Italy

Adoption date

Type of measure

Beneficiaries' sector specification

Description of measure

08/04/2020

Public guarantees

Non-financial corporations

Article 13 of L.D. of 08 April 2020 no. 23 (“Liquidità”) converted into Law of 24 April 2020 no. 40:  the measure repeals article 49 of L.D. 17 March 2020 no. 18 (“Cura Italia”) converted into Law 27/2020 on the guarantee fund for SMEs ("Fondo di Garanzia per le PMI") .
The operations of the guarantee fund for SMEs has been extended to firms with up to 499 employees. It becomes a comprehensive action to support credit access and help containing the effect of the epidemic on private sector. More specifically, the guarantee will be activated with simplified procedures. The guarantee can be cumulated with other forms of guarantees and the maximum coverage can be increased and diversified for more impacted sectors. The coverage for eligible operations has raised to 90 per cent (in the case of loan guarantee consortiums, to 100 per cent) to finance amounts for up to six years. Resources initially allocated to the provision of public guarantees according to article 49 of L.D. no. 18/2020 ("Cura Italia") have been used to finance article 13 of L.D. no. 23/2020 ("Liquidità") and have been further extended by article 31 of L.D. of 19 May 2020 no. 34 ("Rilancio"). Article 64 of L.D. no. 104 of 14 August 2020 ("agosto") has allocated additional resources to the Fund for the years 2023-2025.

With art. 1, paragraphs 244 and 245 of the 2021 Budget Law (Decree 178/2020) the guarantees offered by the SME Guarantee Fund are extended, however with a difference between SMEs and companies with a number of employees between 250 and 499 (midcaps). For the former, guarantees can be granted until 30 June 2021, for the latter until 28 February. As a consequence, resources allocated to the Fund have been further extended.

17/03/2020

Public guarantees

Banking sector

Article 57 of L.D. of 17 March 2020 no. 18 ("Cura Italia") converted into Law of 24 April 2020 no. 27: public guarantees in favour of Cassa Depositi e Prestiti (CDP S.p.A.) on loans to banks and other financial intermediaries that provide financial support to large firms experiencing a drop in turnover related to the pandemic emergency. The guarantee would cover up to 80 per cent of the loans. The measure has not yet been enacted as eligibility criteria and conditions for the access to the guarantee should be defined by a ministerial decree.

08/04/2020

Public support for trade credit insurance

Non-financial corporations

Article 2 of L.D. of 08 April 2020 no. 23 ("Liquidità") converted into Law of 24 April 2020 no. 40. The measure changes the structure of the export credit co-insurance system between the Government and the Italian export credit agency (SACE S.p.A.). The new structure provides that 90% of the burden is assumed by the Government and the remaining 10% by SACE. This system should allow to free resources for around € 200 billion to be allocated by SACE to the strengthening of exports. The measure has not yet been enacted.

17/03/2020

Public moratoria

Non-financial corporations

Article 56 of L.D. of 17 March 2020 no. 18 (“Cura Italia”) converted into Law 27/2020 defines a temporary moratorium on loan repayments for SMEs.
The measure would provide a few-months credit moratorium for Italian SMEs.
Specifically, firms can: (a) freeze the amounts agreed for revocable credit lines or for loans granted against advances on  receivables  until  30  June  2021;  (b)  defer  until  30  June 2021 the  repayment  of  loans  maturing  prior  to  that  date;  (c)  suspend  mortgage  instalments  or  lease  payments  for  the  same  period.   The moratorium does not imply, as such, automatic changes in the credit quality classification of exposures.

Art. 65 of L.D. of 14 August 2020 no. 104 ("Decreto Agosto") extended the moratorium to January 31, 2021.
For firms working in the touristic sector the moratorium applies until March 31, 2021.

With  art. 1, paragraph 248 of the 2021 Budget Law (Decree 178/2020), the moratorium for SMEs has been extended until June 30, 2021. Moreover, with art. 1, paragraph 213 of the same Law, the potential beneficiaries have been expanded including to companies of financial agents, to credit brokerage companies, as well as to companies governed by the Consolidated Banking Act ("Testo Unico Bancario") that carry out the activities of independent insurance experts and liquidators (included in the NACE code K66.21).

17/03/2020

Public guarantees

Banking sector

Article 56 of L.D. of 17 March 2020 no. 18 (“Cura Italia”) converted into Law 27/2020 defines a temporary moratorium on loan repayments for SMEs.
The measure would provide a few-months credit moratorium for Italian SMEs.
Specifically, firms can: (a) freeze the amounts agreed for revocable credit lines or for loans granted against advances on  receivables  until  30  June  2021;  (b)  defer  until  30  June 2021  the  repayment  of  loans  maturing  prior  to  that  date;  (c)  suspend  mortgage  instalments  or  lease  payments  for  the  same  period.   The moratorium does not imply, as such, automatic changes in the credit quality classification of exposures. The guarantee applies to up to 33% of the amount subject to moratorium.  

Art. 65 of L.D. of 14 August 2020 no. 104 ("Decreto Agosto") extended the moratorium to January 31, 2021.
For firms working in the touristic sector the moratorium applies until March 31, 2021.

With  art. 1, paragraph 248 of the 2021 Budget Law (Decree 178/2020), the moratorium for PMIs has been extended until June 30, 2021. 

17/03/2020

Other measures of fiscal nature

Banking sector

Article 55 of L.D. of 17 March 2020 no. 18 ("Cura Italia") converted into Law of 24 April 2020 no. 27: the measure would provide a temporary incentive for companies to sell non-performing loans (NPLs); the incentive consists in the option to transform deferred tax assets (DTAs) into a tax credit for about 20% of the transferred NPLs, up to 2 billion NPLs sold. With Article 1, paragraphs 233-243 of the 2021 Budget Law the measure has been extended to merger operations until 31 December 2021.

17/03/2020

Public guarantees

Non-financial corporations

Article 49 of L.D. of 17 March 2020 no. 18 (“Cura Italia”) converted into Law of 24 April 2020 no. 27.
The guarantee Fund for SMEs becomes a comprehensive action to support credit access and help containing the effect of the epidemic on private sector. More specifically, the guarantee will be activated with simplified procedures. The guarantee can be cumulated with other forms of guarantees and the maximum coverage can be increased and diversified for more impacted sectors.

