In its recent judgment No. 6992/2026, the Tribunal of first instance of Rome dismissed an opposition to a payment order brought by an energy trading company, confirming a claim exceeding €77 million in favour of an electricity Distribution System Operator (DSO).
The Court held that invoices, while not constituting in themselves full proof of a claim according to long-established and consistent case law, may become an effective evidentiary tool when supported by certified extracts from accounting records, technical documentation (including meter readings and metering data), and the absence of specific objections by the debtor.
In particular, in matters relating to the supply and distribution of electricity, meter readings and the analysis of metering data constitute the primary, if not the sole, basis for calculating consumption and benefit from a rebuttable presumption of accuracy. Where such data are challenged, the burden rests on the user to allege and prove, including by way of presumptions, circumstances capable of rebutting that presumption, such as malfunctioning equipment, tampering, reading errors or similar irregularities.