Italy's Crypto Framework: OAM Register & MiCA CASP
Italy regulates crypto virtual asset service providers through a two-tier system. The first tier is mandatory OAM registration — introduced by an amendment to Legislative Decree 231/2007 (Italy's AML legislation) via the Ministry of Economy and Finance. OAM (Organismo Agenti e Mediatori) maintains a public register of VASPs that are permitted to provide crypto services in Italy. Registration confirms AML compliance registration but is not a full supervisory licence.
The second tier, for full MiCA CASP authorisation providing EU passporting rights, involves Banca d'Italia and Consob as the joint Italian competent authorities. Banca d'Italia supervises custody and payment-related crypto services, while Consob oversees exchange, trading, and investment-related crypto activities. This dual-authority structure mirrors Italy's existing financial regulatory division between the two bodies.
Italy has one of Europe's most active crypto user bases, with an estimated 3 million+ users and growing institutional adoption. Domestic platforms including Conio (backed by Poste Italiane), Young Platform, and the Italian operations of international exchanges have established a significant market. Italy's 24% IRES corporate income tax plus 3.9% IRAP regional tax is offset by market size and the relatively fast OAM registration path.
Two-track structure: OAM registration (fast, 1–3 months, EUR 350–500) is required for any VASP targeting Italian customers. MiCA CASP authorisation (Banca d'Italia + Consob, 6–12 months, EUR 150,000 capital) is required for EU passporting. Both may be pursued in parallel, with OAM registration enabling immediate Italian market access while the CASP authorisation is pending.
OAM Registration vs. MiCA CASP Authorisation
| Track | Regulator | Scope & Passporting |
|---|---|---|
| OAM VASP Registration | OAM (register) + MEF (oversight) | Italian market access; AML compliance registration; no EU passport |
| MiCA CASP Authorisation | Banca d'Italia (custody/payment) + Consob (exchange/investment) | Full EU passporting into 27 member states; higher capital requirements |
| ART / EMT Issuance | Banca d'Italia (EMTs) + Consob (ARTs) | Token issuance under MiCA Titles III and IV; separate authorisation |
Italy OAM & MiCA CASP — Key Requirements
How to Get an Italy Crypto Licence — Step by Step
Incorporate an Italian Società a Responsabilità Limitata (S.r.l.) via a notary — minimum share capital of EUR 1 (though practical operation requires adequate capitalisation). Alternatively, a foreign EU entity may register an Italian branch (succursale). Obtain a codice fiscale (tax identification number) and register with the Italian Business Register (Registro delle Imprese).
2–4 weeksPrepare a complete AML/CFT framework compliant with Italian AML legislation. This includes KYC/CDD procedures, customer risk-rating methodology, transaction monitoring rules, Travel Rule compliance procedures, suspicious transaction reporting workflows, and data retention policies per GDPR. Appoint an AML compliance officer (Responsabile Antiriciclaggio).
2–4 weeksFile the VASP registration application with OAM through its online portal. Include corporate documentation, description of crypto services, AML framework summary, management declaration of good repute, and payment of the OAM registration fee (EUR 350–500). OAM acknowledges receipt and reviews completeness. The public OAM register listing follows within 1–3 months.
1–3 monthsWith OAM registration confirmed, commence providing crypto services to Italian customers. Maintain ongoing AML compliance obligations, transaction monitoring, and periodic OAM reporting. Begin preparation of MiCA CASP authorisation application with Banca d'Italia and Consob if EU passporting is required — this is a longer and more complex process.
Ongoing from Month 3For EU passporting, submit the MiCA CASP authorisation application to Banca d'Italia and/or Consob (depending on activities). This requires EUR 150,000 minimum capital, complete governance documentation, full business plan, IT security framework, and fit & proper documentation for all directors and significant shareholders. Authorisation typically takes 6–12 months.
6–12 months (CASP)Italy Crypto Licence — Full Cost Breakdown
| Item | Details | Approx. Cost |
|---|---|---|
| S.r.l. formation | Notary, commercial register, codice fiscale | EUR 1,000–3,000 |
| OAM registration fee | Non-refundable OAM registration fee | EUR 350–500 |
| Legal & AML preparation | AML framework, OAM application, Italian counsel | EUR 5,000–20,000 |
| Annual compliance | AML officer, OAM annual reporting, legal retainer | EUR 10,000–25,000/yr |
| MiCA CASP preparation (optional) | Full CASP application with Banca d'Italia / Consob | EUR 20,000–60,000 |
| Year 1 Total — OAM only (excl. capital) | Formation, OAM fee, legal, compliance | EUR 18,000–50,000 |