19/05/2020

Other measures of fiscal nature

Non-financial corporations

Article 26 of L.D. of 19 May 2020 ("Rilancio") establishes a SME Fund for subscribing by 31 December 2020 bonds or debt securities issued by the beneficiaries of the measure IT-039 with more than 250 employees and a turnover between €10 and €50 million in 2019 that will increase their capital by at least  €250000 by the end of 2020. The Fund amounts to € 4 billion and it is managend by the Italian National Agency for Inward Investment and Economic Development (INVITALIA). The 2021 Budget Law (article 1, paragraph 263-264) has extended the measure until 30 June 2021 and has provided additional € 1 billion to the Fund for 2021.

19/05/2020

Public support for trade credit insurance

Insurance sector

Article 35 of L.D. of 19 May 2020 no. 34 ("Rilancio"): Public guarantees through the Italian export credit agency (SACE S.p.A.) to support trade credit insurance.  SACE S.p.A. will grant a guarantee equal to 90 per cent of the indemnities generated by the exposures relating to trade credit insurances accrued from the date of entry into force of the decree and until 31 December 2020 and within the maximum limit of 2000 million euros. Law no. 178/2020 (so called "Legge di Bilancio 2021") extends  the application of the Public guarantees through the SACE S.p.A. to support trade credit insurance,  until the 30th of June, 2021. 

19/05/2020

Tax reliefs

All sectors

Articles 28, 119, 125 and 176 of L.D. of 19 May 2020 no. 34 ("Rilancio") introduce tax credits on expenses incurred by firms in relation to COVID-19 pandemic (e.g. the adaption of work places), on rents paid by small firms on commercial buildings and on expenses incurred by households for holidays and extend to 110 per cent the tax credit on expenses for building maintenance actions in the field of the energy efficiency and for anti-sismic interventions. Articles 121 and 122 provide for an extension of the possibilities of transferring such tax credits to other subjects - including banks and insurance companies.

19/05/2020

Direct grants

Non-financial corporations

Article 25 of L.D. of 19 May 2020 no. 34 ("Rilancio") provides a non-refundable subsidy to companies and self-employed with a turnover up to €5 million in 2019. The amount of the subsidy depends on the dimension of the firm and of the drop in turnover related to the Covid-19 epidemics. The minimum amount of the subsidy is €1000 for self-employed workers and €2000 for firms. Following the second wave of the pandemic, the size and the beneficiaries of the direct transfers have been extended (with Decree Law n. 137 of 28 October 2020, Decree Law n. 149 of 9 November 2020, Decree Law n. 154 of 23 November 2020 and Decree Law n. 157 of 30 November 2020) to include firms located in the areas or operating in the sectors mostly hit by limitations to the economic activity.

19/05/2020

Equity participation

Non-financial corporations

Article 27 of L.D. of 19 May 2020 no. 34 ("Rilancio"): for companies with a turnover over €50 million, the so called “Patrimonio Rilancio” (Relaunch Fund) has been established for interventions in support of recapitalization for joint-stock companies registered in Italy, excluding banks and insurance companies. The Fund will be participated by the Ministry of Finance and managed by Cassa Depositi e Prestiti S.p.A. The Fund will be financed through new issuances of debt securities up to €44 billion. The Fund is expected to last 12 years since its implementation. However it has not yet been enacted. The functioning of the Fund will be defined with a joint decree of the Ministry of Finance and the Ministry of Economic Development. The L.D. of 14 August 2020 no. 104 has established that part of the endowment of the Fund will be used for the acquisition of equity participations in SACE S.p.A.

19/05/2020

Tax reliefs

Non-financial corporations

For companies with turnover up to €250 million and for self-employed workers, the final payments due for 2019 and the first installment of the advance payments for 2020 related to the regional tax on productive activities (IRAP) are cancelled.

19/05/2020

Public guarantees

Banking sector

The Decree-Law no. 34 provides for a State guarantee on newly issued liabilities of Italian banks, up to a nominal value of €19 billion and it introduces a public support scheme for the efficient management of compulsory administrative liquidation procedures of small banks, with total assets up to 5 billions (to be regulated by ministerial decree).

The Decree-Law no. 34 of the Government introduces the possibility of authorising, until 31 July 2021, contract amendments for state-guaranteed securitisations of non-performing loans. The amendments concern the possibility to suspend for one year the enforcement of the performance triggers .

19/05/2020

Tax reliefs

Non-financial corporations

Article 26 of L.D. of 19 May 2020 ("Rilancio") introduces - for companies with a turnover between €5 and €50 million that will implement a capital increase by the end of 2020 - a tax credit equal to 50% of capital losses exceeding 10%, up to 30% of the capital increase (up to €800.000) and the provision for the shareholder of deductibility of 20% of the amount invested (up to €2 million).

08/04/2020

Public guarantees

Non-financial corporations

Article 1 of L.D. of 08 April 2020 no. 23 (“Liquidità”) converted into Law of 24 April 2020 no. 40: the measure introduces the possibility for the Italian export credit agency (SACE S.p.A.) to provide public guarantees until 30 June 2021 in favour of banks, national and international financial institutions and the other parties authorized to exercise credit in Italy, for financing undertakings for a maximum total amount of EUR 200 billion, of which at least EUR 30 billion is allocated to support SMEs.

With art. 1, paragraphs 206 lett a) of the 2021 Budget Law (Decree 178/2020) the access to the guarantees issued by the SACE ("Garanzia Italia") was extended until 30/06/2021. Moreover, a new provision in paragraph 209 of the same Law, has been included according to which medium-sized companies (with a number of employees of no less than 250 and no more than 499) will no longer be able to access the guarantees of the Central Guarantee Fund from March 1, 2021, but will be admitted to the SACE's guarantee at the same favorable conditions offered by the Fund (ie: granting of guarantees free of charge, coverage percentage of 90 per cent and maximum guaranteed amount of loans of 5 million euros).        

17/03/2020

Tax deferrals

All sectors

The Law Decrees of 17 March ("Cura Italia"), 8 April ("Liquidità") and 19 May 2020 ("Rilancio") have repeatedly postponed the deadlines for payments related to VAT, taxes on income and social security contributions due in March, April and May. The deadlines for these tax payments differ depending on the measure. Some measures apply only to firms and self-emolyed that experienced a drop in turnover with respect to 2019 below given thresholds. The Law Decree of 14 August 2020 no. 104 has established the possibility to pay half of the due taxes in 24 instalments. Following the second wave of the pandemic, tax payments have been further postponed to 2021 (with the so called "ristori" decrees n. 137 of 28 October 2020, n. 149 of 9 November 2020, n. 154 of 23 November 2020 and n. 157 of 30 November 2020) for firms located in the areas or operating in the sectors mostly hit by limitations to the economic activity.

