What a payment institution and an e-money institution are
Two ambiguities need clearing before anything else. "Payment institution" is used loosely for any payments company, and "EMI" is sometimes read as a payment processor rather than an e-money issuer. Neither usage matches the statute, and the gap between them is where a wrong application starts.
The definition of a payment institution (IP)
Definition. A payment institution (IP), istituto di pagamento in Italian, is an undertaking, other than a bank or an e-money institution, authorised to provide one or more of the payment services listed in Article 1(2)(h-septies.1) of the Testo Unico Bancario (Banca d'Italia: Istituti di pagamento).
The definition of an e-money institution (IMEL)
Definition. An e-money institution (IMEL), istituto di moneta elettronica in Italian, is an undertaking, other than a bank, authorised to issue electronic money (Banca d'Italia: Istituti di moneta elettronica). E-money issuance is reserved to banks and IMELs alone. A payment institution may not issue it under either authorisation.
Who authorises both, and the link to our own licensing work
Banca d'Italia is the sole authority for both licences on this page. An already-licensed IP or IMEL that later wants to add crypto-asset services needs our licensing service, a further, separate authorisation covered on its own page, not an extension of this one: unlike that crypto-asset route, where CONSOB and Banca d'Italia split the work, no second regulator opens a file for the licences described here.
What this page does not cover
Four topics sit outside this page on purpose. The consumer side of PSD2, strong customer authentication and disputing a payment belong to a different audience than a founder applying for a licence. The crypto-asset authorisation on its merits, the ten CASP services and the penalties for unauthorised activity belong to the crypto licensing page. MiCA itself, the token categories and the white paper belong to the MiCA guide. Incorporating the underlying S.p.A., S.a.p.a. or S.r.l. step by step belongs to the company registration pages; here only the capital and form conditions that affect this licence appear.
How this differs from a full banking licence: the reservation map
Nine explanations of "payment licence Italy" out of ten give the capital figures and stop. What actually separates an IP or IMEL from a bank is a reservation of activities, and it deserves its own map rather than a single sentence.
Banking activity is reserved to banks alone
Taking repayable funds from the public together with lending constitutes banking activity under Article 10 of the Testo Unico Bancario, and only a bank may carry it on. An IP or IMEL never crosses into this category, whatever the size of the business it moves.
Lending to the public stays with banks and Art. 106 intermediaries
Lending to the public in any other form is reserved to banks and to Article 106 financial intermediaries. A payment institution may grant financing only where it is tied to the payment services it actually provides, within supervisory limits, a narrow exception rather than a lending business of its own.
E-money issuance is reserved to banks and IMELs
The third reserved category is e-money issuance. It sits with banks and IMELs only, and a payment institution is expressly barred from it, restating from the reservation side what the two definitions already set up.
The reservation map, visualised
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.
That is the actual distinction from a full banking licence: an IP or IMEL moves money, and an IMEL issues e-money, but neither one takes deposits from the public or lends as a bank does.
Choosing the category and the company that will hold it
Once the reservation map is clear, the next decision is structural: which legal form, and where it has to sit.
Permitted legal forms
Both an IP and an IMEL may be an S.p.A., an S.a.p.a., an S.r.l. or a cooperative, identically for the two categories. The vehicle has to be incorporated in one of these four forms before an application can be filed; the mechanics of setting one up sit on Company in Italy: company registration in italy, not here.
Registered office and general management in Italy
The registered office and the general management of both categories must sit in Italy, where at least part of the payment-services activity is actually carried on. A licence held at arm's length from another country, with management sitting elsewhere, does not meet this condition.
Fit-and-proper for shareholders and officers
Qualifying shareholders and corporate officers must meet fit-and-proper requirements, and there must be no impediment to effective supervision arising from the institution's group or from close links with other parties. This condition runs on an ongoing basis, not only at the moment of filing.
Capital: tied to the service you actually provide
Competitors quote a single blended range from roughly EUR 20,000 to 125,000 and leave it there. That range hides which activity triggers which figure, and getting the tier wrong before the file is built is an expensive mistake to unwind. Payment institution capital Italy figures and e-money institution capital Italy figures are, in fact, four separate numbers, not one.
