Licensing and intellectual property
E-Money and Payment Institution Licence in Italy
Banca d'Italia authorisation · IMEL and IP
The Banca d'Italia file for an Italian e-money or payment institution, prepared and coordinated for a founder or group abroad.
- Authorised by the Banca d'Italia
- IMEL capital: EUR 350,000 paid up
- 90-day term from a complete file
- Applicant: an Italian company, seat and head office in Italy
What we prepare for an IMEL or payment institution application
We prepare and coordinate the application work of the Italian company applying to become an e-money institution (istituto di moneta elettronica, IMEL) or payment institution (istituto di pagamento, IP). The Banca d'Italia authorises, the notary receives the deed, the authorised institution carries out the regulated activity. Issuing e-money is reserved to banks and IMELs (Banca d'Italia).
We work for founders and groups outside Italy: a new Italian IMEL or IP, a payment institution from outside the EU entering Italy, or a group adding e-money to an existing business. Crypto-asset services follow a route of their own, covered by our CASP authorisation service.
IMEL or payment institution: the two routes
The conditions of each licence side by side, from the Banca d'Italia's pages and the TUB (D.Lgs. 385/1993). The table states the rules; it does not choose a route.
| Condition | E-money institution (IMEL) | Payment institution (IP) |
|---|---|---|
| What it may do | Issue e-money and provide payment services | Provide payment services only |
| Issues e-money | Yes: reserved to banks and IMELs | No |
| Payment services | Services 1 to 8 of Art. 1(2)(h-septies.1) TUB, also unconnected with e-money | The services listed in its application |
| Initial capital | EUR 350,000 paid up | EUR 20,000 for money remittance only; EUR 50,000 for payment initiation only; EUR 125,000 for services 1 to 5 |
| Term to decide | 90 days from a regular and complete application | 90 days from a regular and complete application |
| Admitted forms and seat | S.p.A., S.a.p.a., S.r.l. or cooperative; registered office and head office in Italy | The same conditions |
| Payment initiation | Civil-liability insurance or equivalent guarantee (Art. 114-quinquies(1-bis) TUB) | Civil-liability insurance or equivalent guarantee (Art. 114-novies(1-bis) TUB) |
| Register | IMEL register, Art. 114-quater TUB | IP register, Art. 114-septies TUB |
IMEL and IP conditions from the Banca d'Italia's IMEL page, its payment institution page, its FAQ page on capital tiers and its market-access terms, and Art. 114-novies TUB, in force since 9 January 2026.
Which licence, and whether a hybrid fits, is your decision; the file plan sets out the conditions of each against your services.
What our application work covers
Nine pieces of work, each with its owner named; the people's tests come from the Banca d'Italia's FAQ page on IMELs.
- Scoping the licence and the payment services that go into the application
- A pre-filing meeting with the Banca d'Italia, if you want one
- The people's files: directors, statutory auditors, holders of 10% or more
- Apostille or legalisation and certified Italian translation, coordinated with your authorities
- The notarial deed of the applicant company, coordinated with the notary
- The capital payment and the bank's certificate, coordinated with the bank
- The programme of operations and organisational report, drafted with you
- Board minutes on officers, the assembled file, the PEC filing, follow-up answers
- The Register certificate, the ABF membership and the start-of-operations notice
The decision is the Banca d'Italia's, the deed the notary's, the capital certificate the bank's.
Who applies, and through which company
The applicant is always an Italian company; the route to it depends on where you start.
- A new Italian institution
An S.p.A., S.a.p.a., S.r.l. or cooperative with registered office and head office in Italy (Art. 114-quinquies TUB). Formed new, or one of the shelf companies in Italy, meeting the same form, seat and file conditions.
- A payment institution from outside the EU
It cannot enter through a branch: it forms an Italian subsidiary (filiazione), authorised like a new institution (Banca d'Italia FAQ page). We set up the foreign-owned company in Italy that applies.
