San Marino requires e-invoicing for transactions between San Marino economic operators under Delegated Decree No. 133 of September 4, 2026. Invoices reach the UO Ufficio Tributario through HUB SM, the platform San Marino already uses for the invoice exchange with Italy.
The obligation turns on holding a San Marino economic operator code. It applies to economic operators, agricultural undertakings, the State, and public and private entities that hold one. It covers invoices for transactions carried out exclusively towards economic operators established or identified in San Marino that hold an economic operator code.
Smaller operators sit outside the obligation. Operators that declared revenue below EUR 100,000 in the previous calendar year fall outside it, however they can opt in. After an operator exceeds the threshold or exercises the option, e-invoicing applies in the following years as well. Operators that stay outside the obligation issue paper invoices under Article 100 of Law No. 166/2013.
Public sector application waits on a further step. The decree applies to the State, the Public Administration, and public entities after implementing provisions adopted by regulation of the Congress of State enter into force. The decree does not state a date for this.
Three dates set the timeline:
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From October 1, 2026, San Marino operators can choose to issue an electronic invoice in place of a paper invoice, and this option runs to December 31, 2026.
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From January 1, 2027, e-invoicing becomes mandatory for operators outside the revenue exclusion, and the rules in the decree that govern paper invoices also start to apply.
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The penalties in Articles 6 and 7 start to apply from January 1, 2028.
Deadlines run from the transaction event. Suppliers issue the electronic invoice by the second month following delivery or dispatch of goods, completion of a service, or payment of an advance. Earlier issuance is allowed.
HUB SM controls whether an invoice counts as issued. An electronic invoice that HUB SM rejects counts as not issued. After the UO Ufficio Tributario completes its check, it makes the invoice available electronically to the buyer.
Buyers carry an obligation of their own – when an invoice or note does not arrive within the applicable deadlines, the buyer has 30 days, starting two months after those deadlines, to report the missing invoice data to the UO Ufficio Tributario.
The Congress of State has not yet published the technical and procedural rules, and the decree applies to the State, the Public Administration, and public entities only after separate implementing provisions take effect.
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