On top of this Italy requested waivers that allow usage of some legacy formats and niche products until 1 st February 2016.

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1 Since 1 st February 2014, SEPA became a reality and succeeded in harmonising the European payment landscape. However, in order to support strong local market practices, some local flavours remain applicable in each country. In some others, the migration of specific products still have to be completed. This document will help you understand the local specifics applicable in Italy. Intending to provide a global picture of the transition to SEPA, it also describes the elements that permitted the migration from the legacy means of payment. POST MIGRATION STATUS The European authorities agreed on allowing banks and other payment providers to process payments that differ from the SEPA format until 1 st of August Each Member State has taken a position towards the application of this proposal. Italy reused the proposed date of 1 st of August 2014 for the migration of both credit transfers and direct debits. The main market specificity of Italy lies in its current interbank system called AEA (Allineamento Elettronico Archivi, meaning Electronic Database Alignment). This system supports many interbank services related to all payment means. With the migration to SEPA, this system has been replaced by its successor SEDA (SEPA Electronic Database Alignment), which will continue playing the same role but for SEPA compliant products. On top of this Italy requested waivers that allow usage of some legacy formats and niche products until 1 st February 2016.

2 Italy was supporting two credit transfer formats: the BONI PC and the BONI PE. Description Validity BONI PC Domestic format for domestic credit transfers Waived until the 1 st February 2016 After that date, BONI PC will remain available for urgent domestic credit transfer and cheques issuing BONI PE Domestic format for international credit transfers Waived until the 1 st February 2016 Remains in use for other currencies than Euro or towards beneficiaries out of the SEPA zone pain.001 is the XML standard used for communications between the debtor/initiator and their bank. In addition to considering the format provided by the EPC, two specific points must be taken into account: pain.001 currently exists in 3 versions. A company starting its migration today should implement the last version pain as indicated in the Rulebook 7 (downloadable from the EPC website). Beside the traditional pain.001, the local consortium CBI (Customer to Bank Interaction) has described a new message type that is similar to the pain.001 ISO, but also introduces some local particularities. The CBI format is the only one accepted to use within the CBI Network. For corporates, the main addedvalue of using the format and this network is that it allows to send all payment flows (multi-bank), which will then be routed to the appropriate banks for processing. This service allows corporates and consumers to re-route payments that concern an existing account to another (newly opened) account. Once requested, this service is operational for transfer from the old bank to new one: - Standing orders - Credit transfer received within 12 months. The service works for both incoming and outgoing transactions.

3 To be effective, it requires that both banks (bank of the original account and bank of the new account) adhere to the AOS. SEPA Direct Debits (SDD) Italy was supporting two domestic direct debit products, RID Ordinari and RID veloci, that were phased out on the 1 st August Thanks to a local waiver, the format to initiate SDD collections has been replaced by an enriched standard based on the old RID, containing all the required SEPA information allowing to initiate a SDD. Beside this, two products have been declared as niche products and remain available until the 1 st February 2016: the RID for financial transactions and the fixed amount RID. They can therefore be instructed through the old RID standard (not enriched). A few other means of payment are outside the SEPA scope: RiBa, MAV, RAV and Bollettino Bancario. RID Ordinari RID Veloci RID for financial transactions fixed amount RID RiBa, MAV, RAV, Bollettino Bancario Description Domestic format for domestic direct debits Domestic format for B2B domestic direct debits Domestic format for financial transactions Domestic format for domestic direct with pre-determinate fixed amount Other means of collection Validity Both products have been phased out. The enriched RID format remain allowed until the 1 st February 2016, to initiate SDD. Niche product The product is maintained as today until the 1 st of February 2016 Niche product The product is maintained as today until the 1 st of February 2016 Not in scope of SEPA Before the SEPA end-date, banks were using a specific process supported by the AEA (Electronic Database Alignment) which ensured a validation of new mandates by the debtor. The service was initiated either by the creditor or the debtor: - Creditors inform their bank of the new mandate, which informs the debtor s bank via AEA. From then on, the debtor s bank considers the mandate active and accepts the following collections. - Debtors inform their bank of the new mandate via their banking channel or directly via their branch. In such case, the debtor s bank directly informs the creditor of the readiness of the mandate. The service provides both debtor and creditor with protection against any fraudulent collection and drastically reduces the amount of rejections. It remained active until the 1 st February 2014 for RID ordinari and RID veloci, while for financial transactions rid and fixed amount rid it will remain active until the 1 st February The Italian banking association decided to set in place a successor of AEA dedicated to SEPA transactions: SEDA, which stands for SEPA Electronic Database Alignment.

