From 1 January 2026, the transparency operation on financial accounts with digital assets will start. Banks, portfolio managers and service providers on crypto assets will have to automatically report to the Revenue Agency all information on accounts with electronic money, central bank digital currencies (Cbdc) and crypto assets subject to disclosure, i.e. those used for payments or investments, excluding digital currencies and pure electronic money. It was the Ministry of the Economy that set the rules with a decree signed by Minister Giancarlo Giorgetti at the end of the year, effectively amending the old ministerial decree of 2015 in light of EU Directives 2025/872, so-called Dac 9 and 2023/2226 so-called Dac 8, as well as the OECD addendum signed on 20 November 2024.
How the definitions change
The changes introduced by the new ministerial decree immediately affect key definitions in the Common Reporting Standard (Crs) framework, extending tax due diligence and reporting obligations to new entities and instruments. Starting with the investment entity, which as of 1 January also includes managers that trade or manage crypto assets, provided that the gross income derived from crypto asset management and trading activities is equal to or greater than 50 per cent of the entity’s gross income over the lesser of the three-year period ending 31 December prior to the year in which the determination is made, and the period during which the entity has existed. Then there are depository institutions, which refer to any entity that accepts deposits as part of its banking or similar business and holds electronic money or central bank digital currencies for the benefit of customers.
E-money definition
The decree also provides a precise definition of electronic money. In essence, it is all those products that digitally represent a single fiduciary currency, i.e. the official currency of a jurisdiction issued by a central bank or designated monetary authority, represented by banknotes or physical coins. Not only that. Electronic money is also the product placed on receipt of funds to make payments or all those products that represent a claim on the issuer or even those products accepted in payment by parties other than the issuer.
Enhanced reporting and EU compliance
The decree signed by Giorgetti also provides for a significant increase in the data to be transmitted to the tax authorities: these range from generalities to the tax residence of holders and valid self-certifications and pre-existing or new account types from 2016 to 2026. There is also an obligation to update not only annually, while duplicate information for data already submitted is excluded from the submission. Only for accounts already in existence as at 31 December 2025, for the reporting years 2026 and 2027, Italian reporting institutions will not have to send information on the role(s) by virtue of which a reporting person is a person exercising control over an entity or a holder of a stake in the risk capital of an entity if the financial institutions themselves do not hold this information.
Impacts for intermediaries and savers
Banks and fintechs from 1 January 2026 are required to review their systems for the new free EU identification service and transitional procedures on missing self-certifications. A fact that sets off alarm bells especially among the operators called upon to adopt the new rules on enhanced digital transparency, especially on foreign savers: in order to combat cross-border evasion, the government, as stipulated by the same decree in Article 6, will not have to bear any additional burden, however, passing on new compliance costs to private operators.