Integrated CASP and EMI authorisation for a payments and crypto-asset operator

Electronic money · Crypto-assets

2026

One of Italy’s first cases of integrated CASP + EMI authorisation concerned an operator already registered with the OAM. By resolution no. 24060 of 30 June 2026, after consulting the Bank of Italy, CONSOB authorised custody and administration of crypto-assets on behalf of clients, exchange for funds, exchange for other crypto-assets and transfer on behalf of clients under Article 16(1) of Legislative Decree 129/2024 and Article 63 of Regulation (EU) 2023/1114. In parallel, Bank of Italy measure no. 0713266/26 of 23 June 2026, adopted by Governor’s resolution no. 193/2026, authorised the issuance of electronic money and the provision of the payment service under Article 1(2), letter h-septies.1, point 3.3 of the Italian Banking Act, through the establishment of a dedicated pool of assets under Article 114-quinquies of that Act. The infrastructure supports the movement of value between fiat currency, crypto-assets and stablecoins.

LX20 advised the company in the CASP authorisation procedure under MiCAR and coordinated the transaction as a whole, with a team comprising the managing partner, a senior associate and a trainee. The EMI aspects were handled by another law firm.