Centrale dei Rischi: Banca d’Italia’s credit register
Two numbers decide whether a client appears in Italy’s credit register: thirty thousand euro, and two hundred and fifty. The Centrale dei Rischi is the credit register Banca d’Italia has run since 1991, and it works as an exchange rather than a filing: participants send in every client position above a threshold each month, and get back those clients’ total indebtedness across the whole Italian financial system. This piece sets out who must participate and who need not, the censimento thresholds, what a monthly return carries, the sofferenza judgement behind most disputes, the 25th-of-the-month clock, and how the return flow works.
1. What the Centrale dei Rischi is
The Centrale dei Rischi (CR) is a database managed by Banca d’Italia holding information on the debts households and businesses owe to the banking and financial system. Participating intermediaries transmit the credits and guarantees they have granted; Banca d’Italia consolidates them and reports back to each participant its own clients’ overall indebtedness, the financing received, and whether payments are regular.
The governing text is Circolare n. 139 dell’11 febbraio 1991, «Centrale dei rischi — Istruzioni per gli intermediari creditizi», whose current version is the 21° aggiornamento of 13 February 2025.
One caveat governs how the output may be used. CR data rest in some cases on conventional criteria of representation and therefore do not certify the indebtedness of the reported subject. A credit file treating a CR position as an audited balance is misreading it.
2. Who must participate — and who is not on the list
Participation in the centralised risk service is compulsory for:
- Banks entered in the register under article 13 of the Testo Unico Bancario — which captures Italian banks and the Italian branches of EU and non-EU banks;
- Financial intermediaries entered in the single register under article 106 TUB;
- Securitisation companies and the assignee companies for the guarantee of bank bonds (covered bond vehicles) under law no. 130 of 30 April 1999;
- Collective investment undertakings (OICR) that invest in credit, under article 8(1) and (1-bis) of the Testo Unico della Finanza;
- Cassa depositi e prestiti.
Italian insurance undertakings and SACE participate under a separate provision. Special purpose vehicles securitising proceeds from real estate and registered movable property under article 7(1)(b-bis) of law 130/1999 do not participate.
Read that list against a payments business and the omission is conspicuous. Italian istituti di pagamento and IMEL are not in it. They are entered in their own registers under the payment-services and e-money provisions of the TUB, not under article 106, and the CR instructions do not extend the obligation to them. Granting credit ancillary to payment services does not make a firm an article 106 intermediary.
Two refinements matter to a cross-border group. Participants also report the exposures of their own foreign branches, but only those assumed toward subjects resident in Italy. And article 106 intermediaries have a route out: they may request exoneration where the share of cash and signature financing reportable to the CR is at or below 20 per cent of the financing they grant — a request, not a self-certification.
3. The censimento thresholds
A return is due where, at the reference date, at least one of the following conditions applies to the holder of the risk position — natural person, legal person, joint holding, or investment fund:
| Condition | Threshold |
|---|---|
| Total cash and signature credit (granted or drawn) | ≥ EUR 30,000 |
| Value of guarantees received by the intermediary in total | ≥ EUR 30,000 |
| Intrinsic value of financial derivative operations | ≥ EUR 30,000 |
| Amount of operations carried out on behalf of third parties | ≥ EUR 30,000 |
| Nominal value of credits acquired through factoring, non-recourse portfolio discount and assignment of credit | ≥ EUR 30,000 |
| Non-sofferenza credits sold to third parties, nominal value | ≥ EUR 30,000 |
| Client position in sofferenza, nominal value net of losses | ≥ EUR 250 |
| Sofferenza credits sold to third parties, net of losses | ≥ EUR 250 |
| A sofferenza position written off entirely to loss (losses ≥ EUR 250) | — |
The asymmetry between EUR 30,000 and EUR 250 is the design’s most consequential feature. Performing exposure is visible only above thirty thousand euro; distress at two hundred and fifty. A book of small performing loans is largely invisible to the CR — until one loan goes to sofferenza, whereupon it appears at once.
