CONTATTACI

Anti-Money Laundering (AML/CFT)

Blockchain and Crypto-assets

Cloud computing

Compliance 231

Cybersecurity & NIS2

Digital Transformation for Law Firms

Right to be forgotten and online reputation

Copyright and Intellectual Property

Digital Communications and Influencer Marketing Law

Business and Digital Contracts

Fintech and Payment Systems

Artificial Intelligence

IT M&A

Privacy & DPO

Protection against financial fraud

Fintech and Payment Systems

We assist payment institutions, electronic money institutions (EMIs), banks, PSPs, and fintech startups in accessing the market and ensuring compliance of payment and electronic money services: from service design to contractual arrangements, from anti-fraud safeguards to relations with supervisory authorities.

The regulatory framework is evolving. PSD2 remains in force, but PSD3 and the new Payment Services Regulation (PSR) — politically agreed at the end of 2025 — will reshape authorisation requirements, open banking, strong customer authentication, and the allocation of liability for fraud. At the same time, instruments at the intersection of payments and crypto-assets (stablecoins, EMTs) require payment services regulation and MiCAR to be considered together.

We treat fintech for what it is: a regulated product built on technology. We work with the Firm’s technology partners to align the business model, service architecture, and authorisation perimeter before they become incompatible.

What we do

  • Market access — authorisation and registration of payment institutions and EMIs, agent and distributor networks, relations with the Bank of Italy.
  • Payment services agreements — framework agreements, terms and conditions, merchant acquiring, acquiring and issuing, cards.
  • Open banking and APIs — payment initiation services (PIS) and account information services (AIS), agreements between banks and third parties.
  • Instant payments — compliance with Regulation (EU) 2024/886 and Verification of Payee requirements.
  • Electronic money and stablecoins — EMTs under MiCAR as a means of payment; coordination with banking and anti-money laundering regulations.
  • Anti-fraud and authentication — strong customer authentication (SCA) and management of unauthorised transactions.
  • Consumer protection and transparency — information requirements under the Consumer Code and the Italian Consolidated Banking Act (TUB).
  • PSD2 — Directive (EU) 2015/2366. The current framework for payment services: regulated services, strong customer authentication, and liability rules for unauthorised transactions. Transposed into Italian law through the TUB and the Bank of Italy’s provisions.
  • PSD3 and PSR — under adoption. The proposed directive (PSD3) and proposed regulation (PSR) reached political agreement at the end of 2025; application is expected between late 2026 and 2027. The PSR will be directly applicable, without transposition, and will strengthen anti-fraud measures, open banking, and user protection.
  • Electronic money — Directive 2009/110/EC (EMD2). Governs the issuance of electronic money and EMIs; it is expected to be incorporated into the new PSD3/PSR framework.
  • Instant payments — Regulation (EU) 2024/886. Requires the availability of instant euro transfers and verification of the match between the IBAN and the payee, with implications for anti-fraud measures and user experience.
  • Stablecoins and crypto-assets — MiCAR (Regulation (EU) 2023/1114). EMTs sit at the intersection of electronic money and crypto-assets: their classification determines the competent authority and applicable regulatory framework. See the Blockchain and Crypto-assets practice.
  • Open finance — FIDA. The proposal on access to financial data (Financial Data Access) extends the open banking model to insurance, investment, and pension services; currently under negotiation.

How we work

Fintech operates at the intersection of product, technology, and regulation. We structure each project starting from the authorisation perimeter and allocation of responsibilities, rather than from the contract alone, working alongside the Firm’s technology partners.

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