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San Marino: fintech & payments regulation

Regulated

San Marino fintech & payments: CBK-regulated under 2020-04 & 2024-05; SEPA-aligned

Lead regulator:
Banca Centrale della Repubblica di San Marino
Key law:
Regulation No. 2020-04 on Payment Services and Electronic Money Issuance
Last updated:
2026-07-12

San Marino maintains a fully regulated fintech and payments sector overseen exclusively by the Central Bank of the Republic of San Marino (BCSM). The core framework for payment institutions and electronic money issuers is established under Regulation No. 2020-04, which defines authorization procedures and ongoing prudential requirements.

The jurisdiction is deeply integrated with the Eurozone payment infrastructure, mandating compliance with SEPA standards through Regulation No. 2024-04 and subsequent amendments like Regulation No. 2025-03. This includes the adoption of ISO 20022 XML standards and specific rules for instant payments.

Beyond payments, the BCSM regulates investment services under Regulation No. 2024-05 and banking activities under Regulation No. 2007-07. The regulatory environment is characterized by continuous updates to supervisory provisions, ensuring alignment with EU technical standards and prudential norms.

Who regulates

  • Banca Centrale della Repubblica di San Marino

    Primary supervisor for payment institutions, electronic money issuers, investment firms, and banking entities.

    [1][2][3]

Core laws & rules

  • Regulation No. 2020-04 on Payment Services and Electronic Money Issuance (2020)

    Establishes the comprehensive legal framework for payment institutions and electronic money institutions, defining scope, authorization, and prudential requirements.

    [2]

  • Regulation No. 2024-05 on Investment Services and Activities (2024)

    Governs investment firms, defining licensing requirements, scope of application, and prudential standards including capital.

    [1]

  • Regulation No. 2024-04 on Payment Operations (SEPA) (2024)

    Aligns national payment operations with SEPA standards and EU regulations for euro credit transfers and direct debits.

    [4]

Licensing & registration

  • Payment Institution / Electronic Money Institution

    Authorization procedures and ongoing prudential requirements are defined under Regulation No. 2020-04. Entities must comply with SEPA technical standards.

    [2]

  • Investment Firm

    Licensing requirements and prudential standards, including capital, are established under Regulation No. 2024-05.

    [1]

Restrictions & warnings

  • Payment Service Providers must enable users to set or increase limits for instant transfers in compliance with Regulation No. 2025-03.

    [5]

  • Domestic banks using foreign clearing intermediaries must contribute to the Clearing Guarantee Fund to safeguard the payment system.

Direction of travel

  • The regulatory framework is actively updated to align with EU SEPA standards and technical requirements, as evidenced by recent amendments in 2024 and 2025.

    [4][5]

Sources

  1. Regulation No. 2024-05 on Investment Services and Activities · 2026-01-29
  2. Regulation No. 2020-04 on Payment Services and Electronic Money Issuance (Payment Institutions and EMI) · 2026-01-29
  3. Regulation No. 2007-07 on the Collection of Savings and Banking Activities · 2026-01-29
  4. Regulation No. 2024-04 on Payment Operations (SEPA) · 2025-10-08
  5. Regulation No. 2025-03 — Regulation updating provisions on payment transactions (SEPA) · 2025-10-08

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This guide is compiled automatically from 5 primary-source documents published by San Marino's regulators, reviewed by RegAlert, and refreshed monthly (last updated 2026-07-12). It is not legal advice — always confirm requirements with the regulator or local counsel before acting.