Banca d’Italia Albo of IPs and IMEL: reading the register
The Banca d’Italia Albo of payment institutions and e-money institutions is the public record that tells a bank, a partner or a supervisor whether an Italian firm may provide a given payment service, through which agents and in which other member states. It is not one list but several: the albo of payment institutions under Article 114-septies of the Testo Unico Bancario (TUB, D.Lgs. 385/1993), the albo of e-money institutions under Article 114-quater, and a special section for providers that only offer account information. Banca d’Italia keeps them and publishes them through a single search service. For an operator, the entry is both a credential and an obligation: it is what counterparties check, and it is only as accurate as the notifications the firm sends.
1. What the Albo is
Article 114-septies TUB requires Banca d’Italia to keep a public, regularly updated albo of the payment institutions it has authorised. For each institution the albo shows the payment services it may provide and its agents. Branches that Italian payment institutions open in other EU member states are entered too. For providers of payment initiation services, the albo also carries the details of the professional liability insurance or equivalent guarantee.
Article 114-quater does the same for e-money institutions (IMEL): Banca d’Italia enters Italian-authorised IMEL in their own albo, together with the branches they establish in other member states.
Three further rules shape the register:
- Account information only. Providers offering only account information services sit in a special section of the payment institutions albo, with their insurance details published (Article 114-septies, paragraph 2-bis).
- Excluded providers. Information that certain providers relying on PSD2 exclusions must give under Article 2, paragraph 4-bis of D.Lgs. 11/2010 is published as an appendix to the albo (paragraph 2-ter). Banca d’Italia publishes it as the Elenco dei prestatori di servizi esclusi dall’ambito applicativo della PSD2.
- Disclosure. Payment institutions must state their albo registration in their documents and correspondence (paragraph 2).
Licensing is the gateway to the albo, not the subject of this article. Under Banca d’Italia’s supervisory provisions for payment institutions and e-money institutions (Disposizioni di vigilanza per gli istituti di pagamento e gli istituti di moneta elettronica), the newly authorised institution sends the certificate of its entry in the companies register; Banca d’Italia then enters it in the albo, listing the agents it intends to use, and the institution later notifies the start of operations.
2. Where to search it
The public route is Banca d’Italia’s Albi ed elenchi di vigilanza service, reached from the citizen-services area of bancaditalia.it and hosted on the InfoStat platform (the GIAVA Inquiry application). It covers banks, financial intermediaries, investment firms, payment and e-money institutions, their agents and foreign intermediaries authorised to operate in Italy. Results can be exported to PDF or Excel, and the interface was redesigned in March 2021.
The menu that matters for payments has three entries:
- Intermediari servizi di pagamento — a selector with three lists: Albo IMEL ITA ex 114-quater, Albo IP art. 114-septies TUB, and the special section for account information service providers (AISP).
- Agenti di servizi di pagamento — split into agents operating in Italy and agents operating abroad.
- Banche ed altri intermediari esteri abilitati in Italia and its mirror, Banche ed altri intermediari italiani abilitati all’estero — the passport views.
Each page shows a “data updated to” date, offers a free-text search and a historical/advanced search, and the left menu also carries Variazioni (changes), Provvedimenti rilevanti, predefined reports and explanatory notes. Questions about the content go to Banca d’Italia’s Servizio Rapporti Istituzionali di Vigilanza.
3. How to read an entry
Opening an institution gives a detail page with tabs: Anagrafica (identity data), Albi, Attività autorizzate/notificate, Competenze di Vigilanza and Classificazioni, plus links to group data and the institution’s history.
