Direct Reporting: Banca d’Italia external-sector returns

Italy does not ask every firm for its external-sector data. It picks a sample, writes to them, and gives each one a profile. Direct Reporting — rilevazione diretta presso gli operatori economici, DR for short — is how Banca d’Italia collects the information behind Italy’s balance of payments and international investment position directly from resident firms rather than from the banks that move their money. It runs on four questionnaires, five reporting profiles, a six-digit reporting code and an online platform that refuses paper. This piece sets out the legal basis and the sanction, the four surveys, how a firm learns it is in scope, the nil-return rule that catches first-time reporters, and where a payment institution actually sits.

1. What Direct Reporting is

Banca d’Italia collects, compiles and publishes the statistics on Italy’s balance of payments and international investment position, and contributes to the equivalent EU and euro-area aggregates. Direct Reporting is the part of that job done by asking resident firms directly about the economic and financial relationships they maintain with abroad.

The design choice explains everything downstream. A payment-based collection sees only what a resident intermediary executed. A direct collection sees the transaction wherever it settled — inside a group, or through an account held abroad — but only for the firms it asks. Italy therefore runs a sample, and being outside it is a real and common state rather than a compliance failure.

The obligation is statistical, not supervisory. It does not come from the Testo Unico Bancario. It comes from article 11(1) of legislative decree no. 195 of 19 November 2008, together with EU and European System of Central Banks provisions, and the documentation lives in a dedicated section of the Banca d’Italia statistics site.

2. The sanction is specific, and modest by design

Statistical reporting under Direct Reporting is compulsory. Failure to observe the obligations is punished with an administrative pecuniary sanction of from EUR 500 to EUR 10,000 under article 11 of legislative decree 195/2008.

That range is small enough that firms treat it as a rounding error, which is a mistake for two reasons. It is per breach, and a monthly survey generates twelve opportunities a year. And Banca d’Italia has formalised how such breaches are handled: a provvedimento of 11 November 2025 sets out the sanctioning procedures for non-observance of statistical reporting obligations, framed against the ECB’s statistical sanctions regime.

3. Four surveys, and what each one carries

A survey is identified by a three-character code. There are four, and the reference period differs: EMF and OMF are monthly, TTN quarterly, and CAF a stock at the last day of the reference year.

Three sections are identical across all four questionnaires: A (company registry data), B (morphological and balance-sheet data) and C (contacts), differing only in their reporting codes. Useful in practice: those three can be templated once and reused, and only the economic sections change.

4. You report what your profile says, not what your business does

To match the request to a firm’s statistical significance, the surveys are distributed across five reporting profiles, each a five-character code:

• NFI01 — TTN only
• FIN01 — EMF, OMF and CAF
• FIN03 — EMF and CAF
• MIS01 — TTN, EMF, OMF and CAF
• MIS03 — TTN, EMF and CAF

Each reporter is assigned one profile, communicated in writing, and the profile determines the set of surveys owed. The naming is a hint rather than a rule — NFI for a non-financial pattern, FIN for a financial one, MIS for a mixed one — but the assignment is Banca d’Italia’s, and a firm cannot infer its profile from its ATECO code or licence type.

Two related concepts arrive in the same letter. The codice segnalante (or codice partner) is a six-digit number identifying the reporter uniquely across every survey. The edizione is the span over which the surveys run, named for the year in which most deadlines fall — so participation is scoped to an edition, and the letter states which one applies.

5. How a firm gets into the sample

A segnalante is a resident firm selected by sampling technique which, by specific written communication from Banca d’Italia, has been called on to supply the information covered by the surveys, for relationships in which the firm itself is involved on its own account. Communication of inclusion is sent with reasonable advance notice before the surveys start.

Residence follows economic interest, not incorporation: a person is resident where their centre of economic interests is situated, predominantly and stably for at least a year. Branches of foreign firms located in Italy are resident in Italy if their centre of economic interests is there; branches of Italian firms abroad are non-resident. For a group operating through an Italian branch rather than a subsidiary, that is the line that decides whether Italy can ask at all.

Exit is a form, not a conversation. A reporter can request exclusion on inactivity — merger, liquidation, cessation, total demerger, total transfer of assets, extraordinary wage-guarantee arrangements — or on insolvency proceedings such as extraordinary administration, concordato preventivo, bankruptcy or compulsory administrative liquidation. The request goes on the Mod. CE form from the Direct Reporting section of the Banca d’Italia site, emailed to the DR statistics mailbox with «DR – invio modulo CE» in the subject line.

6. The nil return, which is where first-timers fail

For TTN, OMF and CAF, a reporter with nothing to report for a reference period must still produce a segnalazione nulla — a nil return — by the deadline. A nil return covers exactly one survey and one period, so where the absence of activity persists, it must be repeated at every deadline. There is no standing declaration.

