Legislative Decree 184 implements the European directive on the European Single Access Point (ESAP)

Legislative Decree no. 184 of September 25, 2026 transposes Directive (EU) 2023/2864 and adapts the national legal system to Regulations (EU) 2023/2859 and (EU) 2023/2869, which establish the European Single Access Point (ESAP). The measure is published in the Official Gazette of the Italian Republic, General Series no. 240 of October 15, 2026, page 1, with the official reference 26G00202. Signed by the President of the Republic Mattarella, it sets the dates for the commencement of transmission obligations for banks, insurance companies, listed companies, and pension funds for 2028 and 2030.

Ten articles to align Italy with ESAP

The text implements Article 22 of Law no. 91 of June 13, 2025, the 2024 European delegation law. The preliminary deliberation of the Council of Ministers was on July 2, 2026, and the final one on September 16, 2026; the decree is proposed by the Minister for European Affairs, the PNRR, and Cohesion Policies Foti and the Minister of Economy and Finance Giorgetti, in concert with the Ministers of Foreign Affairs Tajani and Justice Nordio, who also signs as Keeper of the Seals.

The decree intervenes on a wide range of sources: the consolidated law on banking, the consolidated law on financial intermediation, the private insurance code, the regulations on supplementary pension schemes, the law on the securitization of credits, and the rules on statutory auditing and sustainability reporting.

The three deadlines

• July 10, 2026: Consob becomes the collection body for the information provided for by Regulation (EU) no. 236/2012 and Regulation (EU) no. 2017/1129.
• January 10, 2028: obligations begin for corporate sustainability reporting, for UCITS management companies, and for sanctions regarding undertakings for collective investment in transferable securities.
• January 10, 2030: the general deadline takes effect for banks, investment firms, insurance companies, pension funds, statutory auditors, and for the majority of sanction-related communications.

Who transmits and who collects

Obligated entities must send information in a machine-readable data format, accompanied by metadata indicating the name, legal entity identifier, size, sector of activity, and the presence of personal data. The designated collection bodies are:

• the Bank of Italy, for supervised entities and supervisory, sanctioning, and resolution tasks;
• Consob, for issuers, investment firms, and market operators;
• IVASS, for the insurance and distribution sector;
• COVIP, for pension funds and complementary pension schemes;
• the Ministry of Economy and Finance, for statutory auditing;
• the business register at the Chambers of Commerce, for non-listed companies;
• the Supervisory Body and keeper of the single register of financial advisors.

Article 8 provides that the designation of collection bodies shall be notified to ESMA by January 9, 2028, or January 9, 2030, according to the terms of the directive. Article 9 requires every legal person subject to the transmission obligation to obtain in advance the legal entity identifier provided for by Regulation (EU) 2023/2859.

No additional burden

Article 10 contains the financial invariance clause: administrations shall provide for the necessary human, instrumental, and financial resources already available, without new or increased burdens on public finances.

For readers, the change is concrete: from 2028 and 2030, the financial and sustainability information of banks, insurance companies, and listed companies will be available at a single European access point, in a machine-readable format and with standardized metadata.

Source: Official Gazette of the Italian Republic, General Series no. 240 of October 15, 2026, page 1 — Legislative Decree September 25, 2026, no. 184 (26G00202).