Pagamenti digitali e Fintech: Italia (2026)
Italy operates a mature, EU-aligned licensing regime for digital payments and fintech, with Banca d'Italia authorising and supervising payment institutions (PIs) and electronic money institutions (EMIs/IMELs). The regime fully implements PSD2 (open banking, strong customer authentication, access-to-account via licensed TPPs), the E-Money Directive, and the EU Instant Payments Regulation (2024/886), with PSD3/PSR negotiations ongoing and BNPL being drawn into supervised consumer credit via the EU CCD2 from November 2026.
Struttura primaria
Banca d'Italia is the competent authority for payment services and e-money under the Italian Banking Act (TUB, Legislative Decree 385/1993) and Legislative Decree 11/2010, with PSD2 (Directive EU 2015/2366) transposed by Legislative Decree 218/2017 (in force 13 Jan 2018). Supervisory requirements are set out in Banca d'Italia's 'Supervisory Provisions for Payment Institutions and Electronic Money Institutions' of 23 July 2019.
Punti chiave
Competent authority & licensing
Banca d'Italia licenses and supervises PIs and EMIs; payment services are reserved to banks, PIs and EMIs. Applicants must file articles of association, a business plan and organisational description, and Banca d'Italia rejects applications where sound and prudent management or the proper functioning of the payment system is not ensured.
Capital requirements
EMIs require minimum initial capital of €350,000 and a prescribed corporate form. Payment institutions have graduated capital thresholds depending on services offered: €20,000 for money remittance, €50,000 for payment initiation services (PIS), and €125,000 for the full range of PSD2 Annex I payment services.
PSD2 open banking & SCA
PSD2 was transposed by Legislative Decree 218/2017 (in force 13 Jan 2018), amending the Italian Banking Act. It licenses Account Information Service Providers (AISPs) and Payment Initiation Service Providers (PISPs), mandates strong customer authentication, and requires account-servicing PSPs to expose dedicated APIs — a market practice largely implemented through the CBI Globe gateway covering most Italian banks.
Instant payments (TIPS / IPR)
Under EU Regulation 2024/886 (Instant Payments Regulation), PSPs offering ordinary SEPA credit transfers in Italy have been required to receive instant credit transfers since 9 January 2025 and to send them since 9 October 2025, when Verification of Payee (VOP) also became mandatory. Banca d'Italia operates TIPS as the pan-European settlement platform for instant payments in euro.
BNPL and CCD2
Banca d'Italia has clarified that most BNPL arrangements qualify as financing under national banking law, so licensing, AML and disclosure duties apply when the lender is not the merchant. The EU Consumer Credit Directive II (CCD2) extends consumer-credit rules — pre-contractual information, creditworthiness assessment — to most BNPL from November 2026.
Operational and ICT supervision
Banca d'Italia's Regulation of 23 July 2019 sets 'Supervisory Provisions for Payment Institutions and Electronic Money Institutions', covering governance, outsourcing of important operational functions and ICT/security risk management; DORA (EU 2022/2554) applies to Italian PIs and EMIs from 17 January 2025.
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