| Field | What it tells you | Operator use |
|---|---|---|
| Codice meccanografico (codice BI) | Banca d’Italia’s identification code for the intermediary | The key for matching the entry in KYC files, reporting and correspondence |
| Codice fiscale and LEI | Italian tax code and legal entity identifier | Cross-check against the companies register and the LEI record |
| Tipo intermediario / Classificazione | IP or IMEL, and the sub-classification (for example an IMEL with full operations) | Confirms the licence type, not just the name |
| Periodo di validità | Date from which the current data apply | Shows whether you are looking at fresh or stale data |
| Attività autorizzate/notificate | Each activity, mode of operation, state, authorisation or notification date, revocation or closure date, start and end of operations | The real scope: services, and where and how they are exercised |
| Sede legale / Direzione generale | Registered and head office | For foreign intermediaries, the address of the first Italian branch, with the home state shown separately |
The activities grid is the part to read slowly. A name in the albo proves authorisation; the grid proves which services, in which state, and whether through a branch or under the freedom to provide services. Because Banca d’Italia can revoke a single service while the institution stays in the albo, the presence of the name alone is never enough.
4. Agents in the Albo
Agents are part of the albo by statute. The supervisory provisions set the mechanics:
- Agents in Italy. The institution notifies Banca d’Italia of its intention to use agents under Article 128-quater TUB, with a description of its AML controls over them, a declaration that it has checked their controls, organisation and resources, and the services involved. Agent identity data go through the reporting channel set out in Banca d’Italia’s Communication of 24 January 2019 on the new reporting of agents distributing payment services. Banca d’Italia enters the agent within 60 days of a complete notification, and the agent may operate only after entry.
- Agents in other member states. Banca d’Italia passes the notification to the host authority within 30 days and enters the agent within 90 days of a complete notification.
- E-money. IMEL cannot use agents to issue e-money. Distribution and redemption run through soggetti convenzionati, which are notified but are not agents.
The public agent views reflect this split. The Italian view lists, for each agent, the principal’s codice meccanografico and name, the agent’s name, whether it is a natural or legal person, and its OAM registration number — because an agent acting in Italy for an Italian institution must also be enrolled with the Organismo Agenti e Mediatori. The view of agents operating abroad shows the agent’s identification code instead.
5. Branches and EU passports
Outbound, an Italian institution opening a branch in another member state notifies Banca d’Italia, which passes the file to the host authority within 30 days and enters the branch in the albo within 90 days of a complete notification. The institution then communicates the branch’s start date; later material changes, new branches or closures are notified without delay, and closures at least 15 days in advance. Freedom to provide services follows a lighter notice: state and services, passed to the host authority within 30 days, with changes to the services notified 30 days ahead.
Inbound, an EU institution passporting into Italy notifies its home authority, not Banca d’Italia. Its branch may start once Banca d’Italia has received the home authority’s communication. These firms appear in the Banche ed altri intermediari esteri abilitati in Italia view rather than in the Italian albi.
An EU institution using agents in Italy under the right of establishment without a branch must designate a central contact point in Italy (Article 128-decies, paragraph 2-bis TUB). Where it has already set one up under the AML decree, D.Lgs. 231/2007, the same contact point serves both purposes. Its name, address and contacts travel with the home-state notification.
6. The Albo, the OAM registers and the EBA register
Three bodies publish overlapping data. Knowing which holds what avoids the most common due-diligence error: concluding that a firm or agent is unregistered because it is not where you looked.
| Register | Kept by | Who is in it | Legal basis |
|---|---|---|---|
| Albo IP / Albo IMEL / AISP section | Banca d’Italia | Italian IP and IMEL, their agents and EU branches | Articles 114-septies and 114-quater TUB |
| Elenco degli agenti in attività finanziaria — special section for payment services | OAM | Agents promoting and concluding payment services contracts on mandate of intermediaries | Article 128-quater TUB |
| Registro dei soggetti convenzionati e agenti | OAM | Other agents and convenzionati of PSPs and IMEL, including those of EU firms; a dedicated section for central contact points | Article 45 D.Lgs. 231/2007; MEF decree of 31 May 2022 |
| EBA payment institutions register | EBA, from national data | Institutions, agents and branches across the EEA | Article 15 PSD2; Regulations (EU) 2019/410 and 2019/411 |
The OAM registry opened on 3 July 2023. Italian PSPs and IMEL, branches of EU ones and central contact points communicate the data of their agents and convenzionati operating in Italy every six months, through OAM’s portal, after accrediting with OAM. Breaches of Article 45 are sanctioned by OAM under Article 61, paragraph 2 of the AML decree.
