Article 129 Italian Banking Act ex post reporting repealed: final filings and next steps

The FE129 reporting portal will be decommissioned (no earlier than January 31, 2027), after which past reports will no longer be accessible through it.

The cutoff is event-based

The Repealing Act applies to reports relating to events occurring on or after January 1, 2027. As the Bank of Italy clarified in its consultation feedback, what matters is the date of the event triggering the reporting obligation, not the date of the filing. 

Notably, based on the clarifications provided by the Bank of Italy:

• Still reportable: events occurring on or before December 31, 2026, namely:
  • Issuance and offering reports: where a prospectus or final terms are filed with the competent authority or, if no filing is required, the settlement or issue date occurs, on or before December 31, 2026
  • Quarterly reports: the last reportable calendar quarter is the one ending on December 31, 2026
  • Placed or subscribed amounts: for placements or offers ending on or before December 31, 2026
  • Early redemptions: where the settlement date of the redemption occurs on or before December 31, 2026
• Out of scope: any triggering event occurring on or after January 1, 2027

Programs' drawdowns and transactions spanning year-end therefore need close monitoring.

What to do now

• Identify all relevant events (e.g., prospectus/ final terms filings, settlements, issues, closings of placements and offers, and early redemptions) expected to occur by December 31, 2026 and confirm the related filings and deadlines.
• Calendar the final filings due under the residual regime.
• Update compliance manuals, transaction checklists and syndicate and deal documentation to reflect the end of the regime.

The Repealing Act removes a recurring compliance layer for the Italian capital markets, but the current regime applies in full to events occurring until year-end, with some limited residual filings continuing into beginning of 2027.