Banca d'Italia authorises both, under the Testo Unico Bancario
What we do
We support non-resident founders applying to Banca d'Italia for authorisation as a payment institution (istituto di pagamento) or an e-money institution (istituto di moneta elettronica, the IMEL, which the market also calls an EMI). The company has to exist first: company registration in Italy. Pricing on request.
Category and tier assessment
Which of the eight payment services the business model actually needs, whether IP or IMEL is the correct category, and which capital tier follows from that answer.
Form and seat check
Whether the S.p.A., S.a.p.a., S.r.l. or cooperative is in place, and whether the Italy-based registered office and general management condition is already met.
The Banca d'Italia file
The atto costitutivo, the statuto, the programme of activity, the organisational-structure report, and the PIS or AIS insurance evidence where it applies.
After the decision
Registration in the albo, adherence to the ABF, the notice of the start of operations, and protecting the registered name through national UIBM filing or an EU trade mark.
Payment institution or e-money institution
The first decision is which of the two categories the business model falls into, and e-money issuance is the dividing line. Banca d'Italia grants both under the Testo Unico Bancario (TUB), implementing PSD2 and EMD2.
EMI, IMEL and e-money institution all name the second category; "payment institution license Italy" is the American spelling of the first.
| Point | Payment institution (IP) | E-money institution (IMEL) |
|---|---|---|
| What it is | An undertaking other than a bank or an e-money institution, authorised for one or more of the payment services listed at Art. 1(2)(h-septies.1) TUB (Banca d'Italia: Istituti di pagamento) | An undertaking other than a bank, authorised to issue electronic money (Banca d'Italia: Istituti di moneta elettronica) |
| May issue e-money | No. Issuance is reserved to banks and IMELs | Yes |
| Payment services | The one or more it is authorised for | The full range, even unconnected with e-money issuance |
| Initial paid-up capital | EUR 125,000 (services 1 to 5), EUR 20,000 (money remittance only), EUR 50,000 (payment initiation only) | Not less than EUR 350,000, with no lower service-based tier |
| Legal form | S.p.A., S.a.p.a., S.r.l. or cooperative | The same four forms |
| Office and management | Registered office and general management in Italy, where part of the activity is carried on | In Italy, on the same condition |
| Register once authorised | Albo of payment institutions, Art. 114-septies TUB | Albo of e-money institutions, Art. 114-quater TUB |
| Also permitted | Operating payment systems, guaranteeing execution, foreign exchange, custody, recording and processing of data closely connected with its payment services, financing tied to those services within supervisory limits, business crowdfunding, crypto-asset services once separately authorised | Services operationally connected with e-money issuance, financing tied to payment services within supervisory limits, business crowdfunding, crypto-asset services once separately authorised |
Capital tied to the service you actually provide
Four figures, not one blended range. The tier follows the specific service the application names, so that decision comes before the capital is committed.
Four capital tiers in ascending order. Money remittance only, service 6: EUR 20,000. Payment initiation services only, service 7: EUR 50,000. Payment services 1 to 5: EUR 125,000. E-money institution: EUR 350,000, the same figure Article 4 of EMD2 sets for every EU member state.
Providers of payment initiation services (PIS) or account information services (AIS) carry one further condition: professional indemnity insurance, or an equivalent guarantee, alongside whichever capital tier applies.
| Requirement | Value | Article or source |
|---|---|---|
| IP capital: payment services 1 to 5 | EUR 125,000 | bancaditalia.it, istituti di pagamento |
| IP capital: money remittance only (service 6) | EUR 20,000 | bancaditalia.it, istituti di pagamento |
| IP capital: payment initiation services only (service 7) | EUR 50,000 | bancaditalia.it, istituti di pagamento |
| IMEL capital | not less than EUR 350,000 | bancaditalia.it, IMEL / EMD2 Art. 4 |
| Safeguarding of e-money funds after issuance | no later than 5 business days | EMD2 Art. 7 |
| Mandatory ABF dispute-resolution adherence | Art. 128-bis TUB | bancaditalia.it |
| Notification of start of operations | within 12 months of registration | bancaditalia.it, both pages |
| Banking activity (deposits plus lending) | reserved to banks alone, not covered by this licence | Art. 10 TUB, Normattiva |
The reservation map: how this differs from a banking licence
What separates an IP or an IMEL from a bank is a reservation of activities, not a difference of scale.
Banking activity: banks alone
Taking repayable funds from the public together with lending is banking activity under Article 10 of the Testo Unico Bancario, and only a bank may carry it on.
Lending: banks and Art. 106 intermediaries
Lending to the public in any other form is reserved to banks and to Article 106 financial intermediaries. An IP may finance only what is tied to the payment services it provides, within supervisory limits.
E-money issuance: banks and IMELs
The third reserved category sits with banks and IMELs only. A payment institution is expressly barred from it, whatever the size of the business it moves.
What is left is still a licence
An IP or an IMEL moves money, and an IMEL issues e-money. Neither takes deposits from the public, and neither lends as a bank does.