06/03/2020

Private moratoria

Non-financial corporations

1) First addendum of 6 March:  extension of the agreement "Accordo per il Credito 2019" for SMEs damaged by the Coronavirus outbreak.
The Italian banking association (ABI) and the employers’ associations extended the agreement to allow delaying the payment of loans’ instalments due by SMEs. For medium/long term loans, the postponement is up to 100 per cent of the residual maturity, for short-term loans up to 270 or 120 days, depending on the form of loans. The moratorium only applies to the payment of the principal component; borrowers pay interests during the moratorium period. The suspension is granted whithout additional costs or fees beyond those incurred by the bank against third parties. Banks can increase the interest rate up to 60 basis point, in relation to the higher costs connected to the moratorium implementation.
2) Second Addendum of 22 May: extension of the agreement "Accordo per il Credito 2019" as modified by the "Second Addendum of 22 May to "non SME" damaged by the Coronavirus outbreak and amendment of the eligible criteria for SMEs defined in the the agreement "Accordo per il Credito 2019" as modified by the first addendum (see below "eligibility criteria").
3) ABI circular of 26 June: amendment of the claim covered by the moratorium since it is applied to the whole instalment (principal and interest) and for "non SME" postoponement of the application deadline to 30.09.2020.
4) Third Addendum of December 17, 2020: the deadline to request a moratoria is extended to 31.03.2021 and the maximum period of suspension of loan payments is 9 months.

21/04/2020

Private moratoria

Households

1) New agreement of 21 April with customer unions for households moratoria ("Accordo in tema di sospensione della quota capitale dei mutui garantiti da ipoteca su immobili e dei finanziamenti chirografari a rimborso rateale")
The agreement allows borrowers to request the suspension of the principal referred to mortgages guaranteed by collateral on non-luxury properties and unsecured loans, for a period not exceeding 12 months (including through multiple suspensions); borrowers pay interests during the moratorium period. No fee is due for the moratorium. Intermediaries can apply more favourable conditions to borrowers. Previous banking moratorium initiaves linked to coronavirus can be considered covered by this initiative if they provide equal or more favourable requirements for borrowers.
2) ABI circular of 26 June: amendments of the claim coverage by the moratorium since it is applied to the whole instalment (principal and interest) and also to loans which have unpaid instalments until 31.01.2020; and postoponement of the application deadline to 30.09.2020.

06/04/2020

Private moratoria

Other

1) New agreement of 6 April with representatives of local administrations forpublic local entities moratoria ("Accordo Quadro ABI-ANCI-UIP")
The moratorium allows the entities in scope to request the suspension of the principal amount for instalments due in 2020. The original interest rate remains unchanged. The bank can offer better terms than the general terms of the memorandum.
2) ABI circular of 26 June: postoponement of the application deadline to 30.09.2020.

20/04/2020

Private moratoria

Households

1) New agreement of 20 April with  Italian association for consumer and real estate credit for households moratoria ("Moratoria COVID 19 per il credito ai consumatori")
The agreement allows borrowers to request the suspension of the full installments or, alternatively, only of the principal amounts. In the first case, at the end of the moratorium, clients have to pay: 1) the same number of remaining installments incorporating the increased amount; or 2) the same number/amount of remaining installments, except one  incorporating the increased amount; or 3)  an increased number of installments maintaining the original amount. In the second case, during the suspension,  only interests are paid; at the end of the  moratorium, clients resume the payment of the original number and amount of installments.
2) Amendment of December 2020: The deadline for the application to the moratium has been extended to March 31, 2021. The maximum period of suspension of loan payments is 6 months.

17/03/2020

Public moratoria

Households

Art. 26 of D.L. n.9/2020  extends the access to the "Solidarity Fund for residential mortgages related to the home purchase as a primary residency (also called Fondo Gasparrini)" to employees with a lay-off at least of 30 days. This extension is permanent.  The measure defines a temporary moratorium on residential mortgages, by a suspension of payments up to 18 months. The Fund covers 50% of the interests accrued during the suspension. Art. 54 of L.D. 17 March 2020 no. 18 (“DL Cura Italia”) converted into Law 27/2020, article no. 12 of L.D. 8 April 2020, no 23 ("DL Liquidità") converted into Law 40/2020 temporarily extends the operation of the Fondo Gasparrini  to self-employees and professionals who have suffered a reduction in earnings of at least 33% compared to the last quarter of 2019.
Some further small clarifications/modifications to art. 54 have been made with Article 12 of L.D. 08 April 2020 no. 23 (“Liquidità”) converted into Law  of 24 April 2020 no. 40. In particular, art. 12 allows for an extension of the operation of the "Solidarity Fund for residential mortgages related to the home purchase as a primary residency" (also called "Fondo Gasparrini") also to mortgages whose amortization period is below one year.

From 18/12/2020 the measure doesn't apply anymore to  self-employees and professionals who have suffered a reduction in earnings of at least 33% compared to the last quarter of 2019 and to the employees which have benefited from "Fondo di garanzia Prima Casa".
With the conversion of the “DL Ristori” into law on 24/2020 the extension of the simplified access to the moratorium has been extended until December 31, 2021. The access to the moratorium for mortgages whose amortization period is below one year has been extened until April 9, 2022 (conditional on the other requirements being satisfied).

19/05/2020

Other measures of fiscal nature

Other

Articles 115-117 of L.D. of 19 May 2020 no. 34 establishes a fund for cash advances to local governments and to entities of the national health service for the payment of trade debits due by 31 December 2019 towards their suppliers of goods and services. The fund amounts to € 12 billion and it is managed by Cassa Depositi e Prestiti (CDP S.p.A.). Local governments can apply for the cash advance until 7 July 2020 and have to pay their trade debts within 30-60 days after the receipt of the funds. Article 55 of the Law Decree of 14 August 2020 no. 104 has extended the deadline to apply for cash advances to 9 October 2020.