Under Article 114-septies, paragraph 1-bis, and Article 114-quater, paragraph 1-bis, Banca d’Italia must pass albo entries and changes to the EBA without delay. The EBA register reproduces what national authorities send, is updated at least daily as their registers change, and carries no legal effect of its own. For Italy, the albo is the authoritative source; the EBA register is the cross-border index.
7. Keeping the entry current
An albo entry does not maintain itself. The supervisory provisions put the burden on the institution:
- Agent changes are communicated without delay; Banca d’Italia updates the albo within 20 days of a complete communication.
- Agent terminations are communicated within 15 days of the end of the relationship.
- New payment services are notified in advance with a new programme of operations; the institution may start if Banca d’Italia opens no prohibition procedure within 60 days, and the albo is then updated.
- Dormant authorisations lapse: an institution that does not use its authorisation within 12 months of entry is cancelled without further formalities, unless it obtained an extension, normally of up to six months, beforehand.
- Prolonged inactivity of more than six months is a ground for revocation and cancellation.
Two registers, two calendars: the Banca d’Italia agent notification is event-driven, the OAM communication is semi-annual. A firm that only runs one of them will have an albo and an OAM record that disagree.
8. Worked case: verifying an Italian partner
Facts: a German e-money institution is onboarding an Italian payment institution as a collection partner. The contract names it as authorised for money remittance and acquiring.
What the rule says: the albo shows the services each payment institution may provide, and Banca d’Italia may revoke a single service without removing the institution from the albo.
What the practitioner does: searches the Albo IP art. 114-septies TUB by codice fiscale, opens the activities tab and saves the export, checking each service row for a revocation or end-of-operations date. Matches the codice meccanografico and LEI to the contract party, then checks the EBA register for consistency.
Outcome: a dated evidence file showing scope, not just existence, and a mismatch flagged before go-live rather than after.
9. Worked case: an agent network that drifted
Facts: an Italian payment institution ended 40 agent mandates in March. Its OAM semi-annual communication went out in time, but nobody told Banca d’Italia.
What the rule says: terminations are communicated to Banca d’Italia within 15 days, through the agent-reporting channel of the January 2019 Communication.
What the practitioner does: the head of compliance reconciles the agent master file against the public Agenti operativi in Italia view and the OAM data, files the late terminations, records the cause, and makes the Banca d’Italia notification a step in the offboarding workflow.
Outcome: one agent list in three places, and a process fix to show the supervisor rather than a recurring breach.
10. FAQ
Is the Albo the same as the EBA register?
No. The albo is Banca d’Italia’s statutory register. The EBA register republishes national data, is updated at least daily, and has no legal effect of its own.
Where do EU payment institutions passporting into Italy appear?
In the Banche ed altri intermediari esteri abilitati in Italia view of the same search service, not in the Italian albi, and in the home authority’s register.
Does an agent need both a Banca d’Italia and an OAM entry?
An agent of an Italian institution in Italy is entered in the albo and must hold OAM enrolment; the public agent view shows the OAM number. Agents of EU firms are communicated to the OAM registry.
Can an IMEL use agents?
For payment services, yes. For issuing e-money, no; distribution and redemption go through soggetti convenzionati.
How fast does Banca d’Italia update the albo?
Within 60 days for a new Italian agent, 20 days for changes, and 90 days for EU agents and branches, each counted from a complete notification.
11. What to do, today
- Head of compliance: pull your own entry, export the activities tab and confirm every service, agent and branch matches your records.
- MLRO: make the albo export, with its update date, part of counterparty due diligence for every Italian PSP partner.
- COO: wire agent onboarding and offboarding to the Banca d’Italia notification, with the 15-day termination clock.
- Head of reporting: calendar the OAM semi-annual communication alongside the event-driven Banca d’Italia notices.
- EU passporting firms: confirm your central contact point is designated, accredited with OAM and reflected in your home-state notification.
Related: REGAFI, France’s register of agents and institutions · The OAM registers in Italy · PSD2 agents and distributors: register and liability
