilitates, at least in principle, circulation of
goods, and fosters commercial co-operations with
mutual acceptance of the results of certification in
the international trading framework.
The objects of certification are usually processes,
products, people or organizations. To be more
precise, as a measure is a statement of an attribute of
an object, certification often refers to properties or
attributes of objects: so, there is certification of
attributes (e.g. electrical properties) of a product, of
attributes (e.g. capability) of a process, of skill of
professionals, of quality systems of organizations.
In order to assess conformity in a repeatable and
documented way, a certification body must follow a
defined process, and it is important that all the
certification bodies follow the same rules for the
same object types. Again, widely recognized
standards for the assessing process would give such
a confidence.
With respect to the general certification scenario
discussed above, the activities performed at the
SSEC has got some peculiarities:
The role of Accreditation Body in the case of the
Fiscal Meters certification is played by the Ministry
of Finances. It appoints the certification bodies and
performs a sort of control on their certification
activities. No standards for the accreditation are
used. In addition the Ministry of Finances doesn’t
ask nor provide any mutual accreditation/recognition
with respect other peer accreditation bodies.
A certification centre, here identified by the SSEC,
plays the role of Certification Body. The SSEC
certification process is approved by the
Accreditation Body (Ministry of Finances) and the
Italian Fiscal Legislation plays the role of Standard
for Product Requirements. The resulting
Certification and Accreditation scenario for the
Fiscal Meters Certification is represented in Fig. 1.
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Figure 1: SSEC Certification and Accreditation scenario.
2.2 Cash Register Certification
In order to simplify the tax relations between Eu-
ropean Community member countries, in 1972 Italy
has adjusted its tax policies to the other countries tax
policies introducing the value added tax (V.A.T.)
(D.P.R. 633, 1972). By V.A.T. introduction, a sup-
plier of goods or services must charge to the
customer the payment of a tribute, and in turn the
supplier must pay that tribute to the Government.
Subsequently to the V.A.T. introduction, it was
necessary to monitor the revenues of the commercial
activities in order to check the regularity of their
transactions in terms of data integrity and security.
The phenomenon of the tax evasion quickly
increased, and the fiscal receipt was considered the
instrument to oppose the tax evasion. Therefore the
law (L. 18, 1983) established the duty for the cash
register of issuing a fiscal receipt, at the time of the
payment, for the sale of goods, not subject to the
emission of an invoice and occurring in shops or
open public places.
The cash register must be compliant with the
model and the characteristics defined by the
Ministry of Finances (D.M. 03/23, 1983) and its
certification is mandatory before the cash register is
marketed. To this aim, by further laws and decrees
(D.M. 19/06, 1984), (D.M. 14/01, 1985), (D.L. 326,
1987), (D.M. 4/04, 1990), (D.M. 30/03, 1992),
(D.M. 04/03, 2002), (P.M. 31/05, 2002), (P.M.
28/07, 2003), (P.M. 16/05, 2005) the Ministry of
Finances established modalities and terms for the
release of cash registers. According to the current
Italian legislation the cash register definition
includes:
What It Is: The cash registers are devices designed
to record and process numerical data entered by the
keyboard or other suitable functional unit of
information acquisition, equipped with the device to
print on special supports the same data, and their
total (D.M. 03/23 all. A, 1983)
Why It was Introduced: As reported above, the
cash registers were introduced for the release of the
fiscal receipt that was considered the instrument for
checking the regularity of the economic transactions.
By the fiscal receipt it is possible to keep trace of the
payments and therefore to monitor the revenues of
the commercial activities. Consequently, the cash
register must satisfy some requirements of security
and, in particular, of integrity in order to prevent
“unauthorized access to, or modification of,
computer programs or data” (ISO/IEC 25010, 2011).
Its Components: The cash register is composed of
indicating devices (tipically screens), a printing
device, a fiscal memory and the casing. Each
component must satisfy specific normative
requirements. In particular the indicating devices
must be two and the displayed characters must be at
least seven millimeters high. The devices must be
placed on the two opposite sides of the cash register
in order to allow to the purchaser an easy reading of
the displayed amounts.
The printing device provides for the release of the
fiscal receipt, daily fiscal closing report and of the
electronic transactions register. Printed characters
must be at least twenty-five millimeters high.
The fiscal memory is an immovable affixed memory
that contains fiscal data. It must record and store the
fiscal logotype, the serial number, the progressive
accumulation of the amount, etc. In order to
guarantee the integrity of its data, the fiscal memory
must allow, without the possibility of cancellation,
only progressive increasing accumulations and the
preservation of their contents over time.
Finally the casing must foresee a unique fiscal seal
by means of a single screw that ensures the
inaccessibility of all hardware components involved
in the fiscal functionalities of the cash register,
except for the paper management. Also, onto the
casing, must be applied in a well visible place on the
front toward the buyer, a slab with reported data as
mark of the manufacturer, machine serial number,
data of the model approval document and the service
center.