EUR 125,000 for payment services 1 to 5
An IP applying for one or more of payment services 1 to 5 needs initial paid-up capital of EUR 125,000. This is the general tier, and it covers the core payment services most applicants actually run.
EUR 20,000 for money remittance only
An applicant that provides rimessa di denaro (money remittance, payment service 6) only needs EUR 20,000, the lowest of the three IP tiers. Adding a second service outside remittance moves the applicant into the EUR 125,000 tier instead.
EUR 50,000 for payment initiation services only
An IP authorised solely for payment initiation services (PIS, service 7) needs EUR 50,000. Providers of PIS or of account information services (AIS, service 8) also carry a separate condition: professional indemnity insurance, or an equivalent guarantee, alongside whichever capital tier applies.
EUR 350,000 for an e-money institution, and the tiers compared
An IMEL's initial paid-up capital must not be less than EUR 350,000, the same figure Article 4 of EMD2 itself sets for every EU member state. There is no lower, service-based reduction for an IMEL the way there is for an IP. An e-money institution licence Italy grants and an EMI licence Italy grants describe the same IMEL licence Italy status under one name: the market uses "EMI" and "IMEL" interchangeably for the same TUB category.
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.
| 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 |
| IMEL register | Art. 114-quater TUB | bancaditalia.it |
| IP register | Art. 114-septies TUB | bancaditalia.it |
| 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 |
What else an IP or an IMEL may do, and the patrimonio destinato
Neither category is limited strictly to its headline activity. Each carries a set of ancillary permissions, and one condition applies whenever the institution runs another business alongside them.
An IMEL's ancillary permissions
Beyond issuing e-money, an IMEL may provide services operationally connected with that issuance; provide the full range of payment services, even unconnected with e-money issuance; grant financing tied to payment services within supervisory limits; provide business crowdfunding services; and carry on crypto-asset activities once separately authorised, the fork described later on this page.
A payment institution's narrower ancillary permissions
An IP's ancillary set is narrower: operating payment systems, guaranteeing transaction execution, foreign-exchange services, custody, recording or processing of data closely connected with its payment services, business crowdfunding, and crypto-asset activities once separately authorised.
Running another business alongside: the "commercial hybrid"
Where an IP or IMEL also runs an unrelated business, the payment or e-money activity has to sit inside a ring-fenced asset pool, the patrimonio destinato. Banca d'Italia describes an intermediary in that position as a ibrido commerciale (commercial hybrid), and the same ring-fenced structure is the precondition for adding crypto-asset services later.
The application file: what Banca d'Italia asks for
Three things make up the file: which service is being applied for, what documents support it, and where it is filed.
Stating which service or services you want to be authorised for
The application names the specific payment service or services, or e-money issuance, the applicant wants to be authorised for. This single decision fixes the capital tier from the section above, so it has to be made before the capital is committed, not after.
What the file contains
The core documents are the atto costitutivo (deed of incorporation), the statuto (articles of association), a programme analysing the financial sustainability of the initial activity and describing the services offered, and a report on the organisational structure (Banca d'Italia: Istituti di pagamento). For PIS or AIS applicants, the insurance policy or equivalent guarantee from the capital section is filed alongside these.
Filing with Banca d'Italia, and what the page does not state
Applications go to Banca d'Italia under its published authorisation procedure, set out on its how to start an IP or IMEL page for applicants. No specific number of days for the decision appears here, because Banca d'Italia's own pages on payment institutions and IMELs refer applicants to a separate procedural page rather than stating one, and no primary source for that figure was confirmed. A related, optional filing sits alongside the main one: a payment service provider holding online-accessible accounts that opts for a dedicated interface for third-party providers may ask Banca d'Italia for an exemption from building an emergency fallback interface.
Safeguarding client funds
Getting authorised carries a compliance duty from day one: protecting the money the institution holds for its clients. EMI safeguarding requirements and the parallel duty for a payment institution both rest on the same principle, kept apart below by which directive states which figure.
