CRS reporting in Italy: Agenzia Entrate, SID, 30 June

CRS reporting in Italy goes to the Agenzia delle Entrate once a year, through SID, and Italian law names e-money institutions and payment institutions on the list of reporting financial institutions. Being listed is not the whole test, Italian branches of EEA firms are caught too, the e-money rules changed from 2026, and the deadline in the original 2015 decree no longer applies.

1. The legal stack

• Legge 18 giugno 2015, n. 95. It ratifies the Italy–US FATCA agreement signed in Rome on 10 January 2014 and sets out the duties of Italian financial institutions for automatic exchange, both with the US and under agreements with other states.
• Decreto MEF 28 dicembre 2015 (Gazzetta Ufficiale n. 303 of 31 December 2015). It implements Law 95/2015 and DAC2 (Directive 2014/107/EU): definitions in Article 1, due diligence in Article 2, reporting in Article 3. It has applied since 1 January 2016.
• Decreto MEF 6 agosto 2015. The FATCA counterpart, implementing the Model 1 agreement.
• Provvedimento of 4 July 2017, prot. n. 125650. The Agenzia’s implementing rules for CRS/DAC2: how files are compiled and transmitted. For FATCA, the base provvedimento is that of 7 August 2015, prot. n. 2015/106541.
• Decreto MEF 30 dicembre 2025. It amends the 2015 CRS decree to transpose Directive (EU) 2023/2226 (DAC8) and Directive (EU) 2025/872, from 1 January 2026.

2. Are IP and IMEL reporting financial institutions?

Article 1(1)(n) of the CRS decree lists the Italian financial institutions required to report. Item 9 is e-money institutions and payment institutions under Articles 114-bis and 114-sexies of the TUB. That looks conclusive, but the opening words of letter (n) cover only those listed entities that also meet the definition of a financial institution in letter (e). Letter (e) means a custodial institution, a depository institution, an investment entity or a specified insurance company.

For a payments firm, the test that matters is the depository institution test. Until 2025 the decree defined a depository institution as an entity that accepts deposits in the ordinary course of a banking or similar business. Named e-money balances were usually analysed under it; a payment institution that only executes transfers might not be.

• Branches. Item 13 covers Italian permanent establishments of foreign financial institutions carrying on the same activities as the listed institutions. Letter (m) likewise includes Italian branches of non-resident institutions and excludes foreign branches of Italian ones.

The FATCA decree of 6 August 2015 has a parallel list covering the same institutions and branches.

3. The deadline is 30 June

As published in 2015, Article 3(6) of the CRS decree set 30 April of each year for information on the previous calendar year. A ministerial decree of 20 June 2019 (Gazzetta Ufficiale n. 159 of 9 July 2019) changed that to 30 June. It made the same change to Article 5(4) of the FATCA decree. The Agenzia’s current CRS FAQ confirms the ordinary deadline as 30 June of the year after the reporting period, and gives the example of 2024 data due by 30 June 2025.

Earlier one-off dates (20 June 2019 for 2018 data; a COVID-19 deferral by decree of 22 July 2020 for 2019 data) do not repeat.

After the filing, the Agenzia must pass information on residents of each reportable jurisdiction to that jurisdiction’s competent authority by 30 September (Article 3(7)). The technical instructions allow a grace period of 30 days after the deadline. A first filing of new data inside those 30 days gets a lateness flag on the receipt, but it is still sent in the initial exchange. After the 30th day it is still accepted but goes in a later exchange.

4. Channel and file: SID, REI and CrsXML v2.0

CRS and FATCA files go to the Agenzia through SID, the Sistema di Interscambio Flussi Dati. Before the first filing, the Agenzia’s CRS/DAC2 instructions (version 2.3, 28 April 2025) require three things:

1. REI FATCA/CRS. Register the institution’s certified email (PEC) address in the dedicated section of the Registro Elettronico degli Indirizzi, under provvedimento prot. n. 90677 of 10 May 2017. This is where the Agenzia sends administrative communications.
2. SID registration. To register, you must already be enrolled in Entratel or Fisconline. An institution that will file through an intermediary must say that it is using an interchange node.
3. Certificate and software. Registration provides the certificate used, through the Agenzia’s “SID Gestione Flussi CRSDAC2” software, to sign and encrypt the file.

The file follows the OECD CrsXML schema, version 2.0. Version 2.3 of the instructions left the schema unchanged. Large filings may be split into ordered batches; the instructions cite 120,000 AccountReport records as an indicative threshold. The Agenzia’s client software checks the file against the XSD before sending. On receipt, the Agenzia either accepts the whole file or rejects the whole file with a ricevuta di scarto. A rejected file counts as not received.

The MessageTypeIndic values decide what a file does. CRS701 carries new data, CRS702 carries corrections and CRS703 says there is nothing to report. Wait for each receipt before the next send, and never reuse a MessageRefId or DocRefId.

