Towards engaging with the market

Savings: the risk landscape is changing with influencers and digital technology

The focus on the impact of social media content on individuals’ decisions is one of the key aspects of Consob’s work

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3' min read

Translated by AI
Versione italiana

3' min read

Translated by AI
Versione italiana

The countdown has begun to Consob’s annual meeting with the financial market, which is to be held on Monday 13 July in Milan.

It is almost certain that among the key topics at the event will be digital channels, which have been the subject of numerous initiatives by the Commission (which, since 2019, has blocked 1,763 websites belonging to unauthorised financial intermediaries), both in terms of guidelines and research. The most recent of these is the Fintech Report published in June, entitled ‘Financial Communication via Digital Channels’, which aims to identify the risk profiles faced by retail investors in the face of a phenomenon involving four main players: web communities (such as Reddit forums or Telegram groups), platforms, academies (which offer training courses often promising easy profits) and finfluencers, namely influencers who specialise in financial topics in Italia.

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In this regard, the results of a survey conducted as part of the Quaderno suggest that ‘the framing (including visual framing) of the message and narrative techniques tend to fragment attention, reducing the clarity of focus and increasing information overload’. A situation made even more critical by gamification: game-like mechanics in app design that could ‘exploit the investor’s emotional vulnerabilities and maximise their engagement, often on a subconscious level’, obscuring the perception of the risk involved in the transaction. Even the integration of artificial intelligence, the study states, introduces risks, due to the technical unreliability of models prone to so-called ‘hallucinations’ (incorrect responses presented with absolute certainty) and the potential for herd behaviour to become more widespread.

The most important section of Consob’s various measures is, however, the one devoted to finfluencers, for whom two potential risks have been identified: the lack of certified technical expertise and conflicts of interest.

Risks, rights and limitations

“Like all influencers, financial influencers must first and foremost be registered in the dedicated register maintained by Agcom if they reach 500,000 followers or one million monthly views,” emphasises Augusto Vecchi, president of Creafi, an association founded in 2026 and dedicated to creators and influencers in finance, technology and innovation.

More specifically, finfluencers can inform, explain and share stories, but they must not advise, make promises or influence investment decisions.

The key reference point in this regard is the guidance issued by Consob in conjunction with ESMA, the European Union’s financial markets regulatory and supervisory authority. “Ultimately, there are two areas in which finfluencers play a significant role,” explains Francesco Mocci, a partner at Advant Nctm. “Firstly, their activities may conflict with the rules governing investment recommendations, if social media posts explicitly or implicitly recommend a strategy involving financial instruments. ESMA warns that it is easy to cross the line from purely educational activity into making a recommendation, for example by assessing the future performance of an issuer during a webinar. In recommendations, any potential conflicts of interest, the sources consulted, the methodologies used to calculate prices and the frequency of updates must be clearly stated. A superficial dissemination of information can then lead serious offences, such as insider dealing (for example, by revealing the content of an authoritative recommendation in advance) or market manipulation, for example by spreading misleading messages or creating ‘co-ordinated actions’ among social media users to artificially influence prices and profit from them’.

When does unauthorised activity begin?

Honesty, clarity and transparency regarding any remuneration and risks are a good guide to operating correctly as a finfluencer. Conversely, concealing conflicts of interest and feigning expertise or, worse still, providing consultancy services, are prime examples of unethical practices, which may even amount to the offence of unauthorised financial practice. This offence involves carrying out financial activities without the necessary authorisation, such as investment advice, the placement or promotion of financial instruments, or the management and raising of funds for investment – activities which are, by law, reserved for authorised and regulated professionals.

In particular, the unauthorised provision of an investment advisory service occurs where the finfluencer does not merely share information or offer opinions on financial matters, but offers the investing public the opportunity to engage in a personalised interaction aimed at providing a personalised investment recommendation.

The negligence of a few risks overshadowing the potential value of finfluencers. As Nicola Ronchetti, founder and CEO of the independent research institute Finer, points out, ‘the role of finfluencers – if properly understood and free from conflicts of interest – can make a significant contribution to raising awareness of fundamental issues such as the importance of setting up a continuous savings plan in view of a public welfare system that is set to gradually decline’.

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