17/03/2020

Direct grants

Households

The L.D. of 17 March 2020 no. 18 ("Cura Italia") converted into Law of 24 April 2020 no. 27 introduces different measures in the form of direct grants to support income of households and of workers. In particular:
- it extends existing wage compensation schemes for employees;
- it introduces monetary transfers for self-employed workers and for specific categories of workers not included in the existing wage compensation schemes;
- it introduces transfers for workers that have reduced, suspended or ceased their working activity (the so called "reddito di ultima istanza");
- it extends the parental paid leave for workers with children below 12 years old or, alternatively, provides vouchers for baby-sitting services.
These measures have been further reinforced and extended with L.D. of 19 May 2020 no. 34 ("Rilancio") that has also introduced the so called "Reddito di emergenza" for households in need that do not benefit from other subsidies. These measures have been then further reinforced and extended with Law Decree of 14 August 2020 no. 104.
Following the second wave of the pandemic, the size and the beneficiaries of the transfers have been extended (with Decree Law n. 137 of 28 October 2020, Decree Law n. 149 of 9 November 2020, Decree Law n. 154 of 23 November 2020 and Decree Law n. 157 of 30 November 2020) to include workers in the sectors of tourism, sport and entertainment.

19/05/2020

Public guarantees

Non-financial corporations

Article 27 of L.D. of 19 May 2020 no. 34 ("Rilancio"): for companies with a turnover over €50 million, the so called “Patrimonio Rilancio” (Relaunch Fund) has been established for interventions in support of recapitalization for joint-stock companies registered in Italy, excluding banks and insurance companies (measure IT-036). The Fund is allowed to issue own debt securities. State guarantees up to €20 billion could be granted to holders of the securities issued by the Fund. The Fund has not been enacted yet.

17/03/2020

Public guarantees

Non-financial corporations

Article 49 of L.D. of 17 March 2020 no. 18 (“Cura Italia”) converted into Law of 24 April 2020 no. 27.
The same rules for the guarantee Fund for SMEs(measure IT-031) apply also to public guarantees granted by Istituto di Servizi per il Mercato Agricolo Alimentare (ISMEA) on loans to firms operating in the agriculture and fishing sector.

08/04/2020

Public guarantees

Non-financial corporations

Article 13 of L.D. of 08 April 2020 no. 23 (“Liquidità”) converted into Law of 24 April 2020 no. 40: the measure repeals article 49 of L.D. 17 March 2020 no. 18 (“Cura Italia”) converted into Law 27/2020 on the guarantee fund for SMEs ("Fondo di Garanzia per le PMI") .
The same rules for the guarantee Fund for SMEs(measure IT-025) apply also to public guarantees granted by Istituto di Servizi per il Mercato Agricolo Alimentare (ISMEA) on loans to firms operating in the agriculture and fishing sector. Resources initially allocated to the provision of public guarantees according to article 49 of L.D. no. 18/2020 ("Cura Italia") have been used to finance article 13 of L.D. no. 23/2020 ("Liquidità") and have been further extended by article 31 of L.D. of 19 May 2020 no. 34 ("Rilancio").

20/03/2020

CCoB

Banking sector

Bank regulatory requirements. In line with the EBA and ECB press release on actions to mitigate the impact of COVID-19 on the EU banking sector, Banca d’Italia issued a press release encompasing actions to alleviate the operational burden for banks, making use of the flexibility embedded in the regulation. Banca d’Italia will allow banks to operate temporarily below the level of capital defined by the Pillar 2 Guidance (P2G), the capital conservation buffer (CCB) and the liquidity coverage ratio (LCR).  Banca d’Italia is also envisaging to give banks some leeway in the remittance dates of some supervisory documents (i.e. ICAAP, ILAAP, etc)

09/04/2020

Reporting requirements

All sectors

Consob adopted two resolutions (n. 21326 e n. 21327) pursuant to a new Decree (Decreto imprese) which enhanced disclosure in connection with the acquisition of shareholdings in listed companies. Consob Resolution n. 21326 lowered the minimum thresholds for the disclosure of major shareholdings to 1% (instead of 3%), and 3% (instead of 5%) as to small/medium enterprises (SMEs), with respect to 104 selected issuers with widespread shareholding structure. Consob Resolution n. 21327 lowered the minimum thresholds relating to the "declaration of intentions" (i.e.: obligation to disclose investment objectives in relation to the following six months in the event of the acquisition of investments in listed companies), to 5%, with respect to 104 selected issuers with widespread shareholding structure. Both measures apply for three months, starting from April 11.

11/03/2020

Reporting requirements

Pension funds

COVIP's communications to pension funds:
1) Forbearance of end-of-year deadlines. COVIP provided the postponement of the terms for pension funds to draft or approve the 2019 annual reports (to the end of June) and the deadline to send the periodic communication to pension members (2 months) and some annual reporting to COVIP (2-3 months).
2) Ensuring continuity in governance - easing of remote participation to Board meetings, by providing guidelines.

25/03/2020

Reporting requirements

All financial sectors

CONSOB granted intermediaries a 60-day extension of the deadlines for supervisory reporting.

27/03/2020

Dividend distribution policy

Banking sector

Dividend distribution and remuneration policies for Italian LSIs: in order to reinforce previous actions on regulatory requirements, Banca d'Italia – coherently with the ECB Recommendation on dividend distribution for SIs – recommended that, at least until 1 October 2020, Italian LSIs:
- will not pay out any dividends, including the distribution of reserves, and will not take on any irrevocable commitments regarding the payment of dividends for the financial years 2019 and 2020; - will refrain from carrying out share buy-backs aimed at remunerating shareholders.
LSIs that do not intend to comply with the Recommendation must explain the underlying reasons. Banca d'Italia will continue to monitor the economic situation and will assess the advisability of suspending dividend distribution further after 1 October 2020.
In the same direction, banks are also required to adopt a prudent and farsighted approach in setting their variable-remuneration policies.

30/03/2020

Reporting requirements

Insurance sector

In line with EIOPA Recommendation on supervisory flexibility regarding deadlines for supervisory reporting (https://www.eiopa.europa.eu/content/eiopa-issues-recommendations-supervisory-flexibility-regarding-deadlines-supervisory_en ) IVASS allowed undertaking to postpone a number of reporting requirements and to concentrate efforts on monitoring and assessing impact of Coronavirus/COVID-19 and maintaining business continuity.

30/03/2020

Dividend distribution policy

Insurance sector

IVASS has sent a letter to the insurance and reinsurance undertakings with head office in Italy requesting them to use extreme caution, at solo and group level, in the distribution of dividends and in the payment of the variable remuneration component of key managers. Compliance with these recommendations, will be closely monitored by the Institute.