The five-business-day safeguarding deadline
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, not from the moment the funds first arrive.
What counts as an eligible asset
Funds are held in secure, low-risk assets within specific regulatory categories, and the competent authority may exclude particular assets after assessing their security, maturity, value or other risk element. Not every low-risk instrument automatically qualifies.
The parallel principle for payment institutions
PSD2's own recital 37 states that a payment service user's funds must be kept separate from the institution's own funds, the parallel duty for a payment institution (Directive (EU) 2015/2366, recitals 37 and 41). This page cites that recital as a recital, and no further paragraph-numbered obligation is attributed to PSD2 beyond it.
Operating in the rest of the EU: an honest look at passporting
The value of either licence outside Italy deserves an honest answer, not a filled-in one.
The confirmed legal basis
PSD2's recital 41 frames cooperation between competent authorities for an authorised payment institution that wants to provide services in another EU member state, through the right of establishment or the freedom to provide services, while still complying with applicable anti-money-laundering rules. That legal basis is confirmed.
What is not confirmed, stated plainly
The day-by-day Italian procedure and any specific deadlines for this route are not confirmed. Banca d'Italia's general market-access pages carry no dedicated cross-border section for it, and no timeline is invented here to fill that gap.
Not the same passport as the crypto-asset route
A different route entirely governs the MiCAR passport already documented on our crypto licence page, with its own list of states and its own working-day figures. Those numbers belong to that page and are not reused here for a mechanism that works differently.
Adding crypto-asset services to an existing licence
An already-licensed IP or IMEL is not shut out of the crypto-asset market. It simply needs a further authorisation, on its own terms.
Banca d'Italia, having heard CONSOB
Banca d'Italia, having heard CONSOB, is the authority that grants an already-licensed IMEL or payment institution a further, separate authorisation to provide crypto-asset services under Article 16(5) and (6) of Legislative Decree 129/2024. This is a distinct event from the initial IP or IMEL authorisation described on the rest of this page.
The condition: forming the patrimonio destinato first
The ring-fenced asset pool described earlier, the patrimonio destinato, is a precondition of this add-on, not an optional extra. An institution cannot apply for the crypto-services authorisation before it has formed one.
Where the specialised route lives
The specialised CASP route through CONSOB, the ten crypto-asset services and the penalties for unauthorised activity are covered on the MiCA framework, for a reader who wants that regulation on its own merits rather than this add-on procedure.
How we support a payment institution or EMI application
Work on either licence splits into three stages, and the first one decides most of what the other two cost in time. Pricing on request, through the contact form.
A preliminary assessment of category and tier
Before anything is drafted, we check which of the eight payment services the business model actually needs, whether IP or IMEL is the correct category, which capital tier follows from that answer, and whether the company form and the Italy-based management condition are already met.
Building the Banca d'Italia file
Assembly covers the atto costitutivo, the statuto, the programme of activity, the organisational-structure report and, where relevant, the professional indemnity insurance evidence for PIS or AIS. One adjacent point belongs here rather than to marketing: once the institution's public name is entered in the Banca d'Italia register, protecting it is a natural next step, whether through national UIBM filing or an EU trade mark.
After the decision
Once the decision is granted, the work changes shape: registration in the albo, adherence to the ABF, the 12-month notice of the start of operations, and, where relevant, the separate application for the crypto-services add-on described above. If you want us to look at a specific structure, start the onboarding form and describe the services you plan to provide.
From our practice
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.
Frequently asked questions about payment institution and EMI licensing in Italy
Category, authority and capital
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.
The bank comparison and post-authorisation duties
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.
Compliance, the EU and the crypto fork
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.
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.
By Marta De Luca, Regulatory and Licensing Lead, Milan office. Marta De Luca works on authorisations: who has to be licensed in Italy, by which authority, and what the file has to contain. Four years inside the compliance function of an Italian payment institution taught her what a supervisor actually reads.
Reviewed by Giulia Mancini, Head of Corporate Formation. Updated 11 September 2026.