Circolare 217 — supervisory reporting for IP and IMEL

Circolare 217 is the rulebook that turns an Italian payment institution’s or e-money institution’s accounts into the numbers Banca d’Italia expects — and it reaches Italian branches and designated contact points of EU firms too, which is the part passporting teams discover late. It is a compilation manual, not a return: it defines the sections, the items, the attributes and the clocks. This is what it covers, who is in scope, when each section is due, and where the mapping goes wrong.

1. What Circolare 217 is

Circolare n. 217 del 5 agosto 1996 carries the title “Manuale per la compilazione delle Segnalazioni di Vigilanza per gli Intermediari Finanziari, per gli Istituti di pagamento e per gli IMEL” — the manual for compiling supervisory reports for financial intermediaries, payment institutions (istituti di pagamento, IP) and e-money institutions (istituti di moneta elettronica, IMEL). It stands at its 23rd update, of 28 November 2023.

The manual is explicit about the boundary of its own authority. Its rules structure the data flow to Banca d’Italia’s information needs; they therefore do not govern the firm’s chart of accounts, how internal bookkeeping is kept, or how the annual accounts are drawn up. What it does require is that, whatever shape the chart of accounts takes, information is mapped into the reporting items according to the logic of each item — and that the firm holds tooling allowing reconciliation between internal accounting and the data transmitted to Vigilanza. Queries follow the same split: instructions in the manual go to the Divisione Bilanci e segnalazioni, technical instructions for sending data to the Servizio Rilevazioni ed Elaborazioni Statistiche (RES).

2. Who reports under it

The Premessa sets out a wider population than most readers assume: financial intermediaries, pawn-loan agencies, IP and IMEL constituted as companies (“pure”) or as ring-fenced asset pools established by non-financial entities (“non-financial hybrid”) — and then two more categories:

• Italian branches of EU IP or IMEL (succursali insediate in Italia); and
• contact points designated by EU IP and IMEL established in Italy with networks of agents and/or soggetti convenzionati.

Those last two report a subset. They transmit certain items of Section II, subsection 12 “Servizi di pagamento e moneta elettronica”, on the same timing as Italian IP and IMEL. The manual names the items they are relieved of — among them 52503, 52507, 52515, 46436, 46452, 46456, 52240, 58607, 58610, 58672, 58742, 47044 and 58750 through 58780, plus the subitem of 58560 covering money transfer in other countries where the intermediary operates. A branch that builds the full domestic II.12 has over-built; one that builds nothing has misread the scope. Newly established IP and IMEL report from the month they begin operating, not from the first full quarter.

3. The five sections

A report is composed of five informational sections, and each is governed by a different rulebook. That split is the commonest source of build error, because a team treating “Circolare 217” as one specification will find two of the five defined elsewhere.

Inside a section the data runs in descending hierarchy: sezione → sottosezione → voce → sottovoce → attributi informativi. The voce is the base unit; attributes qualify it. Counterparty sector and economic-activity classification comes from a separate fascicle, Circolare 140 of 11 February 1991 — another dependency not in the manual you are reading.

4. The clocks

Reference dates are quarterly — 31 March, 30 June, 30 September, 31 December — with income-statement data half-yearly and year-end data annual. IP and IMEL transmit Sections I, III, IV and V on the same timing as financial intermediaries:

• Sections I and II (excluding half-yearly items and subsection II.13) — by day 25 of the month following the reference date;
• Subsection II.13, historically recorded losses on defaulted positions — by the 25th of the third month following;
• Section III — by the 25th of the third month following for the first-half report (25 September), and by the 5th day of the fourth month after the end of the reference period for the full year (5 April);
• Section V — by the 5th day of the fourth month after the actual close of the financial year;
• Section IV — per Circolare 286, not per this manual.

Two sub-calendars sit inside Section II. Half-yearly items go only at 30 June and 31 December, with postponed deadlines of 25 September and 5 April. A small group of quarterly items — 52427, 52441, 52443, 52445 — goes by the 25th of the third month after the reference date, the 31 December one by 5 April. Within II.12, some items are half-yearly (including the card and e-money fraud items 46442, 46444, 58670, 58675) and others annual (46452, 46456, 46460, 58590, 58607, 58610). Allegato B is the periodicity summary for IP and IMEL, and it is the sheet a reporting calendar should be built from.

5. Worked example — an EU e-money institution opens an Italian branch

Facts: an EU-authorised IMEL passports into Italy, opens a branch in February, and by year-end has issued e-money to Italian residents and signed a network of agents.

Which rules apply: the branch sits inside the Premessa scope as a succursale insediata in Italia of an EU IMEL. Under section 2.3 it does not build the full domestic report: it transmits certain items of Section II subsection 12, with the exclusion list applied, on the Italian IP and IMEL calendar per Allegato B. Because operations began in February, reporting starts from that month rather than the first clean quarter.

What the practitioner does: treats Allegato B plus the section 2.3 exclusion list as the whole specification, and resists the instinct to map Section I. Own-funds reporting is not a Circolare 217 question — Section IV points to Circolare 286, and for a branch of an EU institution the prudential perimeter sits with the home authority. Where distribution runs through agents and a designated contact point replaces a branch, the same II.12 obligation attaches to the contact point.