5. What changed for e-money from 2026

DAC8 brought the OECD’s 2023 amendments to the CRS into EU law. Alongside the crypto-asset regime in d.lgs. 10 dicembre 2025, n. 194, Italy transposed those amendments through the decreto MEF of 30 December 2025. Article 7 makes it apply from 1 January 2026. For payment and e-money firms, Article 2 is the key provision:

• Depository institution now also covers any entity that holds e-money or central bank digital currency for customers, not only entities that accept deposits.
• Depository account now includes an account or notional account representing e-money held for a customer.
• E-money gets its own definition built on five elements: a digital representation of a single fiat currency, issued on receipt of funds to make payment transactions, a claim on the issuer, accepted by others, and redeemable at par on demand. A product created only to facilitate a transfer is excluded, unless funds are ordinarily held more than sixty days.
• A new excluded account (Article 1(2)(ee)(5-bis)) removes a depository account representing all the e-money held for a customer if, on no day of the year, the 90-day rolling average of its aggregate end-of-day balance exceeded the euro equivalent of USD 10,000.
• Transition dates. An account that becomes a financial account only because of these changes is pre-existing if it was held on 31 December 2025, and new if it was opened from 1 January 2026.

Article 3 adds new data points to the return: whether a valid self-certification was obtained, the account type, whether the account is pre-existing or new, whether it is joint and how many holders it has, and each controlling person’s role. Article 7(2) gives some relief for the 2026 and 2027 reporting years: for accounts that already existed on 31 December 2025, the role of controlling persons need not be reported if the institution does not hold it. The first return under the new rules covers 2026 and is due by 30 June 2027.

The Agenzia’s technical-documents page still lists the CrsXML v2.0 schema and version 2.3 of the instructions. Expect a new specification; watch that page from early 2027.

6. Nil returns, corrections and penalties

Italy requires a nil return. An institution that finds no reportable accounts after due diligence must send a Comunicazione di assenza di dati da comunicare (CRS703) by the deadline. The same message, sent within 30 days after the deadline, cancels any earlier on-time filings without replacing them. For an institution that already filed new data, the instructions bar a CRS703 after that 30-day window.

Corrections after the deadline go through CRS702 at the level of the individual DocRefId. For wrong residence countries found late, the Agenzia’s FAQ says to cancel the records with a CRS702 first, then send the correct countries in a late supplementary filing.

Penalties sit in Article 9 of Law 95/2015. It applies to omitted, incomplete or inaccurate reporting the administrative penalty that Article 10(1-bis) of d.lgs. 471/1997 sets for financial operators, and that penalty also covers breaches of the institutions’ obligations under Article 5. Check the amount in the current text of d.lgs. 471/1997.

7. CRS, the Archivio dei rapporti and SID

For an Italian branch, CRS is the second annual SID flow, not the first. The annual return to the Archivio dei rapporti finanziari uses the same infrastructure on an earlier timetable. It covers every relationship; CRS covers only holders resident in reportable jurisdictions.

The two returns share data, so they should share a build. The Agenzia publishes a correlation table that maps Archivio relationship codes to FATCA and CRS amounts. The SID accreditation steps (Entratel, SID registration, certificate, node choice) are done once and serve both returns.

8. Worked examples

A. An EEA e-money institution’s Italian branch.

Facts: an e-money institution authorised in another member state runs an Italian branch that offers named e-wallets with IBANs to Italian-resident customers. About 3% of customers have a second tax residence in another EU state.

What the rule says: under letter (m) and item 13 of Article 1(1)(n), the branch is an Italian reporting financial institution. Its wallet balances fall within the depository account definition, which since 2026 expressly includes accounts representing e-money held for a customer.

What the practitioner does: registers the branch’s PEC in REI FATCA/CRS, completes SID accreditation under the branch’s Italian tax code, and builds the CRS file from the same ledger as the Archivio return. Agrees with the home-state reporting team which accounts sit with the branch, so that no account is reported twice and none is missed.

Outcome: one Italian CRS file by 30 June, reconciled with both.

B. Small balances after 1 January 2026.

Facts: an Italian e-money institution has 200,000 wallets, mostly under EUR 500, plus a few hundred large business wallets.

What the rule says: a depository account that represents all the e-money held for a customer is excluded if its 90-day rolling average of aggregate end-of-day balance did not exceed the euro equivalent of USD 10,000 on any day of the year. Wallets held on 31 December 2025 that are in scope only because of the new rules are pre-existing accounts.

What the practitioner does: builds the 90-day rolling-average test into the daily balance job and aggregates all of a customer’s e-money accounts. Runs pre-existing account due diligence on the large wallets that existed on 31 December 2025.

Outcome: most wallets stay excluded, with a daily test result to show the Agenzia.

C. A branch that finds no reportable accounts.

Facts: a payment institution’s Italian branch serves only Italian-resident sole traders. Due diligence finds no reportable account holder.

What the rule says: an Italian reporting institution with nothing to report must send a CRS703 nil communication by the deadline.

What the practitioner does: documents the classification and the due diligence result, and files the CRS703 through SID before 30 June.

Outcome: the branch is on record as compliant. Without the nil return, it looks the same as a firm that never filed.

9. FAQ

10. What to do, today

• Head of reporting: change the CRS and FATCA dates in the calendar to 30 June if they still say 30 April.
• COO: confirm that each Italian entity and branch has REI FATCA/CRS registration, SID access, a valid certificate and a second trained user.
• Tax / compliance: write a letter (e) classification memo for each entity and each branch, and update it for the 2026 e-money definitions.
• Data: build the 90-day USD 10,000 rolling-average test and the new data points (self-certification flag, account type, joint holders, controlling-person role) before the 2026 year-end close.
• MLRO: line up onboarding self-certification with the AML/KYC refresh cycle. The amended decree now ties TIN outreach to AML/KYC updates.

Related: CRS for EMIs · SID, the Agenzia delle Entrate channel · Modelo 289, Spain’s CRS return · CRS reporting compared across six EU states · CRS reporting in Ireland (Revenue, ROS)