Banca d'Italia and Consob Issue SiS Supervisory Guidelines
Banca d'Italia and Consob have jointly issued new supervisory guidelines for Simple Investment Companies (SiS). These guidelines, published on April 10, 2026, detail the regulatory framework and expectations for these simplified investment vehicles.
Simplified Investment, Clear Conditions
Banca d'Italia and Consob have issued supervisory guidelines for Simple Investment Companies (SiS), a specific type of collective investment undertaking (CIU) in Italy.
SiS operate under a simplified regime for sub-threshold managers, aligning with the AIFMD directive.
Defined as Italian alternative investment funds (AIFs) structured as fixed-capital investment companies (SICAFs), SiS directly manage their own assets.
Key conditions include a net asset value not exceeding €50 million, a threshold recently increased from €25 million by Law 162/2024.
Their exclusive purpose is direct investment in unlisted small and medium-sized enterprises (SMEs) in early stages.
SiS are prohibited from using leverage and must maintain a minimum share capital of €50,000. This framework supports investment in nascent businesses with tailored regulatory oversight.
Navigating the Regulatory Framework
SiS are exempt from certain Consolidated Law on Finance (TUF) provisions but must ensure adequate governance and control, alongside professional liability insurance.
Consob's rules on marketing collective investment undertakings (CIUs) also apply.
These guidelines clarify applicable provisions and outline Banca d'Italia's and Consob's compliance expectations.
While not strictly mandatory, SiS proposing alternative measures must demonstrate their effectiveness to regulators, or face supervisory actions.
Exceeding the net asset threshold, detailed in the Collective Management Regulation, mandates new authorization to continue operations.
Balancing Flexibility and Oversight
These guidelines offer crucial clarity for the growing Simple Investment Company sector, particularly with the recent doubling of the net asset threshold.
While not strictly mandatory, their detailed expectations provide a vital framework for sound management and investor protection.
This approach balances regulatory flexibility with robust oversight, ensuring market integrity without stifling innovation.