Anagrafe dei rapporti — Italy’s account data return

Italy asks financial operators for account data twice on different cycles, and then sends the file back to them once a year to check. The Anagrafe dei rapporti finanziari and the Archivio dei rapporti con operatori finanziari are two layers of the same return with different legal bases, different content and the same transmission channel. A monthly communication tracks the lifecycle of relationships; an annual one carries balances and movements; and an annual fotografia di consistenza comes back the other way, showing each operator exactly what the Agenzia delle Entrate believes it holds. Most of the defects in this regime are visible in that third flow and never looked at.

1. Two names, two legal bases, one channel

The Anagrafe dei rapporti finanziari is the relationship layer — who holds what, opened when, closed when, with which connected subjects. It runs on the provvedimenti of 19 January 2007 and 29 February 2008, under Article 7, sixth paragraph, of DPR 605/1973.

The Archivio dei rapporti con operatori finanziari is the accounting layer. It was created by the Salva Italia decree — Decree-Law 201/2011, converted with amendments by Law 214/2011 — whose Article 11 obliged financial operators to communicate information on the balances and movements of active relationships. The Agenzia places the two side by side: the Salva Italia flow sits alongside the earlier anagrafe flow rather than replacing it.

Both travel through the SID, the Sistema di Interscambio Dati, and since 1 January 2016 both use the single record layout — the tracciato unico — set by the provvedimento of 25 January 2016. That is why they behave in practice as one build with two feeds.

2. Two returns, two clocks

The same data model therefore has to serve two shapes: an event feed keyed to openings and closings with connected subjects and roles attached, and a population-and-balances feed keyed to 1 January and 31 December. Serving both from a single nightly extract of open relationships is the commonest structural error here, and it fails in the direction hardest to detect — silently over-reporting.

3. Who files, and how you get on the channel

The obligation falls on the financial operators identified in Article 7, sixth paragraph, of DPR 605/1973 — a statutory category, not a commercial one. A payment or e-money institution operating into Italy should scope itself against that provision and the operator typologies codified in the tracciato unico, not against an intuition about what counts as a financial business. This is one of the highest-consequence returns in the Italian system: it feeds tax enforcement, it is queried against named individuals, and it is the source behind mismatch findings in ISEE means-testing checks that land on your customers.

Getting onto the channel is a separate project from building the file, and it is the step that is routinely underestimated. To send anything to the Archive the operator must first register a certified e-mail address in the Registro elettronico degli indirizzi, through the route the Agenzia documents under indagini finanziarie. Accreditation to the SID then fixes the transport: either an FTP node or PEC. The choice matters beyond the outbound file, because the Agenzia uses the same declared means to send data back — and where an operator has declared both, the return file goes to the FTP node.

4. The role field, and why it is hard

The monthly communication requires the personal data of subjects connected to the relationship with the role specified. That is a harder requirement than it reads, because the roles the archive recognises are a defined set and a firm’s own product vocabulary rarely maps cleanly onto it. Three sources of difficulty recur:

• Multiple roles on one relationship. A person can be both holder and authorised operator, and the return has to express that rather than pick one.
• Roles that change without the relationship changing. Adding or removing an authorised person is a change to the connected subjects, not to the account — and it still has to reach the Archive.
• Legal-person structures. Where the holder is an entity, the connected natural persons and their roles are a separate mapping question again.

A mapping table from internal role names to the archive’s role codes, versioned and owned, is the artefact that makes this tractable. Build it before the first submission rather than after the first rejection.

5. The specifications that govern, and the ones that do not

This return is specification-driven, and the version in force at the reference period governs — a change to the technical documents changes the file without changing the decree. Three provvedimenti do most of the work:

• 25 January 2016 — the layout and technical specifications in force from 1 January 2016 for both the monthly and the annual communications.
• 23 May 2022 — new technical documents and revised methods and deadlines. It changed the terms for sending the monthly and annual communications, introduced a new representation of the accounting information for certain relationship types, required the currency to be specified where it differs from the UIF codification, and added new relationship types.
• 28 October 2024 — the current set of dispositions on communication of data to the Anagrafe Tributaria by operators under Article 7, sixth paragraph, with the specifications applying from 4 November 2024.

Two habits follow. Pin the specification version to the reference period in build metadata, so a file regenerated in 2027 for a 2025 period is produced against the 2025 rules. And treat currency as a mapping decision rather than a passthrough: the 2022 provvedimento made explicit that the archive’s expectation and the UIF codification are not the same list.

