Update notice pursuant to Decree-Law 95/2025 (and Article 45(5) of MiCAR)

On 30 June, Decree-Law 95/2025 was published in the Official Gazette, extending the national transitional regime for VASPs (Virtual Asset Service Providers) entered in the Register of Virtual Currency Operators kept by the OAM.

In particular, operators already benefiting from the transitional regime may continue to operate for a further six months — that is, until 30 December 2025 — under the rules currently laid down by Legislative Decree No. 141 of 2010 and the related implementing provisions.

In addition, those same operators may continue to operate while the authorisation procedure is pending, until authorisation is granted or refused and in any case no later than 30 June 2026, provided that they: (i) file an application for authorisation in Italy or in another Member State, by 30 December 2025, as crypto-asset service providers (“CASPs”) under Regulation (EU) 2023/1114 (MiCAR), or (ii) belong to the same group as a company that has filed such an application by that same date.

YouHodler Italy S.r.l. already complies with Italian legislation and is entered in the OAM register as a VASP, and is actively preparing to meet the MiCA requirements in order to obtain authorisation as a CASP, making use of the extension granted.

In line with the highest standards of security and transparency, YouHodler Italy S.r.l. gives priority to the security and integrity of users’ assets, and is also equipped with internal control mechanisms, policies and procedures to identify, assess and manage risks, including money laundering and terrorist financing risks.

In compliance with the principles of transparency and fairness towards users and clients, YouHodler Italy S.r.l. also informs that, until authorisation is obtained — as clarified by the Bank of Italy in its communication of 2 July 2025 — the activity carried out by YouHodler Italy S.r.l. will continue to be subject to the rules laid down for providers of services relating to the use of virtual currencies and for digital wallet service providers (VASPs) and not (yet) to those laid down by MiCAR; accordingly, the anti-money laundering rules currently applicable to VASPs will also continue to apply to them.

Milan, 31 July 2025