#
Safeguarding for Italian IPs/IMELs that also conduct non-payment business is achieved via a mandatory ring-fenced 'patrimonio destinato' under Art.114-terdecies TUB. Conduct and transparency supervision sits with Banca d'Italia under the TUB's transparency and fairness provisions, with the Banking and Financial Ombudsman (ABF) providing low-cost alternative dispute resolution since 2009. A December 2025 reform (D.Lgs. 208/2025) strengthens Banca d'Italia's enforcement toolkit, including new periodic penalty payments.
Outlook
The ring-fencing regime is a single-T1-anchor finding this cycle and remains a standing structural feature of Italian conduct regulation rather than a live rule-change; watch for a second corroborating anchor before the confidence rating is upgraded, and for any read-across from the D.Lgs. 208/2025 enforcement reform into safeguarding-breach penalties.
Conduct, Safeguarding & Financial Promotions
Verification of Payee, the mandatory IBAN/name-match check for SEPA Instant transfers, became mandatory eurozone-wide from 9 October 2025 under the EU Instant Payments Regulation, and this obligation ran ahead of the broader PSD3/PSR name-match requirement for ordinary SEPA credit transfers. This is a Probable-confidence finding, drawn from a Tier-4 secondary source, and it sits squarely within the conduct and anti-fraud dimension of payments regulation: PSPs must now verify that the payee name matches the account holder before an instant transfer completes, a control specifically aimed at reducing authorised-push-payment fraud vectors that arise when a payer is misled into transferring funds to the wrong or a fraudulent account.
This obligation applies to both bank and non-bank PSPs offering SCT Inst services in Italy, and it is structurally significant because it establishes a name-matching conduct standard ahead of the wider PSD3/PSR framework, meaning Italian PSPs handling instant transfers were required to build this capability on an accelerated timeline relative to institutions handling only ordinary SEPA transfers. The obligation is directly tied to the parallel Instant Credit Transfer mandate under Regulation (EU) 2024/886, live since 9 January 2025, which requires PSPs to offer and receive instant transfers at parity with standard transfers; the two obligations together form the practical conduct backbone of Italy's instant-payments rollout.
No Italy-specific enforcement action or supervisory finding regarding Verification of Payee compliance was surfaced this cycle; the finding is limited to the confirmation of the obligation's applicability and timing.
Outlook
Watch for whether Banca d'Italia or the relevant conduct supervisor publishes any compliance data on Verification of Payee implementation rates among Italian PSPs, and for the broader PSD3/PSR name-match extension to ordinary SEPA transfers, which would bring non-instant transfers under the same conduct standard.
Sources and findings (5)
- T1https://www.bancaditalia.it/compiti/vigilanza/accesso-mercato/istituti-pagamento/faq-istituti-pagamento/index.htmlretrieved
- T1https://www.arbitrobancariofinanziario.it/abf/index.html
- T3https://www.diritto.it/dlgs-208-2025-novita-per-banche-e-vigilanza/retrieved
- T1https://economiapertutti.bancaditalia.it/aree-tematiche/diritti-e-tutele/arbitro-bancario-finanziario/index.html
- T1https://www.bancaditalia.it/compiti/vigilanza/normativa/archivio-norme/disposizioni/disp-ip-20120620/index.htmlretrieved