- A group that keeps its business
A company with other businesses may issue e-money through a single ring-fenced fund (patrimonio destinato) with named responsible persons (Art. 114-quinquies(4) TUB). The Banca d'Italia may require a company that only issues e-money (Art. 114-quinquies(5)).
- An institution authorised in another EU state
It enters Italy by a notification from its home authority to the Banca d'Italia, not by a new Italian authorisation (Banca d'Italia FAQ page). No Italian applicant company is formed.
From the Italian company to the IMEL register
Before filing: no statutory term
- Scope and optional meetingPre-filing meeting does not count toward the term
- The people's documentsDirectors, auditors, holders of 10% or more
- Italian company and capitalIMEL capital of at least EUR 350,000, certified by the bank
- Board minutes, programme, PEC filingFiled by the legal representative
The Banca d'Italia's terms
- DecisionFrom a regular and complete applicationWithin 90 days
- SuspensionInformation requests, inspections or opinionsAt most 180 days
- Notice of refusal groundsWritten observations10 days
- Register entry and startIdentification code; operations start after ABF membershipWithin 12 months of registration
Sources: Banca d'Italia, market access and IMEL pages; Art. 114-quinquies TUB.
Scope, and an optional pre-filing meeting
IMEL or IP, which payment services, a dedicated company or a hybrid: we set out the conditions, you decide. A pre-filing meeting is optional and does not count toward the term (Banca d'Italia). No statutory term.
The people's documents
Criminal-record certificates, codice fiscale and evidence of soundness for directors, auditors and holders of 10% or more (Banca d'Italia), apostilled and translated. Part of what has to be ready before the Italian deed is signed.
The Italian company and the capital
The notary receives the applicant's deed. The capital, at least EUR 350,000 for an IMEL, goes into a bank whose head office certifies it; the Banca d'Italia checks the funds' origin (FAQ page).
Board minutes and the programme
The board verifies each officer's requirements under D.M. MEF 169/2020 in analytical minutes. The programme carries three-year forecasts, base and stress, with safeguarding and AML procedures, and insurance if payment initiation is offered.
Filing by PEC
The company's legal representative files by PEC with the Banca d'Italia's Servizio Rapporti Istituzionali di Vigilanza, Divisione Costituzioni Banche e Altri Intermediari. The filing takes a day.
The 90-day term
The Banca d'Italia decides within 90 days of a regular and complete application; an incomplete one starts nothing. Information requests, inspections or opinions suspend the term for at most 180 days (Banca d'Italia, market access).
Before any refusal
A notice of the grounds suspends the term and opens 10 days for written observations (market-access page). Refusal follows where sound and prudent management or the payment system's regular functioning is not guaranteed (Art. 114-quinquies(2) TUB).
Register and start
The company sends its Register of Companies certificate; the Banca d'Italia enters the IMEL in its register with an identification code. Then ABF membership, and operations start within 12 months of registration (IMEL page).
The Banca d'Italia's pages we read publish no average duration, so we give the terms, never a date. Passport notifications to other member states can follow under Art. 114-quinquies(6) TUB.
IMEL or payment institution, dedicated or hybrid?
Send us the services in scope and your group structure; the plan sets out the routes, the applicant company and the file.
What goes into the Banca d'Italia file
The elements the Banca d'Italia's own pages list; its supervisory provisions of 17 May 2016 set the full content of the programme.