Amounts are reported in units of euro, rounded at 50 cents, with foreign currency converted at ECB end-of-period rates. There is an express prohibition on netting (divieto di compensazione): a debit position is not reduced by a credit balance held elsewhere in the relationship.
4. What a monthly return actually contains
Positions are filed into sections, and within a section into categorie di censimento:
- Crediti per cassa — five categories: rischi autoliquidanti, rischi a scadenza, rischi a revoca, finanziamenti a procedura concorsuale e altri finanziamenti particolari, and sofferenze.
- Crediti di firma — two categories: guarantees connected with commercial operations, and with financial operations.
- Garanzie ricevute and derivati finanziari — one category each, plus a sezione informativa for supplementary detail such as pool operations.
The category boundaries are legal, not commercial. Rischi a revoca captures current-account credit openings granted for cash elasticity where the intermediary reserved the right to withdraw irrespective of just cause. Whether a facility is revocable in that sense is a contract question that decides the category.
Each position is then valued across classes of data: accordato, accordato operativo, utilizzato, saldo medio, valore garanzia, importo garantito, valore intrinseco and altri importi. The accordato versus accordato operativo distinction is where firms most often get the file wrong: a facility approved but not yet usable is granted, not operative, and reporting one figure in both overstates available credit system-wide.
5. Sofferenza is a judgement, not a trigger
The sofferenza category carries the entire cash exposure toward a subject in a state of insolvency — even where not judicially established — or in substantially equivalent situations, regardless of loss forecasts and irrespective of any collateral or personal guarantees. Positions whose anomaly is attributable to country risk are excluded.
Two constraints generate most of the disputes. First, entry into sofferenza implies an assessment of the client’s overall financial situation and cannot arise automatically from single events — payment delays, or the debtor’s contestation of the credit, are expressly named as insufficient. A collections workflow that classifies on a days-past-due rule has built a trigger the instructions do not permit. Second, the classification must be univoca across the entities in the reporting perimeter: a group cannot have one subsidiary reporting a client to sofferenza while another reports it as performing.
A customer-facing duty attaches too. Where a consumer is to be reported, prior notice must be given, and the instructions are explicit that it exists to ensure transparency and may not be used to make collection easier or to press the debtor to pay. A notice drafted as a demand letter is a defect in its own right.
6. The monthly clock: the 25th, trascinamento and rettifiche
Monthly returns must reach the Centrale dei Rischi by the 25th day of the month following the reference month, and must be sent even where amounts have not changed.
If returns do not arrive in time to close the processing cycle, Banca d’Italia updates its archives and the flows to intermediaries using the previous month’s data — trascinamento dei dati. Firms misread this as a grace period. It is not: the obligation remains, and meanwhile stale figures about that firm’s clients circulate to every other participant under that firm’s name.
Corrections have their own window. Rettifiche to the accounting date in processing that arrive within 5 calendar days after the 25th are normally included in that month’s return flow; later ones force the CR to update information it has already distributed. Hence the duty to correct erroneous data with the utmost promptness, both on the intermediary’s own initiative and in response to communications from the register.
Alongside the monthly cycle sit the rilevazioni inframensili — intra-month reporting — for changes in a client’s status and for regularisations of payments and the clearing of persistent overruns under article 8-bis of decree-law 70/2011. Status changes do not wait for month-end.
Enforcement is real: where an intermediary fails to act within the prescribed term, Banca d’Italia proceeds on its own initiative the day after expiry and starts the sanctions procedure under article 144 TUB (article 190 TUF for OICR).
7. What comes back: flusso di ritorno and prima informazione
Participants receive, monthly, a personalised return flow (flusso di ritorno personalizzato) carrying registry data and the global risk position toward the financial system of each client they reported, together with joint holders and connected subjects. This is the consideration for participating: a lender sees the borrower’s total exposure across every participant, not merely its own. Participants can also request a prima informazione — a first-information enquiry — usable both when monitoring an exposure and at the point of granting financing or guarantees.
