title: Italy — Licensing, Authorisation & Market Access | World Payments Monitor canonical: https://payments.gi/jurisdictions/italy/w1a/ publisher: Asymmetric Intelligence ### W1a Licensing, Authorisation & Market Access 1 gap Confirmed confirmed 2026-07-04 Italy runs a dual bank-PSP / non-bank licensing regime under the Testo Unico Bancario (TUB, D.Lgs. 385/1993) and the PSD2-transposing D.Lgs. 11/2010, supervised by Banca d'Italia. Payment institutions (IP) and e-money institutions (IMEL) are authorised and registered by Banca d'Italia under the Disposizioni di vigilanza per gli IP e IMEL, most recently updated 3 February 2026 to align with DORA. Capital thresholds are tiered by service type, and a new MiCAR/PSD2 dual-authorisation regime for crypto-asset service providers offering payment-like EMT services took effect 2 March 2026. Open gap — wpm-int-1 No independent Banca d'Italia source found this cycle to confirm or rule out an Italy-specific PI/EMI licensing-rule change._Structurally absent rather than a research gap; noted per methodology's bias-correction guardrail for Gibraltar/Crown Dependency coverage._ Horizon · 2026-Q4 (± six months) PSD3/PSR formal adoption pending_Consultation · Tier 3 source_ Standing sub-brief · as of 5 July 2026 211 words · last cycle 2026-09-28 #### Licensing, Authorisation & Market Access Banca d'Italia supervises Italy's dual bank-PSP and non-bank payment-institution licensing regime under the TUB and D.Lgs. 11/2010, with capital requirements tiered by service scope: EUR125,000 for full-scope payment institutions offering services 1-5 under Art.1(2)(h-septies.1) TUB, EUR20,000 for money-remittance-only payment institutions, and EUR50,000 for payment-initiation-service providers. These thresholds set the capital-entry cost for any operator seeking an Italian PI or e-money institution licence and directly shape market-access economics for new entrants and PIS-only fintechs. From 2 March 2026, a new MiCAR/PSD2 dual-authorisation regime requires crypto-asset service providers offering e-money-token transfer or custody services that qualify as payment services to hold both a MiCAR CASP authorisation and a PSD2 payment/e-money institution authorisation, or to partner with an already-authorised payment service provider, with cumulative capital requirements applying across both regimes. The requirement materially raises the compliance and capital bar for crypto-native firms wanting to offer payment-like e-money-token services in Italy, favouring bank-partnership or dual-licence structuring over stand-alone crypto entry. #### Outlook With the capital-threshold architecture and the new crypto dual-authorisation regime both now in force, the near-term licensing question for Italy is less about further rule-making and more about how quickly crypto-native applicants absorb the cumulative capital burden, and whether bank-partnership models displace independent CASP-only entry into payment-like e-money-token services. Periodic update · new data 2026-09-28 #### Licensing, Authorisation & Market Access The Council of the EU's 23 April 2026 'I' Item Note carried final compromise texts for the PSD3 Directive and the PSR (Payment Services Regulation), inviting COREPER approval as the next procedural milestone on the path toward formal adoption. This is a pre-adoption legislative development, not yet in force, but it is a materially advanced stage relative to earlier points in the legislative process: an 'I' Item Note with final compromise texts signals that political agreement on the substance has been reached and the remaining steps are procedural confirmation rather than substantive renegotiation. For Italy's payment-institution and e-money-institution licensing landscape specifically, the significance of PSD3/PSR lies in its consolidation of the current separate EMI (e-money institution) and PI (payment institution) authorisation tracks into a single-licensing regime. Once in force, this would change the authorisation pathway for Italian payment and e-money firms, though the practical mechanics of how Italy's own competent authority would administer that consolidated regime were not detailed in the sources reviewed this cycle, and the regime itself remains pending formal adoption. The distinction between bank and non-bank payment-service provision remains structurally relevant to how this licensing consolidation will apply in practice. A single EMI/PI licensing regime under PSD3/PSR would primarily affect non-bank payment institutions and e-money institutions, since banks already operate under a separate prudential authorisation track; the consolidation is therefore principally a non-bank-PI/EMI development rather than one that changes bank-sector licensing directly. #### Outlook Formal adoption of PSD3/PSR is expected as scheduled toward Q4 2026, subject to COREPER approval and any subsequent procedural steps in the EU legislative process; until formal adoption occurs, Italy's current separate EMI/PI authorisation tracks remain unchanged. The pace of COREPER approval following the 23 April 2026 'I' Item Note is the concrete near-term signal to watch for confirmation that the single-licensing regime is proceeding on the currently expected timeline. **Sources and findings (5)** 1. T1 [https://www.bancaditalia.it/compiti/vigilanza/accesso-mercato/istituti-pagamento/index.html](https://www.bancaditalia.it/compiti/vigilanza/accesso-mercato/istituti-pagamento/index.html) retrieved 2026-07-04 2. T1 [https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/disposizioni/disp-ip-20120620/index.html](https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/disposizioni/disp-ip-20120620/index.html) retrieved 2026-07-04 3. T1 [https://www.bancaditalia.it/compiti/vigilanza/business-in-italia/attivita-istituto-imel/index.html](https://www.bancaditalia.it/compiti/vigilanza/business-in-italia/attivita-istituto-imel/index.html) 4. T3 [https://en.spaziocrypto.com/regulation/mica-bank-crypto-custody-europe-explained/](https://en.spaziocrypto.com/regulation/mica-bank-crypto-custody-europe-explained/) retrieved 2026-07-04 5. T1 [https://www.bancaditalia.it/compiti/vigilanza/accesso-mercato/imel/index.html](https://www.bancaditalia.it/compiti/vigilanza/accesso-mercato/imel/index.html) retrieved 2026-07-04