| File element | Prepared by | What the Banca d'Italia examines | Source |
|---|---|---|---|
| Deed and statute | The notary, with the founders | Form, registered office and head office in Italy, the regulated object | Art. 114-quinquies(1) TUB |
| Description of the services | You, with us | Which payment services the application covers | Banca d'Italia FAQ page |
| Programme of operations | You, with us | Forecast accounts and own-funds projections for three years, base and stress | Banca d'Italia FAQ page |
| Organisational report, IT, internal controls, safeguarding | You, with us | Organisation and IT, with particular attention to safeguarding client funds, including accounting procedures | Banca d'Italia FAQ page |
| List of direct and indirect shareholders, group map | You, with us | Close links that could hinder supervision | Art. 114-quinquies(1) TUB |
| Evidence on qualifying holders (10% or more) | The holders, with us | Honour, reputation, competence and financial soundness | Banca d'Italia FAQ page |
| Board minutes on officers | The board | Suitability under D.M. MEF 169/2020; criminal-record and pending-charges certificates may be asked for | Banca d'Italia FAQ page |
| Bank capital certificate and source of funds | The bank; the shareholders | The paid-up capital and the origin of the funds | Banca d'Italia FAQ page |
| Insurance for payment initiation | You, with an insurer | Civil-liability insurance or an equivalent guarantee | Art. 114-novies(1-bis) TUB |
File elements from the Banca d'Italia's FAQ page on IMEL and IP authorisation and Arts. 114-quinquies and 114-novies TUB; a list of what those pages name, not the annexes in full.
Once the institution operates, client funds are recorded per client and invested in a patrimony separate from its own, out of its creditors' reach (Art. 114-quinquies.1 TUB, in force since 14 September 2024).
Problems we solve
Five places where an IMEL or IP file stalls for a group abroad, and what we do about each.
- "We filed, and the clock never started"
An incomplete application does not open the procedure; the Banca d'Italia tells the applicant the causes (market-access page). We review the file against the Banca d'Italia's list before the PEC filing.
- Certificates from three countries
Officers' criminal-record and pending-charges certificates, apostilled or legalised and translated, are part of the people's file. Missing ones invite requests that can suspend the term. We collect them first.
- The capital must sit in an Italian bank first
The bank's head office certifies the payment and the Banca d'Italia checks the origin of the funds (FAQ page). We prepare the source-of-funds file before the bank meeting: see the corporate bank account page.
- A shareholder's wealth is hard to document
Holders of 10% or more are assessed for honour, reputation, competence and financial soundness (Banca d'Italia FAQ page). We build their evidence, the list of direct and indirect shareholders and the group map early.
- A notice of refusal grounds arrived
The applicant has 10 days to answer in writing (Banca d'Italia, market access). We draft the observations with you inside that window, point by point against the grounds the notice states.
A file already drafted, or a shareholder chain to clear?
Send the draft file or the shareholder chain; we review it against the Banca d'Italia's list before the PEC filing.
Who prepares your file
From our practice
We put the company and the capital in place before the PEC filing, coordinate the notary, the bank and the translators, and answer the Banca d'Italia's requests. It decides; we promise no grant and no date.
Valentina Orsini, licensing, fiduciary and founder-permits lead, Rome; nine years on authorisation files. Italian, English, German. Not an IMEL, an IP or an avvocato.
Related services
- Crypto-asset servicesA route of its own, with its own file: our CASP authorisation service.
- Ready-made companiesAn existing Italian company as the applicant: shelf companies in Italy, on the same conditions.
- Trade marksThe institution's name protected in Italy: our trademark registration service.
- Patent Registration in Italy and EuropePayment technology behind the service, protected by a patent filing.
Frequently asked questions
Can our foreign company hold an e-money licence in Italy directly?
No. The applicant must be an Italian S.p.A., S.a.p.a., S.r.l. or cooperative with its registered office and head office in Italy (Art. 114-quinquies(1) TUB). A payment institution from outside the EU forms an Italian subsidiary, authorised like a new institution; one authorised in another EU state enters by a notification from its home authority.
Is a payment institution (PSP) licence the same as an EMI licence?
No. A payment institution provides payment services but may not issue electronic money. An e-money institution (IMEL) issues electronic money and may also provide payment services, and its initial capital is higher: EUR 350,000 paid up, against EUR 20,000 to EUR 125,000 for a payment institution, depending on the services (Banca d'Italia).
How long does authorisation take?
The Banca d'Italia's term is 90 days for an IMEL or a payment institution, counted only from a regular and complete application. Requests for information, inspections or opinions can suspend it for at most 180 days, and a notice of refusal grounds opens 10 days to reply. The pages we read publish no average duration.
How much capital does an e-money or payment institution need?