Use of the data is bounded. Intermediaries retain full autonomy, and full responsibility, for the judgement on a borrower’s economic capacity; the register informs it and does not substitute for it. Reported individuals may obtain their own CR data from Banca d’Italia free of charge.
8. Three scenarios where the register bites
The EU bank that opened an Italian branch. A bank passports into Italy, assuming its home credit register covers the group. Facts to rule: the article 13 TUB obligation extends to the Italian branches of EU and non-EU banks. What the reporting owner does: stand up a CR participation for the branch — noting the mirror rule, that an Italian participant’s foreign branches report only their Italian-resident clients.
The specialist lender that filed nothing for a quiet month. An article 106 intermediary has no movement and skips the monthly file. Facts to rule: returns are due by the 25th even where amounts are unchanged, and a missing file triggers trascinamento rather than silence. What the analyst does: file the unchanged return, then run the 20 per cent test — exoneration may be available instead of a monthly cycle the firm barely uses.
The consumer classified to sofferenza on a days-past-due rule. A collections platform classifies automatically at a fixed arrears count, and the customer notice is the standard demand letter. Facts to rule: sofferenza requires an assessment of the overall financial situation and cannot arise automatically from payment delays; the notice may not be used to press for payment. What the compliance officer does: replace the trigger with a documented assessment, separate the CR notice from the collections letter, and check consistency across the perimeter.
What is the Centrale dei Rischi reporting threshold?
EUR 30,000 for total cash and signature credit granted or drawn, for guarantees received, for the intrinsic value of financial derivatives, for operations on behalf of third parties and for credits acquired through factoring or assignment. It falls to EUR 250 where the position is in sofferenza, at nominal value net of losses.
Do Italian payment institutions and IMEL report to the Centrale dei Rischi?
Not as a rule. Compulsory participation covers banks under article 13 TUB, financial intermediaries under article 106 TUB, securitisation and covered-bond companies under law 130/1999, credit-investing OICR under article 8 TUF, and Cassa depositi e prestiti. Payment and e-money institutions are not on that list.
When are monthly returns due?
By the 25th day of the month following the reference month, even if amounts have not changed. Corrections arriving within 5 calendar days after the 25th are normally picked up in that month’s return flow.
What happens if a return is late?
Banca d’Italia carries forward the previous month’s data (trascinamento), so the flows to other participants still update — with stale figures. The filing obligation is unaffected, and persistent failure engages the sanctions regime under article 144 TUB.
Can a firm be exempted from participating?
Financial intermediaries registered under article 106 TUB may request exoneration where the share of cash and signature financing reportable to the CR is 20 per cent or less of the financing they grant. It is a request to Banca d’Italia, not a self-assessment.
Can a client be classified to sofferenza automatically after missed payments?
No. Sofferenza requires an assessment of the client’s overall financial situation, and the instructions state expressly that it cannot arise automatically from single events such as payment delays or the debtor’s contestation of the credit. The classification must also be consistent across all entities in the reporting perimeter.
9. What to do, today
- Establish which register you are in — article 13 TUB, article 106 TUB, law 130/1999, article 8 TUF — because that, not your lending volume, decides whether you participate at all.
- If you run an Italian branch of an EU or non-EU bank, confirm the branch has its own CR participation rather than assuming home-country coverage.
- Encode both thresholds separately: EUR 30,000 for performing exposure, EUR 250 for sofferenza. A single threshold constant is a defect.
- Separate accordato from accordato operativo, and check no facility reports the same figure in both.
- Make the monthly file unconditional, and set the correction cut-off five calendar days after the 25th as its own calendar event.
- Audit the sofferenza path for automatic triggers, confirm the assessment is documented and consistent across group entities, and check the consumer notice reads as transparency rather than demand.
- If you are an article 106 intermediary with a mostly sub-threshold book, run the 20 per cent test and consider requesting exoneration.
Related: CIRBE — the Spanish credit register · AnaCredit across national central banks · Banca d’Italia segnalazioni · The Anagrafe dei Rapporti Finanziari
