Fintech & payments regulation in Italy (2026)
Fintech and digital payments in Italy: licensing regime.
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.
Legal framework
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.
How to get an EMI license in Italy
To provide electronic-money or payment services in Italy you need authorisation as an Electronic Money Institution (EMI), supervised by the Banca d'Italia, under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
- Authority
- the Banca d'Italia
- License required
- authorisation as an Electronic Money Institution (EMI)
- Framework / law
- the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2)
- Minimum capital
- €350,000 initial capital for a full (Authorised) EMI; a lighter Small EMI regime exists below an average €5m of outstanding e-money
- Timeline
- roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete
- Cost
- application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs
- Passporting
- Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
What an EMI license in Italy covers
- Issuing electronic money and maintaining payment accounts
- Executing payment transactions: credit transfers, direct debits and card payments
- Issuing and/or acquiring payment instruments
- Money remittance
- Payment initiation services (PIS)
- Account information services (AIS)
Step by step: getting an EMI license in Italy
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there).
Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies.
Deposit and evidence the €350,000 initial capital.
Submit the application to the national competent authority.
The authority has three months from a complete application to grant or refuse.
On authorisation you are entered in the national and EBA registers, then passport into other EEA states before serving them.
Documents required in Italy
- Programme of operations listing each payment service you will provide
- Business plan with a three-year budget forecast
- Evidence of the €350,000 initial capital
- Governance arrangements and internal-control mechanisms
- AML/CFT policy and appointment of a compliance officer
- Safeguarding arrangements for client funds (segregated account or insurance)
- Security policy, incident management and ICT resilience procedures
- Fit-and-proper documentation for directors and qualifying shareholders
- Description of any outsourcing, agents or distributors
- Professional indemnity insurance where you provide PIS or AIS
Ongoing obligations in Italy
- Maintain own funds under the applicable calculation method (A, B or C)
- Safeguard client funds at all times, segregated or insured
- Apply strong customer authentication (SCA) under PSD2
- Run continuous AML/CFT monitoring and reporting
- Report major operational and security incidents to the regulator
- Submit annual audited accounts and periodic regulatory reporting
Key points: digital payments & fintech in Italy
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.
EMI license in Italy: FAQ
Do you need a license to run an e-money business in Italy?
Yes. To provide electronic-money or payment services in Italy you need authorisation as an Electronic Money Institution (EMI), supervised by the Banca d'Italia, under the EU E-Money Directive (2009/110/EC) and the Second Payment Services Directive (PSD2).
Which authority issues EMI licenses in Italy?
The Banca d'Italia.
How much does an EMI license cost in Italy?
Application and supervisory fees that vary by country (often €5,000–€25,000), plus safeguarding and audit costs.
How long does it take to get an EMI license in Italy?
Typically roughly 3–12 months; the regulator has up to 3 months to decide once the application is complete.
What documents do you need for an EMI license in Italy?
The application file centres on programme of operations listing each payment service you will provide; business plan with a three-year budget forecast; evidence of the €350,000 initial capital; governance arrangements and internal-control mechanisms; plus fit-and-proper evidence for directors and qualifying shareholders.
What is the application process for an EMI license in Italy?
Incorporate in the member state and establish real local substance (registered office and part of the business conducted there). Build the application file: programme of operations, three-year business plan, governance, AML/CFT, safeguarding and security policies. The authority then assesses the file and, once authorised, you can begin operating.
Does an Italy EMI license work in other EU/EEA countries?
Yes: an EMI authorisation passports across the whole EEA (all 27 EU states plus Norway, Iceland and Liechtenstein).
Timeline of decisions
- Guidance · officialMiCAR becomes fully applicable; Consob/Bank of Italy operational guidance
With the EU MiCA Regulation fully applicable, Consob and Banca d'Italia issued public notices clarifying the authorization process for crypto-asset service providers and the transitional regime for existing operators. This made crypto-asset licensing operational in Italy.
