PI licence in Italy — Istituto di Pagamento at Banca d’Italia
An Istituto di Pagamento (IP) authorisation at Banca d’Italia covers PSD2 payment services without e-money issuance. The legal framework is Decreto Legislativo 11/2010, which transposed PSD2 into Italian law, supplemented by the Testo Unico Bancario and Banca d’Italia’s Disposizioni di vigilanza. The capital floors are lower than for an IMEL, the dossier structure overlaps heavily, and the post-grant reporting catalogue is broadly the same. What actually differs is scope: which of the eight PSD2 services you select, and everything that selection drags with it — capital, safeguarding, insurance, agent oversight. This piece walks through the regime section by section, with three worked examples showing how the service selection plays out in practice.
1. Who grants and who supervises
Banca d’Italia is the competent authority: it receives the application, runs the review, grants the authorisation and supervises the IP on an ongoing basis — prudential, conduct and AML-preventive. Financial-intelligence work sits with the UIF, which receives suspicious-transaction reports once the firm is live. Where the IP’s account-information or payment-initiation services touch investment products, CONSOB interfaces additionally on the securities side. For a pure payments business, Banca d’Italia is the counterpart for essentially everything from pre-application to inspection.
2. Legal basis
- Directive (EU) 2015/2366 (PSD2) — the EU framework
- Decreto Legislativo n. 11 del 27 gennaio 2010 — the Italian implementation
- Testo Unico Bancario (TUB), Articles 114-quinquies and following — the licensing architecture
- Banca d’Italia Disposizioni di vigilanza per gli Istituti di Pagamento — the supervisory rulebook
- EBA Guidelines on authorisation under PSD2 — which shape what a complete dossier looks like
3. The eight PSD2 services in Italian law
- Deposito di contante su un conto di pagamento e operazioni di gestione
- Prelievo di contante da un conto di pagamento e operazioni di gestione
- Esecuzione di operazioni di pagamento (bonifici, addebiti diretti, pagamenti con carta)
- Esecuzione di operazioni di pagamento coperte da linea di credito
- Emissione di strumenti di pagamento o acquisizione di operazioni di pagamento
- Rimessa di denaro
- Servizi di disposizione di ordini di pagamento (PIS)
- Servizi di informazione sui conti (AIS)
The selection is not cosmetic. It fixes the initial-capital floor, decides whether safeguarding applies (it does wherever the IP holds customer funds), determines whether professional indemnity insurance is required (PIS and AIS), and frames the AML risk assessment Banca d’Italia will run against the business model.
4. Capital floors and ongoing own funds
| Service selection | Initial capital | Notes |
|---|---|---|
| Service 6 only (rimessa di denaro) | €20,000 | Money remittance without payment accounts |
| Service 7 (PIS) | €50,000 | Plus professional indemnity insurance |
| Services 1–5 | €125,000 | Full account-servicing scope |
| Service 8 only (AIS) | No capital floor | Registration regime, insurance still required |
Ongoing own funds must be the higher of the initial floor and the result of one of the three calculation methods in PSD2 — Method A (fixed overheads), Method B (payment volume) or Method C (scaled indicator). Banca d’Italia scrutinises the chosen method and expects the business plan to demonstrate headroom across the three-year projection, not a balance that scrapes the floor in month one.
5. AIS — the registration regime
An AIS-only provider registers with Banca d’Italia rather than seeking full authorisation. There is no initial-capital floor; professional indemnity insurance covering the account-information activity takes its place, and conduct, ICT and AML obligations remain in force. The registration is published in Banca d’Italia’s elenco. The regime is lighter but not light: the dedicated-interface access mechanics, customer-consent management and incident-reporting expectations are the same ones full IPs face for Service 8.
6. What goes in the dossier
The file mirrors the IMEL dossier — see the IMEL piece for the section-by-section walkthrough. The IP-specific differences:
- Programma di attività anchored to the Services 1–8 selection, with the customer journey per service
- Safeguarding under D.Lgs 11/2010 — functionally equivalent to the e-money safeguarding regime but PSD2-specific, applying wherever customer funds are held
- PIS-specific documentation where Service 7 is offered — SCA exemption position, dedicated-interface compliance, professional indemnity insurance
- AIS-specific documentation where Service 8 is offered — access-to-account mechanism, customer-consent management
- Italian-language requirement — the dossier is filed in Italian, which drives translation lead time for group policies drafted in English
7. Worked example — money remitter
Facts: a start-up plans corridor remittances from Italy to two non-EU countries. Customers hand over cash or pay by card; the firm pays out abroad through partner networks. No payment accounts are opened; funds are in transit only. Projected first-year volume is modest.
