2025-10-08

Regulation No. 2025-03 — Regulation updating provisions on payment transactions (SEPA)

The General Director of the Central Bank of the Republic of San Marino issued Regulation No. 2025-03 to amend Regulation No. 2024-04 regarding payment services and SEPA instant transfers. The regulation mandates that Payment Service Providers (PSPs) enable users to set or increase limits for instant credit transfers and require the implementation of Beneficiary Verification (VOP) services by July 9, 2027. During the transition period until that date, PSPs may offer instant transfers without VOP provided they inform users of the verification limitation, while existing contracts must be updated within 60 days of the regulation's entry into force.

Banca Centrale della Repubblica di San Marino logo

San Marino

Banca Centrale della Repubblica di San Marino

Click to view thumbnail

REGULATION NO. 2025-03 UPDATING PROVISIONS ON PAYMENT TRANSACTIONS (SEPA)

Article 1 – Amendment to Article 6 of Regulation No. 2024-04

  1. In Article 6, paragraph 3, of Regulation No. 2024-04, reference to Directive 2009/110/EC is added to letter e).

Article 2 – Amendment to Article 10 of Regulation No. 2024-04

  1. In Article 10 of Regulation No. 2024-04, paragraph 6 is replaced as follows:

“6. Upon request by the USER, a PSP offers the USER the possibility to set a limit establishing the maximum amount transferable via INSTANT CREDIT TRANSFER, if not already provided by the PSP itself, or, if already provided, to propose its increase at their own risk.

This limit can be set on a daily basis or per single transaction. PSPs ensure that USERS are able to modify this maximum amount, within the limit agreed with the PSP, at any time before an ORDER FOR PAYMENT is issued for an INSTANT CREDIT TRANSFER. If an ORDER FOR PAYMENT for an INSTANT CREDIT TRANSFER by a USER exceeds the maximum amount or would cause it to be exceeded, the PSP of the PAYER does not execute the ORDER FOR PAYMENT for the INSTANT CREDIT TRANSFER and notifies the USER, communicating the methods to modify the maximum amount.”

Article 3 – Amendments to Article 22 of Regulation No. 2024-04

  1. In Article 22, paragraph 2, of Regulation No. 2024-04, letter b) is replaced as follows:

“b) by July 9, 2027, the PSPs referred to in the previous letter a) offer all their USERS the payment service of sending INSTANT CREDIT TRANSFERS in euros, in compliance with the provisions of the previous Article 11, and implement what is provided in Annex 2 regarding BENEFICIARY VERIFICATIONS on TRANSFERS.”

  1. In Article 22 of Regulation No. 2024-04, paragraph 3 is replaced as follows:

“3. For PSPs falling into the categories of payment institutions or electronic money institutions, both deadlines referred to in the previous paragraph 2 are set at July 9, 2027.”

Article 4 – Final and Transitional Provisions

  1. This Regulation enters into force on October 8, 2025.

  2. During the period between the entry into force of this Regulation and the deadline of July 9, 2027, the provisions of Article 11, paragraph 2 of Regulation No. 2024-04, concerning the beneficiary verification service (so-called “VOP”) provided for in Annex 2 of the same Regulation, do not apply.

  3. As a result of the provision in the previous paragraph 2, during the transitional period provided for therein, San Marino payment service providers may offer users the payment service of sending instant transfers in euros even in the absence of VOP, provided that such payment service providers inform users of the inability to provide the VOP service.

  4. Contracts concluded before the entry into force of this Regulation and still in force on that date, if they require adjustments with respect to the provisions provided for in Regulation 2024-04, as amended by this Regulation, are subject to generalized variation by payment service providers within 60 days from the date of entry into force of this Regulation and in any case before the start of the service, with the possibility of recourse, in an exceptional manner, to the same procedure provided for in Article X.IV.20 of Regulation No. 2007-07 and subsequent amendments, even though it concerns a variation that is not unilateral but imposed by the need to align with new regulatory standards.

Article 5 – Consolidated Texts

  1. The consolidated text with the modifications introduced by this Regulation will be made available on the website of the Central Bank of the Republic of San Marino (www.bcsm.sm).