Soda Labs

Italy

Customer-level reporting to a public registrar

JurisdictionEuropeConfidential with disclosure

Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.

What Italy actually says

Italy's national addition was a reporting channel rather than a prohibition, and it went further than the European baseline in an unusual direction. Providers registered in the special section had to transmit, every quarter, identification data for each customer together with summary data on that customer's overall activity in Italy. That is customer-level reporting to a registrar, on a fixed cycle, with no suspicion trigger and no transaction threshold. Nothing comparable exists in the EU rules the framework sat on top of. On the questions this section is otherwise about, Italy is quiet: we found no restriction on anonymity-enhancing assets and no national rule on self-hosted wallets.

The instruments that matter

Ministry of Finance decree of 13 January 2022
published in the Official Gazette on 17 February 2022, setting how and when virtual currency and digital wallet service providers must report their Italian activity
A special section of the agents and brokers register
operational from 18 May 2022, with registration required to operate or intend to operate in Italy
Quarterly transmission of customer-level data
providers report identification data for each customer plus summary data on that customer's overall activity, by the fifteenth day of the month following each quarter
No asset-level restriction found
we located no Italian instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets

What this means for confidential transactions

Bubble is built for exactly this shape of obligation: amounts and balances live on chain as ciphertexts, computation happens without decryption, and the only disclosure path is an on-chain access list through which an authorized party - an auditor, a supervisor, a counterparty - can request scoped decryption. That is confidentiality from the public, not from the regulator.

Compliant by default.

See how selective disclosure satisfies a supervisor without publishing your book to the world.