Three columns compare what banks, e-money institutions and payment institutions may do under the Testo Unico Bancario. Banks: deposits from the public, lending, e-money issuance. E-money institutions, IMELs: e-money issuance, the full range of payment services, financing tied to payment services, crowdfunding. Payment institutions, IPs: payment services only, financing tied to payment services within limits, crowdfunding, and expressly not e-money issuance, not deposit-taking and not general lending. Banking activity, deposits plus lending, stays with banks alone under Article 10 TUB.
How the process works
- Fix the service perimeter. The application names the specific payment service or services, or e-money issuance. That decision fixes the capital tier, so it is made before the capital is committed.
- Incorporate the vehicle. An S.p.A., S.a.p.a., S.r.l. or cooperative, with its registered office and general management in Italy, where part of the payment-services activity is actually carried on.
- Pay up the capital. The tier that follows from step 1, held as initial paid-up capital before the file goes in. EUR 20,000 to EUR 350,000
- Clear fit-and-proper. Qualifying shareholders and corporate officers must meet fit-and-proper requirements, with no impediment to effective supervision from the group or from close links. The condition runs on an ongoing basis.
- File with Banca d'Italia. Applications go under its published authorisation procedure, set out on its how to start an IP or IMEL page for applicants.
- Entry in the register. Banca d'Italia enters it in the albo of IMELs under Article 114-quater, or of IPs under Article 114-septies, with an identification code and a record of which services it may provide.
- Post-authorisation duties. Adherence to the Arbitro Bancario e Finanziario under Article 128-bis TUB, then notice to Banca d'Italia of the start of the institution's own operations. Within 12 months of registration
The core of the file, as Banca d'Italia lists it (Banca d'Italia: Istituti di pagamento):
- The atto costitutivo, the deed of incorporation
- The statuto, the articles of association
- A programme analysing the financial sustainability of the initial activity
- A description, inside that programme, of the services offered
- A report on the organisational structure
- Professional indemnity insurance or equivalent guarantee for PIS or AIS; the register records it
- The Registro delle Imprese entry certificate, forwarded after authorisation
Next step
Not sure whether you need an IP or an IMEL?
Describe the payment flows you plan to run and we will place them against the statute.
Tell us about your caseSafeguarding client funds
A compliance duty that starts on day one, and the two directives state it differently.
Five business days, for an IMEL
An e-money institution must safeguard the funds it receives in exchange for e-money issued no later than five business days after issuance, under Article 7 of EMD2. The clock runs from issuance.
What counts as an eligible asset
Secure, low-risk assets within specific regulatory categories. The competent authority may exclude particular assets after assessing security, maturity, value or another risk element. Not every low-risk instrument qualifies.
The parallel principle for an IP
A payment service user's funds must be kept separate from the institution's own funds (Directive (EU) 2015/2366, recitals 37 and 41). The page cites that as a recital and attributes no numbered obligation to PSD2.
Where the licence reaches: the EU and crypto-asset services
Passporting: the confirmed basis
PSD2's recital 41 frames cooperation between competent authorities for an authorised payment institution providing services in another member state, through the right of establishment or the freedom to provide services, anti-money-laundering rules still applying.
Passporting: what is not confirmed
The day-by-day Italian procedure and its deadlines are not confirmed. Banca d'Italia's market-access pages carry no dedicated cross-border section, and no timeline is invented here to fill that gap.
Not the same passport as crypto
A different route governs the MiCAR passport documented on our licensing service, with its own list of states and its own working-day figures. Those numbers stay on that page.
Crypto-asset services: a further authorisation
Banca d'Italia, having heard CONSOB, grants an already-licensed IP or IMEL a separate authorisation to provide crypto-asset services under Article 16(5) and (6) of Legislative Decree 129/2024.
The patrimonio destinato comes first
An institution running an unrelated business alongside must keep the payment or e-money activity in a ring-fenced pool, an ibrido commerciale in Banca d'Italia's terms. The pool is a precondition of the crypto add-on.
Where the specialised route lives
The CASP route through CONSOB, the ten crypto-asset services and the penalties for unauthorised activity sit on the MiCA framework.
Problems we solve
The tier decided after the capital is raised
The application names the service, and the service fixes the tier. A company that raises EUR 125,000 and then finds its business is money remittance alone has raised the wrong figure, not a larger one.
The grounds for refusal
Banca d'Italia verifies legal form, registered office, capital and the fitness of shareholders and officers, and refuses authorisation where sound and prudent management, or the regular functioning of the payment system, is not guaranteed.
Shareholder paperwork crosses borders
Fit-and-proper documentation depends on papers from more than one jurisdiction. We gather it before the file goes in, rather than in answer to a request.
No published decision time
Banca d'Italia's own pages on payment institutions and IMELs refer applicants to a separate procedural page rather than stating a number of days. No primary source confirmed one, so this page states none.
The standards behind the licence
The EBA authorises nobody in Italy, but writes the technical standards Banca d'Italia applies once an institution is licensed: strong customer authentication, the dedicated-interface fallback exemption, indemnity insurance, authorisation-file contents, operational, security and outsourcing risk.