What Kind of Documents It Must Issue: The cash
registers have to be able to print a fiscal receipt, a
daily fiscal closing report, and an electronic
transactions register. Each document must contain
mandatory information specified for single
indention, for instance: company name, owner name
and surname, V.A.T. percentage and company
address, accounting data, etc. The Italian legislation
detailes these generic descriptions providing
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hardware and software requirements that better
characterize structure and functionalities of a valid
cash register (D.M. 03/23 all. A, 1983). In particular
the legislation requires two separate certification
processes: one for the hardware components and one
for the software layer. The two processes are quite
similar in the steps to be performed and differentiate
mainly on the kind of test cases to be applied. For
instance for the hardware components tests for water
tightness or battery capacity as well as HW
reliability are required, while for the software
components black-box tests defined on the basis of
legislation requirements are executed.
The certification of a cash register needs that
both the processes terminate with successful results.
For aim of simplicity this paper only details the steps
required for the fiscal software certification.
2.3 Cash Register Software
Requirements
From the ministerial decree (D.M. 03/23, 1983) on,
the Italian legislation disciplined different moments
of the cash register industrial life-cycle and imposed
precise technological constraints. In order to
highlights the level of detail adopted for the
requirements specification in the Italian legislation
in this section some examples are provided. The
complete requirements list can be extracted from the
legislation.
During the Data Input, it must Not be Possible:
1) To change time in wrong formats (e.g. 26:44).
2) To change date in wrong formats (e.g.
31/09/2012).
With exhausted Fiscal Memory:
The command of issuing a fiscal receipt must
not be executed.
If the Printing Device is disconnected:
1) Any issuing of fiscal documents by the cash
register must be inhibited
2) Congruent warnings must be reported.
3 SSEC EXPERIENCE
The SSEC of the National Research Council
performs third-party evaluations and certifications of
software processes and products, according to
national legislation and international Standards to
meet the needs of users, suppliers and public
administration.
In detail, for the cash registers, the SSEC activities
are: software and hardware certification according to
Italian fiscal legislation on behalf of the Italian
Ministry of Finances, and systems evaluation
(Reliability prediction, Safety, MTBF of context-
dependent systems, Compliance against standards).
In particular the certification process adopted inside
the SSEC is divided into two separate phases (Pezzè
and Young, 2008): the off-line testing activity
preparation and the on-line testing session.
In the context of the fiscal software certification, the
SSEC has also set an activity of building up a
database of data collected by the certifications
already performed in order to set up and conduct
empirical research studies. These data could be of
interest for other certification bodies or involved
actors. Collected data are focused on software
characteristics like maintainability and reliability of
the fiscal software or security of the fiscal data, etc.
The collected data are, for instance, Mean Time
Betweeen Failure (MTBF) or fault patterns and
redundancy as reliability measures, or also number
of provided authentication methods and number of
data corruption instances actually occurring as
security measures.
The data collection is an important and
continuous work in progress of the SSEC due to the
numerous normative updatings and technological
innovations that have deeply modified the product to
be certified over the years. Continuous changes in
the database inputs raise problems of data uniformity
and make difficult having long terms statistical
analysis. Nevertheless the database promotes an
approach of improvement and building up of best
practices for the fiscal software certification.
3.1 Off-line Testing Activity
During the off-line testing activity the collection of
the different information relative to the development
process of the cash register is performed. In
particular five kind of sources are considered:
1) Documentation, that is the collection of
documents provided by the cash register developers.
It mainly consists in: an architectural model, i.e. the
description of the hardware and software
components of the cash register; a functional model,
i.e. the specification of functionalities implemented
in the source code; an end user manuals: the
description of the interface and the functionalities
available to the final user. The documentation
includes the maintenance procedures necessary
during the cycle life of cash register;
2) Additional Information, or extra data that can be
requested as completion of the mandatory
documentation.
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3) Source Code, i.e. the source code of the cash
register completed with the libraries that could be
used during the on-line testing activity.
4) Requirements Repository, i.e. the collection of
cash register requirements, both form the hardware
and software point of view, as required by the Italian
legislation.
5) Test Case Database, that is the collection of test
cases and corresponding correct results useful for the
evaluating of the cash register during the on-line
testing session. In particular a set of specific test
cases and responses is associated to each of the
requirements collected in the requirements lists.
3.2 On-line Testing Activity
During the on-line testing activity the documentation
collected in the off-line activity is exploited for the
conformity assessment of the cash register. In
particular inside the SSEC group the activities can
be divided into the following steps (Pezzè and
Young, 2008):
1. Documentation Analysis: the information
contained into the “Documentations and Additional
Information” folders are analyzed in order to iden-
tify characteristics and functionalities implemented
into the cash register under certification.