06/04/2020

Other measure

Pension funds

Ad-hoc survey of major pension funds to draw information on how the COVID-19 impact was addressed with regard to: 1) business continuity; 2) collection of contributions; 3) early withdrawals; 4) review of investment strategy so to take into account the fall in equity prices and the volatility of markets.

12/03/2020

Short selling ban

Securities and markets

According to the EU Regulation on short selling, Consob laid down the temporary ban on short selling on 85 Italian shares (the ban came into force on Friday 13 March 2020).
http://www.consob.it/web/consob-and-its-activities/news-in-detail/-/asset_publisher/kcxlUuOyjO9x/content/press-release-12-march-2020-short-selling-hp/718268

16/03/2020

Short selling ban

Securities and markets

Consob decided to renew the prohibition of short selling in 20 Italian shares pursuant to Article 23 of Regulation (UE) no. 236/2012.

http://www.consob.it/documents/46180/46181/press_release_20200316.pdf/fc96bf05-447e-4219-aad6-ea5c7426c190

17/03/2020

Short selling ban

Securities and markets

Starting from the session of 18 March, Consob introduced a prohibition of short selling on all shares traded on the Italian regulated market (Resolution n. 21303 of March 17, 2020) pursuant to Article 20 of Regulation (UE) 236/2012. Any form of bearish speculative transaction is banned, including through the use of derivatives or other financial instruments. Bearish intraday trades are also prohibited. The ban applies for three months, starting from March, 18.On May 15, 2020 Consob, in consultation with ESMA and the Austrian, Belgian, Greek, French and Spanish authorities which have taken similar action, resolved the early termination of the ban on net short positions, which expired on 18 May at 23:59 pm (Consob Resolution no. 21367 of 15 May 2020). Consob continues to carefully monitor the situation in financial markets and remains in close contact with other authorities.

17/03/2020

Other measure

Securities and markets

Introduction of a temporary regime of enhanced transparency on holdings in the 48 Italian listed companies with the largest capitalization and widespread shareholdings. The provision (Resolution n. 21304 of March 17, 2020 only Italian version), adopted pursuant to article 120 paragraph 2-bis of the Consolidated Law on Finance (TUF), lowers the minimum thresholds triggering the duty to notify major holdings in a listed company. The new threshold is set at 1% for non-SME companies and 3% for SMEs.

19/05/2020

Other measure

All financial sectors

Extension of the maximum amount of investments in financial instruments issued by unlisted firms to include in the Long Term Investment Plans (so called PIRs) portfolios run by OICVM and insurers. Tax benefits for PIR customers are extended in time  (Article 136 of the Decree Law no. 34/2020).
With the 2021 Budget Law (Decree 178/2020) a tax credit is established for losses deriving from SMEs PIR, provided that these instruments are held for at least 5 years and the tax credit does not exceed 20% of the amounts invested in the same instruments (the rule applies to plans established from 1 January 2021 and for investments made by 31 December 2021).

09/04/2020

Other measure

Non-financial corporations

Close scrutiny, on the basis of complaints, of on-line unauthorised offers and promotions of financial products or investment services also in view to contrast coronavirus related scams. Consob is enabled to order the black out of the relevant web-sites and publish warnings, see also Consob website (www.consob.it) section "Watch out for scams!"

19/05/2020

Other measure

All financial sectors

Simplified operating procedures for the conclusion of the financial and insurance contracts and the related communications to the costumers

19/05/2020

Other measure

All sectors

Simplification of public administration proceedings that will apply from 19 May until 31 December 2020.

02/03/2020

Other measure

All non-financial sector

Emergency measures and interventions to support the most critical areas. Small-amount measures focussing on the formerly “red and yellow zones” (parts of northern Italy). No impact on the public finances, as resources already available under the current legislation.  Among them: refinancing of the revolving fund in support of export companies. As the restrictions were extended on the entire national territory, the government adopted new economic reliefs to be applied to the entire Nation.

03/04/2020

Other measure

Insurance sector

IVASS published a warning, drawing the attention of the operators on the fact that the insurance business is included among the commercial activities exempted from the suspensions stated by the Government for other commercial activities. Therefore, in relation to the commitments undertaken and compatibly with the emergency situation, the operators are required to arrange their activities in order to be able to guarantee the continuity of services and the best protection of the consumers’ interests (e.g. to make an extensive use of e-mail and electronic means of communication for sending communications to customers, reserving the use of the postal service - whose operations have been significantly reduced as a consequence of the health emergency - to cases where this is strictly indispensable).
In line with the indications provided by EIOPA on 1th April 2020, supervised entities are recommended to make sure that insurance activities continue to take place correctly and in the interest of consumers, despite the exceptional situation, and in particular:
- to provide timely and clear information to customers regarding the organizational measures taken to ensure the continuity of services and correct contractual relationships, promptly reporting any operational changes and situations of impediment to the ordinary management of relationships;
- to keep specific evidence of any impediments to the smooth running of the business and of the remedies adopted to safeguard the rights of customers who could be affected by delays or misunderstandings in the communications directed to them;
- to take into due consideration the difficulties that consumers may also encounter in fulfilling their obligations, as a consequence of the measures to contain the contagion from COVID-19.On April 3 last, IVASS, in response to the highlighted operational and management problems of the postal service, asked companies to give priority to the use of electronic mail and electronic means of communication for sending communications to customers, reserving the use of the postal service only in cases where this is strictly necessary. Given that  the critical condition represented at the time has disappeared IVASS ordered  the reinstatement of the "normal operating  mode" of postal services. Companies are nevertheless called upon to guarantee the quality of services by offering users the choice of the means of communication which they consider to be in their best interests.

08/04/2020

Other state of emergency measure

All sectors

The Government adopted the Decree-Law no. 23 introducing new rules in order to guarantee business continuity:
Measures to simplify procedures for signing contracts and communications to consumers.
• Deferral of the entry into force of the Business Crisis Code and Insolvency (pursuant to Legislative Decree no. 14 of 12 January 2019) to 1 September 2021.
• Suspension of insolvency proceedings.
• Temporary derogations to some rules regarding companies capital reduction, financing to companies, balance sheet principles.
• Suspension of the expiration term of credit instruments.