CONSOB
- Guidance · officialConsob-Banca d'Italia joint recognition note on MiCAR
The two authorities published a joint synthesis note allocating supervisory roles under MiCA: Banca d'Italia over e-money tokens and (jointly) asset-referenced tokens, Consob over crypto-asset markets and service providers. It set the operating ground rules ahead of full MiCA application.
CONSOB / Banca d'Italia
- Law · officialDecree-law 25/2023 introduces DLT-based digital financial instruments
Italy implemented the EU DLT Pilot Regime (Reg. 2022/858), enabling issuance and circulation of financial instruments via distributed ledger technology and authorizing Banca d'Italia and Consob to license DLT market infrastructures and registrars. It extended fintech licensing into tokenized securities.
Banca d'Italia
- Guidance · officialBanca d'Italia launches Milano Hub innovation centre
Banca d'Italia opened Milano Hub to support digital transformation of finance, with its first call for fintech projects running September-October 2021. It became a key 'innovation facilitator' for firms developing new payment and financial technologies.
Banca d'Italia
- Law · officialRegulatory sandbox established by Ministerial Decree 100/2021
Decree 100/2021 set up the FinTech Committee and the regulatory sandbox run jointly by Banca d'Italia, Consob and IVASS, letting supervised intermediaries and fintechs test innovative products under a simplified, time-limited regime (first window opened 15 November 2021). It gave Italy a structured testbed for novel payment and fintech models.
MEF — Dipartimento del Tesoro
- Law · officialLegislative Decree 218/2017 transposes PSD2
Italy transposed EU Directive 2015/2366 (PSD2) by amending the Banking Consolidation Act (TUB), introducing strong customer authentication, open-banking access (AISPs/PISPs) and updating payment-institution licensing under Banca d'Italia supervision. It reshaped how payment services are authorized and accessed in Italy.
Camera dei Deputati
- Law · officialLegislative Decree 11/2010 transposes PSD1 and creates payment institutions
Implementing EU Directive 2007/64, the decree introduced the new licensed category of 'payment institutions' (istituti di pagamento) alongside banks and e-money institutions, inserting Title V-ter into the TUB under Banca d'Italia authorization and supervision. It established the modern non-bank payment-services licensing regime.
MEF — Dipartimento delle Finanze
- Law · officialLaw 39/2002 transposes the E-Money Directive, creating IMEL
Law 39/2002 implemented Directives 2000/46/EC and 2000/28/EC, amending the TUB to establish electronic money institutions (istituti di moneta elettronica, IMEL) authorized and supervised by Banca d'Italia. It laid the foundation for Italy's licensed e-money/digital-payments framework.
Banca d'Italia
Sources
- bancaditalia.it/compiti/vigilanza/accesso-mercato/istituti-pagamento/index.html?com.d
- bancaditalia.it/compiti/vigilanza/accesso-mercato/imel/index.html?com.dotmarketing.ht
- bancaditalia.it/compiti/vigilanza/accesso-mercato/index.html?com.dotmarketing.htmlpag
- bancaditalia.it/compiti/sispaga-mercati/comitato-pagamenti-italia/bonifici-istantanei
- bancaditalia.it/compiti/sistema-pagamenti/pagamenti-tips/index.html?com.dotmarketing.
- bancaditalia.it/pubblicazioni/note-stabilita/2026-0050/index.html?com.dotmarketing.ht
- hoganlovells.com/en/publications/psd2-and-gdpr-bank-of-italy-view
- twobirds.com/en/trending-topics/buy-now-pay-later-regulatory-tracker/italy
- bancaditalia.it/compiti/sispaga-mercati/normativa-sorveglianza/Regulation_of_9_Novemb
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Next topicOrientation, not legal advice: verify against the primary sources linked above. Last verified 7 Oct 2026. Methodology & how to cite · State of Technology Regulation 2026