EMF is the exception. The compilation instructions specify the cases in which an EMF return is due; where those cases do not arise, nothing at all is owed — no submission, no communication, no nil return. A firm on the FIN03 profile therefore has two different silences to manage: an active nil return for CAF, and a genuine absence for EMF.

Nil returns can be produced in a simplified way, directly through the DR section of the Banca d’Italia site, as well as through the standard software route — so a nil period does not require the full questionnaire pipeline to be exercised.

7. Submission mechanics

The questionnaires cannot be used on paper for submission. Data are compiled electronically through the INFOSTAT data-collection environment at the DR endpoint, using the PSDR-Web online data-entry application. Alternatively a reporter can produce the submission with the downloadable PSDR compilation software (Produzione Segnalazioni Direct Reporting), or with its own software built to the published technical specifications.

Inside PSDR-Web the reporter works from a calendar of deadlines showing the state of each questionnaire — expected, sent, compiled, expired or reopened — selects one, and completes data entry. Submission is an explicit act: the operator activates Consegna, and the system returns a protocol number by email. Corrections work by reopening the questionnaire in edit mode and resubmitting; the resubmission completely replaces the previous one rather than amending it. Where Banca d’Italia raises findings (rilievi), the reporter can confirm the data through a dedicated Conferme function with an explanatory note, or resubmit with corrections.

Underneath the screens is a coding system a firm building its own software has to understand. Each elementary field is identified by a 15-digit codice segnalazione plus a six-character codice variabile beginning with V. The first four digits identify the survey: 3220 = EMF, 3240 = TTN, 3250 = CAF, 3260 = OMF. The fifth digit is 1 for the registry sections A, B and C and 0 for the economic sections; the next five are constant zeros; the last five identify the phenomenon within a section. Alongside sit the schemi matriciali, which set the file layout for import into PSDR, and fifteen code lists — ATECO activity codes, institutional sectors, countries, currencies, and a dedicated list for special purpose entities.

8. Where a payment institution actually sits

The Direct Reporting manual states in its subtitle that it contains provisions relating to resident firms, and the population it describes is drawn from non-financial and insurance firms. Financial intermediaries are collected differently: Italian istituti di pagamento and IMEL report through the statistical and supervisory framework whose compilation manual is Circolare no. 217 of 5 August 1996, with transmission schemes under Circolare no. 154 of 22 November 1991, submitted through INFOSTAT.

So a payments firm reaching for Direct Reporting is usually reaching for the wrong instrument — but not always, and the distinguishing fact is the written communication. If a letter naming a codice segnalante and a profile has arrived, the firm is in the sample and the profile governs, whatever its licence says. If none has, the obligation to look at is Circolare 217.

Three cases show how this plays out. The Italian branch that assumed the parent reported. An EU group operates in Italy through a branch and assumes external-sector data flows up to the parent’s home reporting. Facts to rule: a branch located in Italy is resident in Italy where its centre of economic interests is there, so Italy can sample it in its own right. What the reporting owner does: check whether a written communication reached the branch’s legal representative, and treat its absence as unconfirmed rather than as exemption. The quarterly-only firm that skipped two nil returns. A firm on NFI01 has no cross-border service transactions for two quarters and files nothing. Facts to rule: TTN requires a nil return at every deadline. What the analyst does: file the simplified nil returns for the open periods, and make it a recurring calendar task rather than one triggered by activity. The reporter that amended one figure. A firm resubmits a questionnaire containing only a corrected line. Facts to rule: a resubmission completely replaces the previous submission. What the team does: rebuild and resubmit the full questionnaire, or use Conferme with a note where the original figure was in fact right.

9. What to do, today

• Check whether a written communication has reached the legal representative; if the answer is unknown, treat it as unknown rather than as exemption.
• Read the profile code off the letter — NFI01, FIN01, FIN03, MIS01 or MIS03 — and derive the survey set from it, not from the licence or the ATECO code.
• Record the six-digit codice segnalante and the edition where the reporting team can find them; both recur in every later communication.
• Put nil returns in the calendar as recurring tasks for TTN, OMF and CAF, and note that EMF works the opposite way.
• Use the PSDR-Web deadline calendar as the authority for each period’s date, and keep the emailed protocol number as proof of delivery.
• Before correcting anything, decide whether the answer is a full resubmission or a Conferme note — different acts, different consequences.
• If building your own software, work from the schemi matriciali and code lists rather than the questionnaire PDFs, and encode the 3220/3240/3250/3260 prefixes explicitly.
• For an Italian payment institution or IMEL with no designation letter, scope Circolare 217 instead — a shared INFOSTAT platform is not a shared obligation.

Related: External-sector reporting compared across the EU · The INFOSTAT reporting channel · Banca d’Italia segnalazioni — supervisory reporting · The Italian EMI licence