2. Requirements Selection: on the bases of the
architectural and functional models, the susbsets of
hardware and software requirements are identified
from the complete list of requirements available into
the “Requirements Repository”.
3. Test Objective Selection: For each of the
selected requirement subsets, the test objectives are
identified. In particular the SSEC considers five
different testing conditions corresponding to
different cash register behaviors: Initialization, i.e.
the fiscal memory of the cash register is not
recording data (fiscal memory not jet active); Fiscal
Functioning, i.e. the fiscal memory is activated;
Abnormal Conditions, i.e. possible anomalous
behavior due to misinterpretation or incorrect time
and data input; Boundary Condition, i.e. boundary
values for the fiscal memory use are considered, for
example close to the exhaustion or exhausted;
Malfunctioning, i.e. accidental and malicious
situations are considered.
4. Test Plan Definition: According to the detected
test objectives for any requirement subsets, one or
more test cases are selected among those available
into the Test Cases Database. In case of the test
cases are missing the proper ones are ad-hoc
generated and the Test Case Database enriched
accordingly. In this way a customized test plan is
obtained.
5. Test Plan Execution: The required test
environment is set up and the selected test cases are
executed. During this phase the test results are
collected and compared with the correct results
associated to each of the executed test case. If the
expected result is the same of that obtained by the
cash register, then the test case is considered as pass,
otherwise the test case is classified as fail. At the end
of the testing session, the set of verdicts (pass or fail)
are collected into a Test Report. In case of error
discovered during the test execution a modification
of the source code is requested to the cash register
developers and an optional phase of regression
(Pezze` and Young, 2008) testing is considered.
6. Certification Results: The final product of the
certification process is the Compliance Certificate,
that is the collection of the provided documentation,
by the test report and by the certification center
possible remarks and comments. It is to be noticed
that the certificate can be only successful. In case the
testing step has failed, a report of any spotted issues
is drawn up both to lead the stakeholder during its
software improvement and to update the certification
centre activity historical recording. After the
stakeholder may apply again to a new testing
session.
4 DISCUSSION AND
CONCLUSIONS
In the previous sections the overall certification
process adopted inside the SSEC has been presented
and the off-line and on-line testing activities,
performed during the process, have been detailed.
However, due to the peculiarities of each cash
register, to the company that develops it and to the
Italian legislation, many exceptions to the presented
process have been encountered over the years. In the
following a not exhaustive list of the main challen-
ges derived by the everyday experience is discussed.
The first one is represented by the Italian legislation.
It tends to be too verbose and too generic to cover all
the possible exceptions and issues. This can cause
misunderstanding and errors during the assessment
of the requirements satisfaction. The automation of
the conformance assessment process would be a
desirable goal, but a too generic and continuously
modified legislation is a strong limit to this
automation, and the human intervention is thus
always necessary. Besides, the SSEC keeps
continuously updated and aligned the Requirements
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Repository to the continuous modifications in the
legislation imposed by the designate authorities.
However these modifications heavily influence also
the historical data collection, its uniformity and
analysis. An additional challenge of the SSEC
activity is therefore to adopt specific procedures to
manage, verify and update the normative corpus so
promptly react and integrate the legislation
modifications, the official clarifications or
interpretations provided by the designate authorities.
During the on-line testing activity one of the main
problem encountered by the SSEC has been the
management of the documentations provided by the
stakeholders that in many cases did not reach the
sufficient level of detail. Indeed, due to time-to-
market constraints, either the architectural model or
the functional model could not be fully complete and
documentation integration could be necessary.
An additional critical issue of the on-line testing
activity is the management of the errors discovered
during the test plan execution. Indeed, in case of
faults or non-compliances, corrections of the source
code are necessary. This increases the prize, in terms
of time and effort, of the certification and
development activities. In particular, an important
delay in the test certification release could be caused
by the necessity to the execution of an additional
phase of regression testing. This is important to
verify that the source code corrections do not
invalidate the already tested functionalities. To
speed up this part of the process, the solution
adopted inside the SSEC is the compartmentation of
the source code, i.e. wherever possible, by the
analysis of the documentation available, the source
code is sliced into separate components so that only
the test cases related to a specific part are selected
and re-executed.
In order to identify the best strategy to improve
the effectiveness of the fight against tax evasion,
currently the Italian legislators are trying to
strengthen the transactions traceability. To this aim,
the abolition of the fiscal receipt is being considered
as well as the adoption of tools for the electronic
invoice and the telematic transmission of the
payments. By means of these actions, an important
process of cultural change is becoming established
in the country. This apparent simplification of the
transactions traceability imposes new challenges of
technological advancement and adjustments in
respect of the legislation for the cash register
developers, suppliers and vendors. A reorganization
of the certification process in the legislation
compliance check is needed as well. These
challenges advise that the fiscal receipt is more and
more becoming the symbol of a historic moment
destined already to a quick end (Prokin and Prokin,
2013).
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