As debate continues in India over the Foreign Contribution (Regulation) Amendment Bill, 2026, sections of Christian organisations have called for the FCRA framework to be scrapped. Against this backdrop, it is worth examining how the Vatican City State, the sovereign seat of the Holy See, regulates foreign funding and financial operations within its own jurisdiction.
As a sovereign state and the territorial seat of the Holy See, the Vatican City State offers a significant comparison. The Holy see rests on Law No. XVIII of 2013 on Transparency, Supervision and Financial Information, along with the 2022 Praedicate Evangelium reforms and the December 2022 Motu Proprio on instrumental legal persons. It imposes a detailed financial-control framework covering transparency, anti-money-laundering measures, financial supervision and cross-border transactions.
Vatican Law No. XVIII: The foundation of financial transparency
A major turning point came on October 8, 2013, when the Pontifical Commission for Vatican City State adopted Law No. XVIII on Transparency, Supervision and Financial Information.
The legislation strengthened the Vatican’s system for preventing and combating money laundering and terrorist financing and was part of the Vatican’s broader effort to bring its financial system closer to international standards, including the recommendations of the Financial Action Task Force (FATF).
Law No. XVIII expanded the legal framework for financial transparency, supervision, identification and reporting. It gave Vatican financial authorities greater capacity to monitor financial activities falling within their jurisdiction and to identify transactions presenting potential money-laundering or terrorist-financing risks.
The law also strengthened the institutional position of ASIF, the Vatican’s financial intelligence and supervisory authority.
ASIF performs financial-intelligence functions and exercises prudential and anti-money-laundering supervision over relevant financial institutions and entities subject to Vatican financial legislation. This means foreign financial transactions falling within the Vatican’s regulatory framework are not simply treated as private transfers. They can be examined through the Vatican’s financial-intelligence, customer-identification, transaction-monitoring and anti-money-laundering mechanisms.
The significance of Law No. XVIII is therefore broader than foreign donations alone. It forms part of the legal infrastructure through which the Vatican monitors financial activity, identifies risks and promotes transparency.
ASIF and the Vatican’s financial surveillance system
ASIF occupies a central position in the Vatican’s financial-control architecture. The authority combines financial intelligence functions with supervisory responsibilities. Its role includes monitoring compliance with anti-money-laundering and counter-terrorist-financing requirements and supervising relevant financial activities.
The framework also involves the Institute for the Works of Religion (IOR), commonly known as the Vatican Bank.
The IOR is not simply a conventional commercial bank. It is an institution of the Holy See whose activities operate within the Vatican’s financial and regulatory framework.
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The combination of ASIF supervision, financial-intelligence mechanisms and regulated financial institutions provides the Vatican with a system for identifying suspicious transactions and tracing financial activity that falls within its jurisdiction. This is particularly significant for international transactions because cross-border payments can create money-laundering, terrorist-financing and beneficial-ownership risks.
Vatican financial law regulates foreign financial activity through requirements relating to transparency, identification, supervision and risk assessment. The scope of these requirements varies according to the nature of the transaction and the entity involved.
Praedicate Evangelium: Vatican centralises management of Holy See assets
The next major stage in the reform came in 2022, when Pope Francis promulgated the Apostolic Constitution Praedicate Evangelium, reorganising the Roman Curia and redefining the responsibilities of its economic institutions.
One of the most important institutions in this structure is the Administration of the Patrimony of the Apostolic See (APSA).
Under Article 219 of Praedicate Evangelium, APSA administers and manages the movable and immovable assets of the Holy See intended to provide the resources necessary for the activities of the Roman Curia.
APSA can also administer assets belonging to entities that have entrusted their property to the Holy See.
The reform therefore strengthened central management of significant Holy See financial and patrimonial assets.
Article 219 also provides that financial transactions involving the assets covered by the provision are carried out through the IOR. APSA serves as a central institution for administering and managing relevant Holy See assets.
Similarly, the reforms do not establish that every foreign donation received by every Catholic organisation must automatically be transferred to APSA. The centralisation applies within the legal and institutional framework established for Holy See assets and relevant Curial institutions.
December 2022 Motu Proprio tightens control over Vatican legal entities
A further step came on December 5, 2022, when Pope Francis issued a Motu Proprio regulating instrumental legal persons. The measure entered into force on December 8, 2022.
Instrumental legal persons are entities connected to and dependent upon institutions of the Roman Curia. They can include funds, foundations and other juridical structures established to serve institutional purposes.
The 2022 rules subjected these entities to significantly greater economic and financial supervision. Their temporal goods are treated within the patrimonial framework of the Apostolic See, and the entities are subject to supervision not only by the Curial institution on which they depend but also by the economic institutions of the Roman Curia.
