ITALY Trends and Developments Contributed by: Francesco Paolo Patti and Marta Vittoria Colombo, Patti Legal
non-duplication, traceability and accessibility of data, as well as mechanisms to ensure business continu- ity and the correct recording of transfers and encum- brances. This regime has become a key driver of innovation in Italy, particularly in the tokenisation of real-world assets (RWAs). Unlike unregulated crypto-assets, tokenised financial instruments benefit from an estab- lished legal infrastructure, making them especially attractive for institutional actors seeking to leverage blockchain technology within a clearly defined and enforceable legal framework. Institutional Innovation Hubs: Consob Tech and Milano Hub Italy’s approach to financial innovation is supported not only by formal regulatory frameworks but also by dedicated institutional platforms designed to facilitate early engagement between regulators and market participants. Two initiatives stand out in this respect: Consob Tech and the Milano Hub of the Bank of Italy, which operate in a complementary manner within their respective areas of competence. Consob Tech functions as the primary entry point for projects falling within the securities and investor pro- tection perimeter. It is not an authorisation mecha- nism, but a structured dialogue channel through which firms can present innovative business models – par- ticularly in areas such as crypto-assets, tokenisation and digital platforms – and receive preliminary, non- binding guidance. A key feature of Consob Tech is its focus on legal classification and regulatory framing, helping operators determine whether a product quali- fies as a financial instrument, falls within MiCAR or is subject to other regulatory regimes. In doing so, it reduces legal uncertainty at an early stage and sup- ports a compliance-by-design approach. In parallel, the Bank of Italy’s Milano Hub serves as a broader innovation centre focused on the banking, payments and financial infrastructure domains. Unlike Consob Tech, which is primarily interpretative and regulatory in nature, the Milano Hub provides techni- cal and institutional support for the development of innovative solutions. Selected projects are admitted to dedicated “call for proposals” cycles and benefit
from interaction with Bank of Italy experts, as well as access to research, workshops and collaborative initiatives. The Hub does not grant licences or funding, but facilitates the maturation of projects by aligning technological innovation with regulatory expectations, particularly in areas such as digital payments, DLT- based infrastructures and operational resilience. Together, these two initiatives reflect a coherent insti- tutional strategy. Innovation is not addressed through deregulation, but through structured engagement with competent authorities, allowing business models to be refined before entering fully regulated markets. For operators, this dual framework offers both legal clar- ity (through Consob Tech) and technical and super- visory dialogue (through the Milano Hub), reinforcing Italy’s approach of integrating innovation within a well- Italian regulators – particularly Consob – have adopted a proactive and assertive enforcement approach. This is evident not only in formal supervisory frameworks but also in a growing number of concrete enforcement actions targeting both domestic and cross-border operators. Consob has been especially active in: • blocking websites offering unauthorised crypto- asset services to Italian users; • issuing public warnings against non-compliant operators; and • intervening in unlawful public offerings of crypto- assets. defined regulatory perimeter. A Strong Enforcement Posture Recent cases have included the prohibition of multiple online platforms and enforcement measures against token offerings conducted without compliant white papers. These interventions have not been limited to Italian-based entities but have extended to operators established abroad that actively target Italian inves- tors, demonstrating a willingness to exercise powers in a cross-border context where necessary. A particularly illustrative case is the public offering of the so-called memecoin $CORONA. In January 2026, Consob issued a formal public statement under Article
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