"Unfinished Business": Italy's missing approach to colonial returns in a comparative perspective

Compared to other European countries with a colonial past, Italy has shown limited engagement in the ongoing international debate over the restitution of cultural heritage looted during colonial rule. The lack of a coherent legal framework and the absence of structured governmental initiatives have contributed to a significant delay when compared to countries such as France, Germany, Belgium, and the Netherlands, all of which have adopted targeted legal instruments and proactive policies in recent years. While Italy carried out a few high-profile restitutions in the early 2000s, including the Venus of Cyrene and the Obelisk of Axum, the momentum has since stalled. Only recently, following the establishment of a specialised ministerial Working Group on Colonial Collections in 2021 and the emergence of some independent initiatives by museums and cultural institutions, has the issue begun to re-emerge in public and academic discourse. Nevertheless, these developments remain fragmented and have yet to produce tangible regulatory outcomes. This paper offers a comparative legal and policy-based analysis of the approaches adopted by other European states, with a particular focus on the distinction between bottom-up initiatives led by cultural institutions and governmental strategies. By exploring paradigmatic models in France, Germany, Belgium, and the Netherlands, the paper seeks to identify patterns that could inform a more coherent and comprehensive Italian response and potentially be applied in practice. The paper briefly examines Italy’s engagement at the international level and reflects on the case of the Cotton Zemí, a Taíno idol held in the Museum of Anthropology and Ethnography in Turin, whose temporary loan to the Dominican Republic exemplifies a cautious and fragmented stance on colonial restitutions. Ultimately, the paper argues that, despite the reactivation of discourse and some modest developments, Italy still lacks a systematic and legally grounded approach to the restitution of colonial looted cultural property.