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The December 2022 Motu Proprio specifically distinguishes instrumental legal persons from privately established foundations, associations and non-profit bodies that are not instrumental to the purposes of Curial institutions.
For instrumental legal persons, however, the controls are extensive. Their establishment and registration require prior authorisation from the Secretariat of State, and existing instrumental legal persons were given three months to bring their statutes into conformity with the new rules.
The legislation consequently reduced the scope for independent financial administration by entities directly connected with the Roman Curia.
Budgets, donors, beneficiaries and financial records under scrutiny
The Vatican’s economic supervision extends beyond the creation of instrumental legal persons.
Under the December 2022 framework, instrumental legal persons must submit their budgets and final accounts to the Secretariat for the Economy within the deadlines established by the Secretariat.
The documents are then transmitted to the Council for the Economy for approval.
The governing body of an instrumental legal person must also obtain the opinion of the Curial institution on which it canonically depends before submitting its proposed budget.
The system therefore gives the Vatican’s economic authorities a substantial role in monitoring the financial planning and accounts of instrumental legal persons.
The oversight does not stop at annual figures. The relevant Curial institution, the Secretariat for the Economy and the Office of the Auditor General, can obtain access to accounting records, supporting documentation and information relating to financial transactions.
The framework also allows authorities to obtain information concerning donors, beneficiaries, beneficial owners and governing bodies. This creates a system in which financial accountability can extend from the final accounts to the underlying documentation supporting individual transactions.
Vatican legislation also imposes long-term record-keeping requirements for financial documentation, including invoices, contracts and bank statements necessary to demonstrate how resources have been used.
The result is a system designed to create a documentary trail around the financial activities of entities within its scope.
Foreign Funding and Cross-Border Transactions: What Vatican law actually requires
The Vatican’s financial controls are particularly relevant to cross-border transactions and foreign funding.
Law No. XVIII strengthened the state’s mechanisms for monitoring international financial activity and preventing money laundering and terrorist financing. Foreign transfers are not inherently prohibited. Instead, transactions falling within Vatican financial regulation are subjected to identification, monitoring and financial-intelligence mechanisms designed to detect suspicious activity.
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The Vatican also maintains controls over the physical movement of cash and bearer negotiable instruments across its borders. Law No. XVIII introduced a €10,000 threshold for relevant cross-border cash declarations.
These provisions reflect a broader international principle that significant movements of physical currency and bearer instruments must be transparent enough for authorities to identify potential illicit financial activity.
The system therefore addresses both electronic financial transactions and physical cross-border movement of funds.
For foreign donors, foundations and other international financial actors, the practical significance is that transactions involving Vatican-regulated entities cannot simply be treated as entirely outside the Vatican’s financial-control system.
Vatican can suppress certain instrumental legal persons
The December 2022 Motu Proprio also contains an important enforcement mechanism concerning instrumental legal persons. Where the conditions specified by the law are met, an instrumental legal person can be suppressed and placed into liquidation by decree of the Curial institution on which it canonically depends. This gives the Holy See significant authority over juridical entities that form part of the institutional structure of the Roman Curia.
The rules establish a procedure for liquidation, including the settlement of creditors and determination of the destination of remaining assets. After creditors have been satisfied, residual property is devolved according to the provisions contained in the founding deed or statutes. If the founding documents do not specify how the remaining assets should be distributed, those assets are transferred to the Apostolic See. The final liquidation balance sheet is also submitted through the Secretariat for the Economy to the Council for the Economy for approval.
The legal mechanism therefore provides strong institutional control while still establishing rules governing the destination of residual property.
The evolution of Vatican financial law since 2013 shows a clear movement towards greater centralisation, transparency and institutional supervision.
Law No. XVIII strengthened anti-money-laundering controls, financial intelligence and financial supervision.
Praedicate Evangelium strengthened the central role of APSA in administering Holy See patrimonial assets and clarified the responsibilities of the Curia’s economic institutions.
The December 2022 Motu Proprio introduced a more structured system for supervising instrumental legal persons connected to the Roman Curia, including their registration, budgets, accounts, financial records, donors and beneficiaries.
Taken together, these measures have created a closely supervised financial architecture for the Vatican and the institutions of the Holy See.
For foreign funding and international financial transactions falling within this framework, the system creates multiple layers of oversight, from financial intelligence and transaction monitoring to budgetary reporting, accounting controls and institutional audits.
Every sovereign country has its own laws governing foreign funding, financial transactions and the use of overseas contributions. The Vatican City State is no exception, with its own detailed framework for financial transparency, supervision and cross-border transactions. This raises a broader question in the FCRA debate in India: while countries across the world maintain regulatory oversight over foreign funds and financial flows, should India be expected to keep its regulatory framework outside such oversight, or should foreign contributions received by organisations operating in the country remain subject to appropriate financial scrutiny?