Next step
Have you already fixed the structure?
Send us the services you plan to provide and we will tell you what the file has to contain.
Tell us about your caseWhy work with us
From our practice. Two items of the application file come back for rework more often than the rest: the financial-sustainability analysis and the organisational-structure report. Both tend to arrive written as a pitch for the business rather than as a description of how it will actually run, and Banca d'Italia is reading for the second thing.
Prepared by Marta De Luca, Regulatory and Licensing Lead, Milan office, after four years inside the compliance function of an Italian payment institution.
Reviewed by Giulia Mancini, Head of Corporate Formation. Updated 13 September 2026.
Accuracy note: this page states the position under the instruments cited, as published at the update date, and is not legal advice. Where a figure or a procedure was not confirmed by a primary source, the page says so rather than estimating one. Sources verified 6 to 11 September 2026.
Tell us about your case
Describe the payment flow and whose money is held when, and we will say which authorisation it needs.
Frequently asked questions about payment institution and EMI licensing in Italy
What is the difference between a payment institution and an electronic money institution in Italy?
A payment institution (IP) is authorised for one or more payment services; an electronic money institution (IMEL) is authorised to issue electronic money and may also provide the full range of payment services. Electronic money issuance is reserved to banks and IMELs, so an IP may not issue it.
Who authorises payment institutions and e-money institutions in Italy?
Banca d'Italia is the sole authority that authorises, registers and supervises payment institutions and e-money institutions, under the Testo Unico Bancario. It verifies legal form, capital, registered office and the fitness of shareholders and officers before granting authorisation.
What is the minimum capital for a payment institution in Italy?
EUR 125,000 in paid-up capital for one or more of payment services 1 to 5, EUR 20,000 for money remittance only, or EUR 50,000 for payment initiation services only. The tier follows the specific service actually provided, not a single blended figure.
What is the minimum capital for an e-money institution (IMEL) in Italy?
Not less than EUR 350,000 in paid-up capital, the same figure Directive 2009/110/EC (EMD2) sets at Article 4 for every EU member state, with no lower service-based tier.
Can a payment institution issue electronic money in Italy?
No. Electronic money issuance is reserved exclusively to banks and e-money institutions. A payment institution authorised for payment services may not issue e-money without separately holding, or becoming, an e-money institution.
Is a payment institution or EMI licence the same as a full banking licence?
No. Banking activity, meaning taking deposits from the public together with lending, is reserved to banks alone under Article 10 of the Testo Unico Bancario. A payment institution or e-money institution moves money, and an IMEL issues e-money, but neither takes deposits or lends as a bank does.
What happens once Banca d'Italia grants the authorisation?
The institution is entered in the relevant Banca d'Italia register: the albo of e-money institutions under Article 114-quater, or of payment institutions under Article 114-septies of the Testo Unico Bancario, with an identification code, once its Registro delle Imprese entry is confirmed.
Must a newly authorised payment institution or IMEL start operating immediately?
No, but it must notify Banca d'Italia of the start of its own operations within 12 months of registration. There is no minimum trading period, only this outer notification deadline.
Does an authorised payment institution or IMEL have to join a dispute-resolution scheme?
Yes. Once registered, the institution must adhere to the Arbitro Bancario e Finanziario, the out-of-court banking and financial dispute-resolution scheme, under Article 128-bis of the Testo Unico Bancario, alongside its other post-authorisation duties.
Which EU directives govern payment institutions and e-money institutions in Italy?
The Second Payment Services Directive, (EU) 2015/2366 (PSD2), for payment institutions, and the Second E-Money Directive, 2009/110/EC (EMD2), for e-money institutions. Both are implemented mainly through the Testo Unico Bancario and its supervisory secondary legislation.
Which Italian decrees transposed PSD2 and EMD2?
Banca d'Italia's own reference list names D.Lgs. 218/2017 as the decree that transposed PSD2 and D.Lgs. 45/2012 as the decree that transposed EMD2, alongside the Testo Unico Bancario. Their article-level content is not analysed on this page: every substantive claim here cites the TUB or Banca d'Italia's own supervisory pages directly instead.
How must client funds be safeguarded?
An e-money institution must safeguard funds received for e-money issued, in secure, low-risk assets, no later than five business days after issuance, under Article 7 of EMD2. Payment service user funds must likewise be kept separate from the institution's own funds under PSD2's own principle.
Can an Italian-authorised payment institution or e-money institution operate in other EU countries?
In principle yes, through the right of establishment or the freedom to provide services recognised by PSD2. The specific Italian notification procedure and timelines for this route were not confirmed in the research behind this page, so no timetable is stated here.
Can a payment institution or e-money institution provide crypto-asset services?
Yes, but only with a further, separate Banca d'Italia authorisation, granted after hearing CONSOB, and only once the institution has formed a ring-fenced patrimonio destinato for that activity. That additional route is covered on our crypto licence page.