San Marino Introduces Domestic E-Invoicing Mandate From January 2027
San Marino will introduce mandatory e-invoicing for domestic transactions between economic operators from 1 January 2027.
Delegated Decree No. 133, published on 4 September 2026, establishes a voluntary adoption period from 1 October to 31 December 2026, giving businesses three months to begin testing the new process before it becomes compulsory.
The Scope of the Mandate
The mandate will cover domestic sales of goods and services between economic operators in San Marino. This includes businesses, agricultural enterprises and public or private entities holding an economic operator code.
Businesses with annual revenue below €100,000 will be exempt, although they will be able to adopt e-invoicing voluntarily. Once an operator opts into the system or exceeds the threshold, it will be required to continue issuing electronic invoices in subsequent years.
Invoices Will Be Transmitted Through HUB SM
In-scope invoices will need to be created and transmitted electronically through San Marino’s HUB SM platform to the Ufficio Tributario, the country’s tax authority. Each transmitted file will be assigned a unique HASH code.
The requirements will apply to domestic supplies of goods and services, including advance payments and continuous supplies. Any corrective document or note of variation will generally need to follow the same format as the original invoice.
Invoices must normally be transmitted by the end of the second month following the delivery of goods or completion of a service. For continuous supplies where no payments are made during the year, transmission will be required by the end of the second month following the relevant calendar year.
The mandate will also extend to the state and public entities once the necessary implementing regulations have been adopted.
Penalties Delayed Until 2028
Although e-invoicing becomes mandatory on 1 January 2027, administrative penalties will not take effect until 1 January 2028.
From that date, a fine of €100 may apply where an electronic invoice or note of variation is transmitted late or not transmitted.
This effectively gives businesses a year between the beginning of mandatory adoption and the start of financial penalties. However, organisations will still need to adapt their invoicing systems and processes ahead of the January 2027 deadline.
Further technical instructions and procedural guidance are expected from the Ufficio Tributario, including details of the required data schema and transmission process.
The implementation timetable is:
- 1 October 2026: Voluntary e-invoicing begins
- 1 January 2027: Mandatory adoption for in-scope economic operators
- 1 January 2028: Administrative penalties take effect
Although San Marino is not an EU member and is therefore not directly subject to ViDA, the reform broadly aligns with the EU’s wider move towards structured e-invoicing and transaction-level digital reporting.
Source: KPMG
This content is intended to share insights and practical considerations based on industry experience. It does not constitute legal, regulatory, or financial advice. Regulatory requirements vary by jurisdiction and circumstance, so any compliance-related matters should be reviewed and validated with your own professional advisors.