6. The ten-year rule, and what a rejection looks like

Since 1 January 2022 any communication sent under the invio straordinario type that contains Saldi e movimenti records must not carry accounting data for years more than ten years before the year of transmission. The rule implements the maximum retention term for accounting data in Article 11, paragraph 3 of Decree-Law 201/2011.

Enforcement is mechanical: communications containing such information are not acquired by the system, and the rejection is notified with a specific indication in the receipt. From 1 January 2022, records referring to 2011 stopped being accepted. A remediation that reaches back through a portfolio’s whole history will hit a wall it cannot argue with; scope the correction to the years still inside the window rather than retrying the file.

7. The fotografia di consistenza — the feedback loop nobody uses

Once a year the Agenzia sends each financial operator a fotografia di consistenza: a snapshot of everything the Archive holds attributed to that operator at a stated reference date, built from the migration after the tracciato unico went live plus every monthly and annual flow, ordinary or extraordinary, accepted positively by that date. The data reflect flows transmitted and accepted by 30 September of the current year, and the file goes to whoever is the owner of each relationship at the reference date.

It exists so an operator can verify alignment between what it has reported and what its systems hold, identify corrective or integrative actions, manage processing outcomes, and support customers who received a mismatch finding in an ISEE check. The alignment work should be done without delay and in any event when preparing the annual accounting flows — which makes the snapshot an input to the 15 February return, not a report to be filed away.

How you fix what it reveals is prescribed, and getting it wrong is a documented failure mode:

One structural trap sits inside this. Where a reorganisation happens between the snapshot’s reference date and the date it becomes available, the file arrives at the old operator — and the transferring entity must make it promptly available to the acquirer. In an acquisition, the reconciliation file for the book you just bought lands in the seller’s mailbox. Ask for it in the transition-services schedule, not afterwards.

8. Three files, three outcomes

Scenario one — the over-reported month. An EMI entering Italy builds its monthly communication from a nightly extract of all open relationships. Rule: the monthly return is owed in respect of openings and closings within the following month; the full population with balances belongs to the annual return. Action: split the build into an event feed and a population-and-balances feed. Outcome: the monthly file stops restating unchanged relationships, and the two obligations become independently testable.

Scenario two — the snapshot that arrived at the wrong company. A payment institution acquires an Italian portfolio in November. The following year’s ISEE queries generate customer complaints about relationships the acquirer has no record of reporting. Rule: the fotografia goes to the owner at the reference date, and the transferring operator must promptly pass it on. Action: request the snapshot from the seller, reconcile it against the migrated book, and clear gaps with tipo comunicazione 1 / tipologia invio 2 and divergences with tipo comunicazione 2. Outcome: the Archive matches the acquired book before the next 15 February.

Scenario three — the remediation that will not load. A firm discovers a historic gap in balances and prepares an extraordinary send covering every year since the relationship opened. The file is rejected. Rule: since 1 January 2022 an extraordinary send containing Saldi e movimenti records cannot carry accounting data older than ten years before the year of transmission; the file is not acquired and the receipt carries the rejection indication. Action: truncate the correction to the years inside the window, and record the out-of-window years as a documented, unremediable gap rather than an open action. Outcome: the loadable part loads, and the audit trail explains the rest by reference to the retention rule instead of leaving a failed submission on the log.

FAQ

9. What to do, today

• Check which feed your monthly file is built from. If it reads the open-relationship population rather than lifecycle events, it is over-reporting every month and has been since go-live.
• Find last year’s fotografia di consistenza. If nobody can produce it, that is the finding — it is the only independent view of what the Archive believes you hold.
• Pin the specification version to the reference period. The 2016, 2022 and 2024 provvedimenti each changed the file without changing the decree.
• Treat currency as a mapping, not a passthrough. The 2022 provvedimento made the divergence from the UIF codification explicit.
• Scope remediation inside the ten-year window first. A file carrying older accounting records is not acquired at all, so an over-broad correction fixes nothing.
• Put the snapshot into any Italian portfolio transfer agreement. It arrives at the transferring operator, and you need it to reconcile the book you bought.

Related: SID — the Agenzia delle Entrate channel · The Italian reporting calendar · FICOBA in France · The FTF in Spain · CRBA — Luxembourg’s central register of bank accounts · CAI — Centrale di allarme interbancaria · Registro Imprese — the Italian company register