Overview of CONSOB’s DePub Platform: New Requirements for Marketing Materials Submission in in Italy

Overview

• From 1 September 2025, CONSOB’s DePub platform becomes available for the submission of advertising and marketing materials for funds offered to retail investors in Italy
• A transitional period runs from 1 September to 31 December 2025 during which submissions may be made via DePub or via the existing certified email system (Posta Elettronica Certificata, PEC) at [email protected]
• From 1 January 2026, DePub becomes the sole accepted channel for submitting marketing communications to CONSOB
• Legal and compliance teams should determine the firm’s submission model (direct vs. delegate), complete registration, update procedures, and train staff during the transitional period

Background and purpose

• CONSOB has established the DePub platform to centralise and streamline the supervision of advertising and marketing materials addressed to Italian investors for retail-distributed products
• The change is intended to create a uniform, electronic process for submissions and oversight and to replace the PEC-based process from 1 January 2026

Scope of application

• In-scope products (retail-distributed in Italy), including:
  • UCITS
  • ELTIFs
  • ETFs
  • Non-reserved AIFs

• In-scope submitters:
  • Manufacturers of marketing materials (e.g., the management company/AIFM)
  • Authorised delegates acting on behalf of the manufacturer (e.g., third-party service providers, such as Maples)
  • Italian distributors, where they are manufacturers or authorised to submit on the manufacturer’s behalf

• In-scope communications:
  • “Marketing communications” mean all messages advertising for a UCITS, ELTIF, or an AIF, regardless of medium
  • Examples: press articles, press releases, advertisements, factsheets

• Practical note: investor notices and similar communications may be in scope where they have a promotional or advertising character or are used in distribution to retail investors. If in doubt, align with CONSOB guidance and consider submitting

Timeline and transitional arrangements

• 1 September 2025: DePub becomes available; transitional period begins
• 1 September – 31 December 2025: Submissions can be made via DePub or via PEC ([email protected])
• 1 January 2026: DePub becomes the only accepted submission channel for marketing communications

Registration and access

• Credentials: Users register via the DePub portal using existing CONSOB DEPROF/Teleraccolta credentials
• Who may register:
  • Manufacturers (e.g., the management company/AIFM)
  • Authorised delegates (e.g., third-party service providers such as Maples)

• Registration options:
  • Registration via an authorised delegate
  • The delegate registers on DePub and submits marketing materials on your behalf

• Required documentation:
  • A signed delegation letter on the management company’s letterhead authorising the delegate
  • A copy of the legal representative’s identification

• Direct registration by the management company/AIFM
  • Register directly using existing DEPROF/Teleraccolta credentials
  • The management company can create second‑level access within DePub and assign a delegate (e.g., a third-party service provider) with appropriate permissions

Next Steps / Checklist

• Decide your submission approach (delegate vs. direct) ahead of 1 January 2026
• If using a delegate:
  • prepare the delegation letter; and
  • ID copy for upload
• Ensure internal teams have (or can recover) DEPROF/Teleraccolta credentials
• Complete DePub registration during the transition period (1 September 2025-31 December 2025
• Update internal procedures to route all submissions exclusively via DePub from 1 January 2026
• Map in-scope communications and channels (including press materials, factsheets, digital ads, and any investor notices with promotional content) and implement controls to capture and submit them consistently

How the Maples Group Can Help

The Maples Group GRS supports UCITS and AIFMs in their multi-market distribution strategies by providing an integrated global network of experts coordinated by a dedicated central team supporting all legal and regulatory aspects governing the cross-border marketing of investment funds on both a private placement and public offer basis.

Further Information

If you would like further information, please liaise with your usual Maples Group GRS contact.