An IMEL needs EUR 350,000 paid up. A payment institution needs EUR 20,000 for money remittance only, EUR 50,000 for payment initiation only and EUR 125,000 for the other payment services (Banca d'Italia). These are initial capital figures, not the own funds required once the institution operates.
Where is the capital paid, and do we need an Italian bank account first?
The capital is paid into a bank, whose head office certifies the payment for the application file, and the Banca d'Italia checks where the funds used to subscribe it came from. The bank's own onboarding of a non-resident shareholder is a separate step with no published term; we prepare the source-of-funds file for it.
Will the Banca d'Italia examine our shareholders and directors?
Yes. Holders of 10% or more of the shares or votes are assessed for honour, reputation, competence and financial soundness. The suitability of directors and statutory auditors follows D.M. MEF 169/2020: the board verifies it first, and the Banca d'Italia may ask for criminal-record and pending-charges certificates (Banca d'Italia FAQ page).
On what grounds can the application be refused?
The Banca d'Italia refuses authorisation when sound and prudent management or the regular functioning of the payment system is not guaranteed (Art. 114-quinquies(2) TUB). Before refusing, it sends a notice of the grounds, which suspends the term, and the applicant has 10 days to submit written observations.
Can our group keep its existing business and add e-money?
Yes, as a hybrid issuer. A company that runs other businesses may issue e-money if it meets the conditions of Art. 114-quinquies(1) TUB, forms a single ring-fenced fund (patrimonio destinato) and names the persons responsible. Where the other business threatens soundness or supervision, the Banca d'Italia may require a company that only issues e-money.
What does the application cost?
None of the Banca d'Italia pages we read names an application fee, a supervisory contribution or a stamp duty for an IMEL or payment institution application; that does not mean there is none. Our work depends on the licence, the services in scope and the group structure, and is quoted on request.
What is an e-money institution (IMEL) in Italy?
An IMEL, istituto di moneta elettronica, is an undertaking other than a bank that issues electronic money; issuing it is reserved to banks and IMELs. An IMEL may also provide payment services 1 to 8 of Art. 1(2)(h-septies.1) TUB, even unconnected with e-money (Banca d'Italia, IMEL page).
Who grants an e-money licence in Italy, and how is the file filed?
The Banca d'Italia, on the conditions of Art. 114-quinquies(1) TUB. The application goes by PEC to its Servizio Rapporti Istituzionali di Vigilanza, Divisione Costituzioni Banche e Altri Intermediari, and the procedure starts only once the application is regular and complete. Only banking applications go through the SSM portal instead.
Can an S.r.l. be an e-money institution?
Yes. The S.r.l. is one of the four company forms the Banca d'Italia admits, with the S.p.A., the S.a.p.a. and the cooperative, provided its registered office and head office are in Italy, where at least part of the authorised activity is carried out (Art. 114-quinquies(1) TUB). Its paid-up capital must still reach EUR 350,000.
How are customers' funds protected?
The institution records the funds received for each client and invests them in assets forming a patrimony separate from its own, which its creditors and the depositary's creditors cannot reach (Art. 114-quinquies.1 TUB). EU law requires the funds to be safeguarded no later than five business days after the e-money is issued (Art. 7(1) Directive 2009/110/EC).
Can an Italian e-money institution operate across the EU?
Yes. An Italian IMEL may operate in another EU member state, with or without branches, under procedures set by the Banca d'Italia; operating in a country outside the EU needs the Banca d'Italia's prior authorisation (Art. 114-quinquies(6) TUB). The notifications follow registration, under those procedures.
What happens after the licence is granted?
A newly formed company sends the Banca d'Italia the Register of Companies certificate of its entry date and is entered in the register of IMELs with an identification code (Banca d'Italia, IMEL page). It then joins the ABF out-of-court dispute scheme (Art. 128-bis TUB) and notifies the start of operations within 12 months of registration.
Request an authorisation file plan
Send the services in scope, your group structure and the countries of your directors and holders; we reply with the routes and the file plan.