08/04/2020

Other measure

All sectors

With the Decree-Law no. 23, the Government introduces new rules for disclosure of controlling shareholding in strategic relevance sectors (including, in the financial sector, credit and insurance). In this regard, the following events are subject to notification:
a) any shares acquisition which have as their effect changes in the ownership, control or availability of the assets or a change in their destination;
b) any shares acquisition by foreign entities, including those belonging to the European Union, such as to determine the permanent establishment of the purchaser by reason of the acquisition of the control of the company; as well as purchases of equity investments by non-EU persons, which attribute a share of voting rights or capital of at least 10%, taking into account the shares or quotas already directly or indirectly owned, and the total value of the investment is equal or in excess of EUR 1 million; acquisitions which result in the thresholds of being exceeded for 15%, 20%, 25% and 50%. In cases of breach of the notification requirements, even in the absence of notification, the Government may initiate proceedings in order to exercise golden powers. The measure, initially intended to be applied until 31 December 2020, has been extended until 30 June 2021 through an amendment to Art. 4-bis, par. 3-bis and par. 3-quarter of Decree-Law 105/2019.

09/04/2020

Other measure

All sectors

Consob published a warning note drawing the attention of the board members, managers responsible for drafting the listed companies’ financial statements, auditors and audit committees on the need of complying with the financial information standards. In relation to the financial information to be delivered in the accounting reports and in the prospectuses, the warning urges companies to highlight with the greatest possible transparency - as required by international accounting standards - the possible effects had by the COVID-19 health emergency on company activities, with reference both to the financial statements at 31 December 2019 in approval and to subsequent reports. A similar warning is also addressed to the auditors, in particular as regards the evaluation of the information provided in the financial statements on the effects of the epidemic. Finally, the warning recommends the control bodies of listed companies, also in their role of audit committee, to strengthen information flows and exchanges with the administrative bodies and communication on a timely basis with the auditors during this period.

09/04/2020

Other measure

All sectors

Warning alerting against possible investment scams related to the coronavirus outbreak (Covid-19), including fraudulent on-line offerings of securities of phantom companies allegedly containing or curing the coronavirus, as well as high-yield investment opportunities, as virtual currencies supposedly linked to the spread and lethality of viral contagion.

10/04/2020

Other measure

All sectors

Consob issued Communication n. 3/2020 of April 10th, 2020 that gives operational guidance on the managing of the next ordinary and extraordinary meetings, following the new provisions of the "Care Italy" ("Cura Italia") Law-Decree of 17 March 2020 n. 18 mentioned above. Listed companies are invited to ensure that all shareholders are enabled to participate and exercise remote voting, making use of at least one of the various tools indicated in article 106 of the "Care Italy" Decree, including electronic or mail voting, remote intervention via IT connection, recourse to the representative appointed by the company (i.e. Rappresentante Designato).

10/04/2020

Other measure

All non-financial sector

Banca d’Italia issued a communication to banks and financial intermediaries drawing the attention on the central role of the financial system to transmit the effects of governmental measures, and to avoid detrimental impacts on clients.
Recommendations issued include:
Ensuring the opening of branches in case services cannot be provided by distance;
Addressing the staff with clear and consistent instructions on how to help customers willing to benefit from the emergency measures adopted by the Government;
Providing full disclosure and proper assistance to customers about emergency measures;
Reimbursing instalments unduly charged to clients who applied for house loans moratorium, and reverting any detrimental effect incurred.
Banca d’Italia also asked to strengthen remote channels for assistance (telephone, website), providing detailed recommendation about the structure and the content of web sites sections dedicated to the Covid-19 emergency.
With the same communication, Banca d’Italia also issued recommendation on the implementation of anti money laundering safeguards, recalling to calibrate AML obligations according to the emerging ML/TF risks associated with COVID-19.  In this respect, specific attention is requested in order to prevent misuse of financial public aid to individuals and corporations.

16/04/2020

Other measure

All sectors

UIF issued a Communiqué drawing the attention of AML/CFT obliged entities and their staff to the new threats and risks to which they may be exposed and to the need to promptly detect suspicions related to the Covid-19 emergency and report them.
Frauds, exploitation scams, trafficking in counterfeit medicines or sanitary equipment, illegal speculations, malicious fundraising, usury are examples of emerging or evolving threats. Attention is also drawn on the risk of corruption or misappropriation of funds from governments or charities, particularly as a consequence of abuse of measures aimed at providing funding liquidity to individuals and firms; the need for adequate due diligence and monitoring on the recipients is recalled. In addition, deteriorated economic conditions and perspectives may allow criminals to more easily abuse or take hold of, or taken over, ailing enterprises or individuals that face liquidity or solvability problems.
The use of IT tools and online facilities may pose heightened risks. At the same time, obliged entities are invited to leverage on sophisticated technology to facilitate anomalies’ detection and prompt reporting.
The Communiqué also cross-references more general “red flags” and instructions, provided by UIF in the past and still particularly relevant in the current situation.

17/03/2020

Other measure

All sectors

Postponement of the deadlines for the approval of the  2019 financial statements by the General Assembly (Art.106, par.1, Decree-Law "Cura Italia" no. 18/2020, converted with amendments by Law no. 27/2020)

17/03/2020

Other measure

Insurance sector

Measure relating to the lifetime of the compulsory insurance contracts against civil liability in respect of the use of motor vehicles and craft: until July 31 2020, extension of a further fifteen days (of the current period of fifteen days) until the insurance company is required to maintain the guarantee provided by the previous insurance contract until the new policy comes into force. On 24th April 2020 the Parliament approved an amendments to the decree Law adopted by the Government and issued on 17th March 2020, which clarifies that the extensition of fifteen days applies both to the contracts expired and still not renewed and to contracts expiring in the period between 21th February and 31th July 2020.

17/03/2020

Other measure

Insurance sector

IVASS issued first measures to give some relief to insurance firms and intermediaries on some operational regulatory requirements

17/04/2020

Other measure

All sectors

Banca d'Italia and IVASS are reinforcing the protection of their internal IT systems and, as part of their institutional tasks, they are helping to guarantee the security of the financial and insurance systems. They are also renewing their commitment to protecting users of digital financial services, with a particular focus on people and firms that did not use the Internet much before the epidemic.
Initiatives in this field mainly include: the establishment in the Banca d'Italia of Computer Emergency Response Team (CERT) dedicated to the collection of information regarding vulnerabilities and cyber incidents; deeper evaluation of different types of cyber threats, infosharing with technological partners, banking intermediaries and insurance companies; enhancing security awareness.