4 SEDA is usable by both Italian and non-italian creditors, assuming the service is provided by their bank. From the creditor point of view, the main features of SEDA are : - Possibility to perform a check on the debtor s information: it is possible to verify the validity of a debtor s account, but also ensure that the person signing the mandate (identified by its fiscal code) has well the rights to authorize debits on the indicated account. - Account Information update: if the debtor changes of account within the same bank (for instance because his local branch is closed), the new account information will directly be provided to the creditor - B2B mandate confirmation: once a B2B mandate is validated by a debtor, the creditor is automatically notified SEDA can be used both in debtor and creditor mandate flows: - Credit mandate flow: the creditor introduce the mandate in SEDA by sending a dedicated XML file - Debtor mandate flow: the mandate introduction is performed by the debtor s bank SEDA connectivity is mandatory for banks present in Italy on debtor side. It is optional on the creditor side, therefore if you wish to use it, make sure the service is supported by your bank. Beside the traditional pain.008, the local consortium CBI (Customer to Bank Interaction) has set a new message type that is similar to the pain.008 ISO, but also introduces some local particularities. As for SCT, the main added-value of using the CBI format and the related network is that it allows to send all payments/collections flows (multi-bank), which will then be routed to the appropriate banks for processing. In order to use SEPA direct debit, the first administrative step you must take is getting a SEPA Creditor Identifier. This number will identify your company wherever you will be collecting within the SEPA zone. Note that you can request one SEPA CI for each of your business activities. Contact your BNP Paribas point of contact to get a SEPA Creditor Identifier. The bank will ensure its correct calculation according to the Italian standard. The Italian format is the following: IT97ZZZA1B2C3D4E5F6G7H8 The Italian CI has a length of 23 characters in total. The fiscal code (codice fiscale) and VAT number (Partita IVA) will be used as the national part of the Creditor Identifier. The fiscal code is 16 digits long, while VAT number and temporary fiscal code are both 11 digits long (in this case a 5 zero padding on the left is used). The Creditor Identifier for Italy will be: Characters 1-2 : IT, the ISO country code. Characters 3-4: standard SEPA check digit. Characters 5-7: the Creditor Business Code, selected by the creditor to fulfill his business needs (if not applicable: ZZZ).

5 Characters 8-23: national fiscal code, assigned by the Italian Tax Agency. When the code is a VAT number or a temporary fiscal code (which are 11 characters long), the positions 8-13 are filled with 5 zeros and with the actual code. Italian companies have the choice between two types of mandates: paper and electronic. The mandate for SDD will be integrated with info required for SEDA if subscriber is different from debtor (name of the subscriber and tax code). The Regulation N 260/2012, article 7 Validity of mandates and right to a refund, allows that existing mandates within a legacy direct debit scheme continue to be used within SEPA. Migrating a mandate means that you already have a domestic mandate authorizing you to debit the account of one of your customer and that you will continue using the same mandate, only with SEPA compliant collections. A mandate is considered as migrated when its first related collection in SEPA format has been successfully performed. One of the benefits of the migration is that you can continue to debit your customers with no need for them to re-sign a SEPA mandate. Mandates that have not been migrated yet should be migrated before their legal expiration, which is 36 months after the last debit performed under the legacy scheme. To migrate your mandates, you should consider the two main following points: RID can be migrated to SDD without signing a new mandate. Note that in Italy, micro enterprises are seen as fully-fledged businesses and can therefore be declared debtors of B2B mandates. The first SDD collection sent to convert a RID mandate can be valued with First Recurrent or Last. The creditor can choose to migrate a mandate to Core or B2B without asking the debtor to resign a new mandate but informing the debtor at least 30 days before the migration date: Consumers: migration to Core only Non-consumers: migration to Core or B2B, depending on the agreement between Creditor and Debtor. To migrate mandates, a creditor must generate the Unique Mandate Reference as indicated by ABI: Company code SIA + type of RID mandate + the unique code of RID mandate SIA Code used by the Creditor to collect RID.

6 In Italy, the IBAN is composed of 27 characters with the following structure: The first two characters identify the country of the account and are therefore always: IT. The next three characters correspond to the standard IBAN check digit plus CIN. Then the structure is the following: 5 crt: ABI code 5 crt: CAB code 12 crt : account number Example: IT 21G