What the rule says: this is Service 6, rimessa di denaro, with a €20,000 initial-capital floor. Ongoing own funds are the higher of that floor and the output of the chosen PSD2 method — for a remitter, Method B on payment volume is the natural fit. Because funds are held, however briefly, safeguarding applies while they are in the firm’s hands. The cash-intensive, cross-border model places the firm in a higher AML risk band from day one.
What the practitioner does: applies for Service 6 only, resists the temptation to add account services “for later”, and over-invests in the AML sections of the dossier — corridor risk assessment, agent controls, transaction-monitoring scenarios. For a remitter the licensing bottleneck is almost never capital; it is convincing Banca d’Italia the AML framework matches the inherent risk of the corridors.
8. Worked example — PIS + AIS fintech
Facts: a software company offers account aggregation to retail users and payment initiation to e-commerce merchants. It never holds customer funds. It wants the fastest viable route to market in Italy.
What the rule says: Service 8 alone would allow the registration regime — no capital floor, insurance instead. Adding Service 7 (PIS) converts the case into a full authorisation with a €50,000 floor plus professional indemnity insurance covering the initiation activity. Because no funds are held, safeguarding falls away entirely — but the dedicated-interface, SCA and consent-management documentation must stand up for both services.
What the practitioner does: checks whether the merchant proposition genuinely needs initiation at launch. If aggregation alone validates the product, registering as AIS-only gets the firm live sooner, and Service 7 can be added through a licence-extension application once the merchant pipeline is real. If initiation is the core revenue line, the firm files for both at once — running two sequential procedures costs more than one combined file.
9. Worked example — full-scope IP with agents
Facts: an applicant plans payment accounts with transfers and card issuance (Services 1–3 and 5), distributed partly through a physical agent network across Italian regions.
What the rule says: the €125,000 floor applies. Agents operating in Italy must be registered with the Organismo degli Agenti e dei Mediatori (OAM) — see our OAM piece — independently of the IP authorisation, and the IP remains responsible for supervising them under D.Lgs 11/2010 and the Disposizioni. Safeguarding covers all customer balances on the payment accounts.
What the practitioner does: builds the agent-oversight framework into the original dossier rather than bolting it on: onboarding due diligence, AML training, mystery-shopping, termination triggers. Agent misconduct is a recurring Banca d’Italia inspection theme, and an application that treats the network as an afterthought invites a feedback round.
10. Realistic timing
The statutory review clock runs from a complete dossier — six months in the Italian framework. In practice, completeness is where time is won or lost: pre-application meetings with Banca d’Italia are routine and worth doing, and each feedback round on an incomplete file adds weeks. End-to-end, a first-time applicant should plan for nine to twelve months from kick-off to grant.
11. What switches on at grant
- Banca d’Italia Segnalazioni — the prudential and statistical reporting cycle
- UIF AML reporting plus the AUA daily archive
- CESOP reporting where cross-border payments are in scope
- IPR statistical report
- Conduct and complaints handling through the ABF framework
- Passporting notifications to host states where the IP operates cross-border
12. FAQ
Should I apply for an IP or an IMEL?
If the business model involves issuing electronic money (stored-value accounts) — IMEL. If purely payment services — IP. The choice is not reversible without re-licensing, so map the three-year roadmap before filing.
Can an IP issue Italian IBANs?
Yes, where the licence covers account servicing or the issuing/acquiring service. See our Italian IBANs piece.
How does the AIS lite regime work?
Service 8 only: registration rather than full authorisation with Banca d’Italia, no capital floor, professional indemnity insurance instead. Conduct, ICT and AML obligations remain in full.
Do IPs need to register agents with OAM?
Where the IP operates through agents in Italy, yes. The OAM register is separate from the IP authorisation, and the IP supervises its agents under D.Lgs 11/2010.
What changes under PSD3 / PSR?
The proposed merger of the EMI and PI categories will reshape this regime. Existing IP authorisations are expected to be grandfathered with transitional provisions. Track the PSD3 / PSR file.
Can I sponsor smaller payment firms as a banking-as-a-service partner?
The Italian market has such relationships. The contractual allocation of AML obligations between the parties is a recurring Banca d’Italia inspection focus — document it precisely.
13. What to do, today
- Founders: choose the PSD2 services against the actual roadmap — the selection drives capital, safeguarding, insurance and AML scope.
- Programme leads: engage Banca d’Italia early; pre-application meetings are routine and shorten feedback rounds.
- AIS-only businesses: plan against the lighter registration regime and get the indemnity insurance quoted early.
- Distribution owners: coordinate with OAM if agents are part of the model, and write the oversight framework into the dossier.
- COOs: build the post-grant reporting stack in parallel with the application.
Related: IMEL licence in Italy · OAM register · PSD3 tracker