19/05/2020

Health sector measure

Other

With Decree-Law no. 34 the Government continues supporting the Health System and Civil Protection Force with €5.5 billion (for the reorganization of the hospital network and  the refinancing of the National Emergency Fund for Civil Protection activities).

23/03/2020

Other measure

Insurance sector

In order to ensure an accurate examination of complaints and requests for information made by policyholders during this extraordinary time of health emergency, IVASS has granted insurance companies an extension of the time limits to respond to customers. The insurance undertakings are allowed:
1. to respond to complaints within 75 days, instead of the expected 45;
2. to respond to customer requests for information within 35 days instead of the expected 20 days.

24/04/2020

Other measure

Insurance sector

On 24th April 2020 the Parliament approved amendments to the first decree Law “Cura Italia” adopted by the Government and issued on 17th March 2020, stating the possibility to suspend MTPL insurance contracts during its effectiveness, given that the restriction to the mobility adopted by the Government has significantly reduced the risk for insurance undertakings. In particular, upon request by the insured persons, the contract can be suspended, for the period requested and up to 31 July 2020. This suspension operates from the day on which the insurance company received the suspension request and until 31 July 2020 and the insurance companies cannot apply penalties or charges to the insured person requesting the suspension. The duration of the contracts is extended by a number of days equal to those of suspension. It is specified that during the suspension period the vehicle for which the insured has been suspended cannot circulate or be parked on a public road or on an area equivalent to a public road, given that it is temporarily not covered by the compulsory insurance required by law. The decree Law, as emended by the Parliament on 24th April, will be published later this week and will be into force immediately.

24/04/2020

Other measure

Insurance sector

On 24th April 2020 the Parliament approved an amendments to the first decree Law “Cura Italia” adopted by the Government and issued on 17th March 2020, stating the possibility to suspend MTPL insurance contracts during its effectiveness, given that the restriction to the mobility adopted by the Government has significantly reduced the risk for insurance undertakings. In particular, upon request by the insured persons, the contract can be suspended, for the period requested and up to 31 July 2020. This suspension operates from the day on which the insurance company received the suspension request and until 31 July 2020 and the insurance companies cannot apply penalties or charges to the insured person requesting the suspension. The duration of the contracts is extended by a number of days equal to those of suspension. It is specified that during the suspension period the vehicle for which the insured has been suspended cannot circulate or be parked on a public road or on an area equivalent to a public road, given that it is temporarily not covered by the compulsory insurance required by law. The decree Law, as amended by Parliament on 24th April, entered into force on 30th April.

29/03/2020

Other measure

All sectors

The Ministry of Economy and Finance, the Ministry of Economic Development, the Bank of Italy, the Italian Banking Association (ABI), Mediocredito Centrale S.p.A. (MCC), and the Italian Export Credit Agency (SACE) have formed a task force to oversee the efficient and rapid implementation of the liquidity support measures approved by the Government with the Decree Law 18/2020 and extended with the Decree Law 23/2020.

30/07/2020

Dividend distribution policy

Insurance sector

Taking account ESRB  recommendation, of 27 May 2020, and following up to  the letter sent on March, IVASS recommends undertakings to refrain, at least until 1 January 2021, from:
       making a dividend distribution or giving an irrevocable commitment to make a dividend distribution;   buying back ordinary shares;        creating an obligation to pay the variable remuneration component to key managers.

30/06/2020

Other measure

Insurance sector

By notices published in its website on 23 March and 3 April 2020 the Institute temporarily granted insurance companies and intermediaries concerned an extension to the deadlines established by Regulations no. 24/2008 and no. 41/2018 to reply to the complaints and inquiries by policyholders and parties entitled to insurance benefits.
The extension was a response to the operational difficulties arising from the COVID-19 epidemiological emergency.
Given the sensitivity of this issue, which has a direct impact on the rights and interests of consumers, and in light of the end of the most acute phase of the operational emergency for undertakings and intermediaries - which justified the temporary extension of the response times - the Institute orders the reintroduction of the normal time limits for the management of complaints and for the inquiries that the undertakings will receive starting from 1 July.

28/07/2020

Dividend distribution policy

Banking sector

 Given the persistent economic uncertainty linked to the COVID-19 pandemic, the Bank of Italy deems it necessary to update the indications provided last March, in line with the provisions of the ESRB Recommendation.
The Bank of Italy recommends that, until 1 January 2021:
a) less significant banks: 1) refrain from distributing dividends for the financial years 2019 and 2020 (including the distribution of reserves) and from making any irrevocable commitment to pay out dividends for the same financial years; 2) refrain from making share buybacks aimed at remunerating shareholders.
b) investment firms subject to the CRR/CRD IV capital requirements: 1) refrain from distributing dividends for the current financial year (including the distribution of reserves) and from making any irrevocable commitment to pay out dividends for the current financial year; 2) refrain from making share buybacks aimed at remunerating shareholders.
In the same direction, banks and investment firms subject to the CRR/CRD IV capital requirements are also required to adopt an extremely prudent approach until 1 January 2021 with reference to variable-remuneration policies.

08/07/2020

Reporting requirements

All sectors

By Resolution n. 21434, Consob extended the effects of Resolutions n. 21326 and n. 21327 of April 9, 2020 by three months, from July 12, 2020 until October 12, 2020, unless revoked early. Resolutions n. 21326 and n. 21327 introduce further thresholds for disclosure of significant holdings and declarations of intent in issuers with a particularly broad shareholder base. The list of issuers to which the said Resolutions apply is available on Consob website.

16/07/2020

Other measure

All sectors

Consob published a warning note drawing the attention of actors involved in the process of preparing financial reporting in accordance with international accounting standards on
the recommendations provided by ESMA in its public statement of May 20, 2020 on “Implications of the COVID-19 outbreak on the half-yearly financial reports”. In particular, the warning  the information to be given in half-yearly financial reports as at June 30, 2020 regarding the effects of the Covid-19 pandemic.

30/07/2020

Other measure

All sectors

Consob published a warning note drawing attention of
issuers of financial instruments widely distributed among the public and of issuers of financial instruments traded on multilateral trading facilities that prepare their financial reporting in accordance with the Italian Civil Code and national accounting standards on the information to be disclosed to the market with regard to the use of exemptions to preserve the going concern provided for by legislative measures introduced by the Government to address the impact of Covid-19 emergency. The warning is intended to ensure transparency, allowing investors to have an adequate set of information to guide their investment choices and intermediaries to provide information on the risks associated with the proposed investments, taking into account that those issuers are subject to Consob supervision regarding disclosure to the market and market abuse. 

