On Oct. 15, ITA GVT issued DLgs 184 transposition of ESAP legislation.
ITA GVT published DLgs 184 of Sep. 25, 2026 transposition of Directive 2023/2864 and adaptation of national law to Regulations 2023/2859 and 2023/2869 on ESAP.
Follows Mar. 2026 EC took action to ensure complete, timely transposition #294790.
Follows Mar. 2026 ITA GVT issued decree to adapt TUF text to EU law, see #289074.
Overview
Decree based on art 22 European Delegation Law 2024 Law 91/2025, TUF, TUB, etc.
Provisions implementing Directive 2023/2864 impact on DLgs 142/2005 (see art 2).
Rules transposing Art 9 Dir 2023/2864 which amends Accounting Dir 2013/34 (art 3).
Art 4 covers implementation of art 10 of ESAP Dir re amendments to CRD IV while art 5 does the same but related to art 11 which relates to BRRD Dir 2014/59.
Art 6, in turn, implements art 15 of ESAP Dir re changes made to IFD Dir 2019/2034.
Art 7 deals with adaptation of national law to Reg 2023/2869 while art 8 focuses on the notification to ESMA of designation of collection bodies (and relevant dates for it).
Art 9 states that any legal entity subject to obligation to submit information to ESAP must first obtain legal entity identifier, in accordance with Art 7.4b) of Reg 2023/2859.
Art 10 details financial neutrality clause but does not set express entry into force date.
Effectiveness
Due to internal rules and lack of express in force date, new decree applies on Oct. 30.
Regulators
ITA GVT
Entity Types
B/D; Bank; Corp; Ins; Inv Co
Reference
OG 240, 26G00202, 10/15/2026; DLgs 184/2026, 9/25/2026; Law 91/2025; ESAP Dir 2023/2864, Reg 2023/2859, Reg 2023/2869
