Digital Payments & Fintech · San Marino
Fintech & digital payments rules in San Marino (2026)
San Marino shaded by its digital payments & fintech status
San Marino has a dedicated, in-force licensing regime for payment institutions and electronic-money institutions, supervised by the Central Bank of the Republic of San Marino (BCSM). Regulation No. 2014-04, in force since 1 November 2014, transposed the EU PSD and E-Money Directive, and BCSM maintains a public register of authorised payment service providers. San Marino participates in SEPA, and the 2023 EU Association Agreement will require fuller transposition of EU financial-services rules over a multi-year transition.
Key points
BCSM Regulation No. 2014-04 'on payment and electronic money issuing services' entered into force on 1 November 2014, creating authorisation regimes for payment institutions and EMIs harmonised with EU Directives 2007/64/EC and 2009/110/EC.
The Central Bank of the Republic of San Marino (BCSM) is the financial supervisory authority; its Statute (Law No. 96 of 29 June 2005) assigns it responsibility for regulating and supervising the national payments system.
BCSM maintains a register of payment service providers established under Article 25 of Delegated Decree No. 177/2018 and governed by Regulation No. 2020-04, Part XIII, listing authorised PSPs.
San Marino participates in the Single Euro Payments Area, enabling households, businesses and public administration to use EU-standard payment services; SEPA participation is governed by BCSM Regulation No. 2024-04 on payment transactions (SEPA).
San Marino has separately regulated distributed-ledger technologies (Delegated Decree No. 138 of 29 Aug 2024, in force 2 Oct 2024), defining crypto-assets, electronic-money tokens, utility tokens and NFTs in a framework broadly aligned with the EU MiCAR; this sits alongside, not within, the core PI/EMI regime.
Under the 2023 EU Association Agreement, San Marino must transpose and apply EU financial-services rules (banking, securities, asset management, AML/CFT) to gain single-market access, with a transition of up to 15 years; this is expected to further deepen its payments/fintech framework. No San Marino-specific BNPL regime was identified in official sources.
San Marino - other topics
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