07/10/2020

Reporting requirements

All sectors

By Resolution n. 21525, Consob extended the effects of Resolutions n. 21326 and n. 21327 of April 9, 2020 (as already extended by three months pursuant to Resolution n. 21434 of July 8, 2020), by further three months, from October 13, 2020 until January 13, 2021, unless revoked early. Resolutions n. 21326 and n. 21327 introduce further thresholds for disclosure of significant holdings and declarations of intent in issuers with a particularly broad shareholder base. The list of issuers to which the said Resolutions apply is available on Consob website.

01/10/2020

Other measure

Insurance sector

Considering the importance that professional training has for consumer protection, IVASS agreed on an extension of the deadline to meet the obligations under current legislation recognizing the organizational complexities resulting from the lockdown period and, more generally, the health emergency linked to COVID-19.

29/12/2020

Dividend distribution policy

Insurance sector

IVASS, in aligning with the renewed EIOPA recommendation to companies to use extreme caution in their capital management policies and the ESRB's recommendations (ESRB 15/2020), requests companies  proposing to carry out dividend distributions, buy-backs of own shares or variable remunerations, with regard to both 2019 and to the current year, to carefully and responsibly assess their impacts and to previously contact IVASS to verify consistency with the objectives of the recommendation. Indeed, any dividend distributions, buy-backs of own shares or variable remunerations should not exceed thresholds of prudency; the potential reduction in the quantity or quality of their capital should not reduce own funds to a level inappropriate to their risk exposure; this with a view to safeguarding insurers' ability to absorb, also in the future, the impacts of the epidemiological emergency on their business models and solvency, liquidity and financial position
IVASS will closely monitor compliance with these recommendations. In order to ensure a uniform approach at European level, IVASS shall take into account EIOPA’s recommendations and shall cooperate with the other national authorities supervising over groups based in more than one EU Member State

01/01/2021

Other state of emergency measure

Insurance sector

The application of article 33 of the Decree law no. 34/2020, concerning simplified measures for the conclusion of insurance and financial contracts, has been extended until the 31th of March 2021, according with Art. 19 of the Decree-Law no. 183/2020 (so called "Decreto Milleproroghe")

01/01/2021

Other state of emergency measure

All sectors

The application of article 106, par. 1 of the Decree law no. 18/2020, concerning the postponement of the deadlines for the approval of the  2019 financial statements, has been extended until the 31th of March 2021, according with Art. 3, par. 6, of the Decree-Law no. 183/2020 (so called "Decreto Milleproroghe")

16/12/2020

Dividend distribution policy

Banking sector

In light of the current economic situation, given that the impact of the pandemic on banks’ balance sheets has not yet manifested itself in full and coherently with the ECB and ESRB– Bank of Italy issued its third recommendation on dividend distribution and remuneration policies for Italian LSIs, following the ones issued last 27 March and last 28 July.
In particular, at least until 30 September 2021, it is recommended to:
- refrain from deciding on or paying out dividends/cash pay-out reducing the quantity or quality of Common Equity Tier 1 capital or limit the amount to no more than 15 per cent of the accumulated profit for the financial years 2019 and 2020, or no more than 20 basis points in terms of the Common Equity Tier 1 ratio, whichever is lower;
- refrain from deciding on or paying out provisional dividends/cash pay-out in relation to profit for 2021;
- exercise extreme prudence in calculating variable remuneration.
Banks that intend to pay out dividends/cash pay-out should first verify their capital adequacy and their internal capital generation capacity, current and forward-looking, taking into account the impact of the pandemic on asset quality and on profitability, and should then contact the Bank of Italy to assess whether the level of distribution can be considered prudent.

16/02/2021

Other measure

All sectors

In line with the April 2020 Warning Notice on the matter, Consob published a new warning note (1/21) requesting an enhanced disclosure concerning the Covid-19 impact (i) by supervised issuers, supervisory bodies and audit firms in relation to the 2020 financial statements prepared in accordance with international accounting standards; (ii) by companies that publish 2020 non-financial statements; (iii) by issuers with listed shares and by supervisory bodies at shareholders' meetings for capital increase resolutions; (iv) by those responsible for drafting takeover documents and prospectuses; (iv) by issuers subject to the European Regulation on Market Abuse. Especially, in the preparation of the 2020 financial statements, Consob has recommended issuers to follow the effects of the ESMA document on the 2020 common European enforcement priorities of 28 October 2020 and the areas specified thereby. As a novelty to the Warning Notice of 9 April 2020, Consob has highlighted the necessity to disclose in non-financial statements Covid-19 impact on sustainability matters and the related mitigating actions taken by the subjects obliged to this declaration.

15/03/2021

Other measure

All sectors

Consob issued a warning notice (4/21) on information related to the impact of the pandemic to be provided in the 2020 financial statements drawn up on the basis of the provisions of the Civil Code and national accounting standards (instead of international accounting standards). The warning notice is addressed to issuers of financial instruments widely distributed among the public; issuers of financial instruments traded on MTF/OTF; auditing companies and control bodies. In particular, by updating the previous measure on the matter (see previous row) Consob has warned issuers to follow the updated indications set by the Italian Accounting Setter (OIC) in March 2021. Consob clarified, among other, that the financial statements must also include specific information on any use by the issuer of the special measures introduced in Italian legislation to address the Covid-19 pandemic and to preserve business continuity (such as the right to suspend the annual depreciation of tangible and intangible fixed assets, the possibility of not devaluing the securities recorded under current assets, the right to revalue corporate assets and equity investments).
Issuers are also requested, among other, (i) to pay a specific attention to the planning process put in place, in order to ensure that budgetary assessments are consistent and appropriately reflect the available internal and external variables; (ii) to provide updated information in the report on operations on the impacts of the pandemic on the company’s situation and outlook. Moreover, the warning notice draws the attention of auditors to the need to verify the impacts deriving from the effects of the pandemic in budgetary assessments (with a particular regard to the accounting estimates and to the completeness and correctness of the disclosures provided in the financial statements).

16/02/2021

Other measure

All sectors

Consob published a warning notice (2/21) addressed to crowdfunding service providers recommending disclosure of information concerning any update on the offers and on Covid-19 implications on the sustainability of the projects and the related organisational measures adopted by providers. This measure updates a previous Consob warning issued in march 2020 (n. 2/20).