Outcome: a bounded slice of payment-services and e-money data on the Italian calendar — avoiding two symmetrical errors: building a full Italian return the branch does not owe, and assuming home-state reporting discharges an Italian obligation it does.

6. Subsection II.12 — payment services and e-money

II.12 is where a payments firm’s actual business lands. Payment services as governed by d.lgs. n. 11/2010 may be provided by IP and by IMEL — pure, financial hybrid and non-financial hybrid alike; issuing e-money is reserved to IMEL. The subsection gives standalone visibility to payment accounts and the investments made with the corresponding funds, plus further payment-services data. Financial hybrids also activate the patrimonio destinato/azienda attribute in Sections I and III to separate ring-fenced from company assets; pure and non-financial hybrids report it as non applicabile. The manual’s definitions are worth mapping against product taxonomy rather than assumed:

• Carte di credito settle after the transaction, with debtor counterparties conventionally classified as famiglie consumatrici; carte di debito are usable at ATM and POS and, as a rule by the day after the operation, debit the holder’s account per transaction.
• Money transfer (rimessa di denaro) — the service in which, without opening payment accounts for payer or payee, the provider receives funds from the payer solely to transfer a corresponding amount to the payee or to another provider acting for the payee.
• Conto di pagamento — an account held for one or more payment service users, used to execute payment operations.
• Moneta elettronica — electronically or magnetically stored monetary value, a claim on the issuer, issued to carry out payment operations under art. 1(1)(c) of d.lgs. 11/2010 and accepted by persons other than the issuer.

One geography rule catches acquiring businesses. In acquirer items the territorial split follows where the operation is carried out; in issuer items it follows the state or province of the cardholder. The same transaction lands in two different territorial buckets depending on which side of it the firm reports.

One exclusion is worth settling before a build starts. Activity conducted with strumenti di pagamento a spendibilità limitata — instruments usable only on the issuer’s premises or, under a commercial agreement with the issuer, within a limited network of providers or for a limited range of goods or services — is outside II.12, because it falls outside the payment services rules under art. 2, comma 2, of d.lgs. 11/2010. Related financings are directed elsewhere: to Section I sub-item 46168.17 for limited-network credit cards, and in Sections II and III to “altri finanziamenti” — for example item 52286 “Crediti per altri finanziamenti” — and expressly not to the consumer-credit or credit-card items. Settle the limited-network position in legal, then let the mapping follow it; the reporting team should not decide it by choosing an item code.

7. Worked example — rounding breaks the balance

Facts: a first submission of Section I fails a control — total assets do not equal total liabilities, by a handful of euro.

Which rules apply: amounts are in units of euro, and rounding is prescribed: decimals of 50 cents or less are dropped, above 50 cents round up. Item-by-item rounding can therefore leave a residual, and the manual prescribes the remedy. Where rounding produces a difference in Dati patrimoniali or Dati di conto economico, the squaring is achieved using, respectively, sub-items 52034.06 “altre attività: altre”, 52070.10 “altre passività: altre”, 52470.11 “altri oneri di gestione: altri” and 52512.09 “altri proventi di gestione: altri”.

What the practitioner does — and the outcome: implements the plug as a deterministic, logged final step in the generator rather than letting an analyst nudge a number, so the adjustment reads as a rounding plug in the audit trail. The manual separately expects the firm to use the interval between reference date and transmission date to allocate items left suspended at period end — the other common cause of a return that will not square. Every figure must reflect the position at the reference date even where that date is a holiday.

8. The attestation letter, and who signs it

To attest that reported data corresponds to the company accounts, reporting entities send Banca d’Italia a communication drawn up on the fac-simile at Allegato D, subscribed by four named officers: the chairman of the board, the chairman of the collegio sindacale (or equivalent body), the direttore generale, and the dirigente preposto or chief accountant.

Two mechanics matter. The letter is not an annual filing: it is renewed only where one of those officers ceases to hold office, and must then be delivered within 10 days of the successor’s appointment. And it goes to the territorially competent Filiale or to the Amministrazione Centrale, depending on how supervision of the intermediary is allocated. A firm that replaces its direttore generale in March and files nothing until the annual cycle has already missed a ten-day clock nobody was watching.

FAQ

What to do, today

• Reporting lead: build the calendar from Allegato B, not from the reference dates. The 25th-of-the-month rule, the 25 September and 5 April postponements and the half-yearly and annual items inside II.12 are four separate clocks.
• Branch or contact-point owner: take the section 2.3 exclusion list as your specification and confirm in writing that Sections I, III and V are out of scope.
• Product and legal: settle the limited-network position for every stored-value instrument.
• Engineer: make the rounding plug a deterministic logged step, and clear suspense items between reference date and transmission date.
• Company secretary: wire the Allegato D letter to the officer-appointment process, with a ten-day trigger.

Related: Banca d’Italia Segnalazioni — the reporting matrix · INFOSTAT — the Banca d’Italia reporting channel · Italy reporting calendar for payment institutions · EMI authorisation in Italy