Opinion of the European Central Bank of 24 March 2025 on the increase of Italy’s quota in the International Monetary Fund (CON/2025/6)
Date: 2025-03-24
Institutions: European Central Bank
Subjects: institutional activity

ECB-PUBLIC 

EN 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 24 March 2025  

on the increase of Italy’s quota in the International Monetary Fund  

(CON/2025/6) 

Introduction and legal basis 

On  19  February  2025  the  European  Central  Bank  (ECB)  received  a  request  from  the  Italian  Ministry  of 

Economy and Finance for an opinion on an article (hereinafter the ‘draft article’) included in a draft law on 

Italian participation in banks and multilateral development funds (hereinafter the ‘draft law’). 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 

Functioning  of  the  European  Union  (the  ‘Treaty’)  and  Article 2(1),  third  indent,  of  Council  Decision 

98/415/EC1, as the draft article relates to the Banca d’Italia. In accordance with Article 17.5, first sentence, 

of the Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion. 

1. 

Purpose of the draft article 

1.1  As set out  in the explanatory memorandum accompanying the draft  law, the  purpose  of the draft 

article is to increase Italy’s quota in the International Monetary Fund (IMF). On 15 December 2023, 

the IMF Board of Governors finalised the Sixteenth General Review of Quotas and agreed to a 50 % 

increase  in  quotas  while  maintaining  the  existing  relative  quota  shares.  The  Board  of  Governors’ 

resolution also stated that the IMF’s lending capacity should be maintained and its dependence on 

borrowed funds reduced. This is to be achieved by reducing the New Arrangements to Borrow (NAB) 

and phasing out bilateral borrowing agreements (BBAs) by means entailing (1) an increase of 50 % 

in IMF quotas; (2) a simultaneous reduction (of around 16 %) in the NAB; and (3) the termination of 

the BBAs. The reduction of the NAB and the termination of the BBAs will be finalised when the quota 

increase is completed. 

1.2 

In particular, the draft article authorises the Ministry of Economy and Finance to implement the 50 % 

increase  in  Italy’s  IMF  quota  from  15.070  million  Special  Drawing  Rights  (SDR)  to  SDR  22.605 

million, drawing on the Banca d’Italia’s resources and in accordance with the agreements already 

existing between the Ministry of Economy and Finance, the Banca d’Italia and the IMF2. 

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2 

Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national 
authorities regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42, ELI: 
http://data.europa.eu/eli/dec/1998/415/oj). 

Article 3(1) of the draft law. 

 
 
 
 
 
 
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1.3  The draft article further specifies that, pending the finalisation of the quota increase, the Banca d’Italia 

is authorised to extend the duration of the BBA until 31 December 20273.  

1.4  The draft article further provides that the Italian Republic is to grant a State guarantee to the Banca 

d’Italia for all the disbursements related to the increase of Italy’s quota at the IMF4. A State guarantee 

is also granted for the extension of the BBA for the risks connected to the repayment of the principal 

amount and interest, and the exchange rate5.   

2. 

Monetary financing prohibition 

2.1  Article 123(1) of the Treaty prohibits the national central banks (NCBs) in the European System of 

Central Banks (ESCB) from granting overdraft facilities or any other type of credit facility to public 

authorities  and  bodies  of  the  Member  States.  Article  1  of  Council  Regulation  (EC)  No  3603/936 

defines ‘any other type of credit facility’, inter alia, as ‘any financing of the public sector’s obligations 

vis-à-vis  third  parties’.  This  prohibition  is  however  subject  to  certain  exemptions  contained  in 

Regulation (EC) No 3603/93. In particular, Article 7 of Regulation (EC) No 3603/93 provides that the 

financing by NCBs of obligations falling upon the public sector vis-à-vis the IMF is not regarded as a 

credit facility within the meaning of Article 123 of the Treaty. The fourteenth recital of Regulation (EC) 

No 3603/93 sets out the rationale behind this exemption, stating that it is appropriate to authorise the 

financing by the NCBs of obligations falling upon the public sector vis-à-vis the IMF because such 

financing ‘results in foreign claims which have all the characteristics of reserve assets’. Therefore, 

the  exemption  in  Article  7  of  Regulation  (EC)  No  3603/93  should  be  interpreted  in  line  with  that 

rationale. 

2.2  Reserve  assets  have  been  defined  as  those  external  assets  that  are  readily  available  to  and 

controlled by monetary authorities for meeting balance of payments financing needs, for interventions 

in exchange markets to affect the currency exchange rate, and for other related purposes, such as 

maintaining confidence in the currency and the economy and serving as a basis for foreign borrowing. 

Under this definition, reserve assets must be foreign currency assets and, other than gold bullion, 

must be claims on non-residents7.  

2.3  As the payment by the Banca d’Italia of the proposed increase in Italy’s IMF quota would result in 

claims  which  have  all  the  characteristics  of  reserve  assets,  the  draft  article  complies  with  the 

monetary financing prohibition8.  

2.4  Moreover,  the  ECB  considers  that  the  extension  of  the  BBA  falls  within  the  exemption  set  out  in 

Article 7 of Regulation (EC) No 3603/93. This is because the financing results in foreign currency 

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5 
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8 

Concluded on the basis of the authorisation included under existing Italian law. See Article 1(637) of Law No 178 of 
30 December 2020; that BBA expired on 31 December 2024. 
Article 3(3) of the draft law. 

Article 3(3) of the draft law. 
Council Regulation (EC) No 3603/93 of 13 December 1993 specifying definitions for the application of the 
prohibitions referred to in Articles 104 and 104b (1) of the Treaty (OJ L 332, 31.12.1993, p. 1, ELI: 
http://data.europa.eu/eli/reg/1993/3603/oj). 

See International Monetary Fund, Balance of Payments and International Investment Position Manual (sixth edn., 
2009), Chapter 8, Section F, pp. 111-118. 
See Opinion CON/2011/68, which concerns the last increase of Italy’s quota in the IMF. All ECB opinions are 
published on EUR-Lex. 

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(SDR)-denominated claims of the Banca d’Italia against non-resident persons (the IMF) that have all 

the characteristics of reserve assets9. 

3. 

Financial independence 

In order to ensure the independence of the NCBs laid down in  Article 130 of the Treaty, Member States 

may not place NCBs in a situation which in any way undermines their ability to carry out independently a 

task  falling  within  the  scope  of  the  ESCB  or  the  Eurosystem10.  This  includes  putting  them  in  a  position 

where  they  have  insufficient  financial  resources  to  carry  out  such  task11.  From  the  perspective  of 

safeguarding the financial independence of the Banca d’Italia, the ECB, therefore, welcomes the guarantee 

to be provided by the State under the draft article with respect to any risks deriving from the quota increase 

and, with respect to the BBA, the reimbursement of the principal and interest accrued on the Banca d’Italia’s 

loan, which will also cover any exchange rate risk arising from the implementation of the BBA.  

This opinion will be published on EUR-Lex. 

Done at Frankfurt am Main, 24 March 2025. 

[signed] 

The President of the ECB 

Christine LAGARDE 

9 

10 
11 

See, for example, Opinion CON/2020/37, which concerns Banca d’Italia’s participation in International Monetary 
Fund borrowing arrangements, including the BBA.  
Judgment of 13 September 2022, Banka Slovenije, C-45/21, ECLI:EU:C:2022:670, paragraph 97.  

See ECB Convergence Report, June 2024, pp. 27-28, available on the ECB’s website at www.ecb.europa.eu.  

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