fintech15 - CONSOB AND ITS ACTIVITIES

Insights on Artificial Intelligence and Financial Supervision
P. Deriu, S. Racioppi; with a preface by A. Lalli
FinTech no. 15 - August 2025 [PDF] (Italian version)
Abstract
This paper explores the challenges linked to the use of artificial intelligence systems in CONSOB’s market surveillance activities. Given the lack of a systematic assessment of AI adoption within public administrations, the analysis begins with an overview of the applicable legal framework and a review of recent case law. It then introduces the concept of SupTech – defined as the use of advanced technologies to enhance supervisory functions – through an initial survey of key initiatives undertaken by international, European, and national authorities. Within this context, particular attention is given to the experimental projects launched by CONSOB. Finally, the paper examines the potential benefits and risks associated with these technologies and assesses the SupTech solutions developed by CONSOB in light of current regulatory requirements, with the aim of identifying their main implications and outlining possible paths for future development.
Authors
Paola Deriu - CONSOB, Head of the Research and Regulation Department (p.deriu@consob.it);
Stefania Racioppi - Sapienza University of Rome (stefania.racioppi@uniroma1.it), PhD student 38th cycle, Faculty of Law, Public Law, curriculum C - PNRR351 PA, subject of reference: administrative law, NEXT GEN EU, CUP 351: B83C22003030006, Mission: I.4.1 PNRR Public Administration Scholarships (Mission 4), Component: 1.
Stefania Racioppi wrote Chapter I (paragraphs 1, 1.1, 1.2, 1.3, 2, 3, 4) and Chapter II (paragraphs 1, 2, 3), both authors jointly wrote Chapter II (paragraph 4), the entire Chapter III, and the Conclusions.
We would like to thank M. Bellofiore, G. Calanchi, F. Gigante, S. La Civita, A. Limosani, C. Milia, T.N. Poli, A. Raffaelli, A. Russo, and G. Trovatore for their valuable support during the drafting and review of this work. All comments, suggestions, and observations received were extremely valuable. Their commitment and dedication reminded us of the importance of constructive dialogue and how research can benefit from a critical and attentive eye. The opinions expressed in this paper are solely those of the authors and do not represent the official position of CONSOB, nor do they in any way engage the responsibility of the Institute. When citing this paper, it is therefore incorrect to attribute the arguments expressed herein to CONSOB or its senior management. Errors and inaccuracies are attributable solely to the authors.
JEL Classifications: G18, G28, H83, K23, K24, K30, O32, O33, C55.
Keywords: artificial intelligence, SupTech, data-driven and risk-based supervision.