San Marino

​

Overview

​

Identifiers

Collect two identifiers from each business customer in San Marino and submit them as strings on the application body. Tax ID: The COE is a progressive 5-digit numeric code assigned to every licensed economic operator upon registration in the Trade Register under Art. 5 of Law No. 71/2004. It is San Marino’s universal business identifier and serves as the fiscal reference for the General Income Tax (IGR) under Law No. 166/2013. San Marino does not levy VAT; there is no VAT certificate. For cross-border electronic invoicing with Italy the COE appears as SM followed by 5 digits (e.g. SM01234). The COE is printed on the business licence (licenza) and the company registration certificate. Registration number: Sequential number assigned at company formation under Law No. 47/2006 (Companies Act); appears on the Certificato di iscrizione al Registro delle Società and on the company registration certificate from the Trade Register. The same operator is recorded in both the Registro Pubblico delle Società (held by the Ufficio Attività Economiche, public company-law record) and the Registro delle Imprese (commercial registry, transferred to ASE-CC effective 1 June 2025). The COE is the primary cross-registry identifier for the same operator.

​

Sector regulators

BCSM (Banca Centrale della Repubblica di San Marino) · AIF (Agenzia di Informazione Finanziaria) · Ufficio Attività Economiche · Agenzia per lo Sviluppo Economico – Camera di Commercio S.p.A. (ASE-CC)

​

Legal structures

​

How documents combine

For each evidence area, this table shows whether the listed documents are alternatives (any one of) or a bundle (all required). The artifact-by-artifact lookup follows below.

​

Documents to collect

The physical documents you’ll collect from your customer, with the evidence area each one proves. One document can prove multiple areas — for example, Brazil’s Cartão CNPJ covers both tax and business-registration proof, so it appears once with both areas listed.

​

Collection notes

• Legal Registration: Two overlapping certificates exist depending on the requesting authority: (1) the Certificato di iscrizione al Registro Pubblico delle Società issued by the Ufficio Attività Economiche under Law No. 47/2006 and Decreto Delegato No. 152/2022 (operative 15 Jan 2023) — this is the authoritative company-law record showing corporate status, date of registration, corporate bodies, objects, and directors’ powers; (2) the company registration certificate from the Registro delle Imprese (Trade Register) issued by ASE-CC (Camera di Commercio) under Law No. 71/2004 — commercial record. Accept either; the company-law certificate from the Ufficio Attività Economiche is preferred for KYB. Both carry the COE. Documents are in Italian; no English version is officially issued. Certificates available for download via registroimprese.cc.sm (fee applies) or from the Ufficio Attività Economiche OPEC portal (pa.sm).
• Constitutive Documents: San Marino companies (S.r.l. and S.p.A.) must be constituted by notarial public deed before a San Marino notary under Law No. 47/2006 Art. 14. The notarial deed is the Atto Costitutivo; the Statuto (bylaws) is the constitutive document setting out governance, share capital, corporate objects, and director powers — it is an integral part of the Atto Costitutivo even when executed as a separate instrument. The notary deposits a certified copy with the Ufficio Attività Economiche within 30 days of execution. For partnerships (S.n.c., S.a.s.) the equivalent instrument is the Patto Sociale (partnership deed), also in notarial form. Documents are in Italian; translations required for foreign-language KYB reviews.
• Tax Registration: San Marino does not have VAT; the indirect tax system uses a single-phase import tax (imposta monofase sulle importazioni) rather than a VAT chain. For direct income tax purposes, the COE is the entity’s fiscal identifier under the General Income Tax (Imposta Generale sui Redditi — IGR) introduced by Law No. 166/2013 (17% standard rate; transitional 18% for 2026–2030). The COE is printed on the business licence (licenza) issued by the Ufficio Attività Economiche. There is no separate tax registration certificate; the licenza itself serves as proof of tax registration. For cross-border identification with Italian fiscal authorities, the COE appears prefixed ‘SM’ on electronic invoices (SDI/HUB-SM gateway). Collect the current-year licenza as the primary tax certificate.
• Operating Permit: Under Law No. 40/2014 (Licences Act, replacing Law No. 129/2010) ALL entities wishing to carry on economic activity in San Marino must obtain a licenza from the Ufficio Attività Economiche (operational functions transferred to ASE-CC effective 1 June 2025 per resolution of the Congress of State of 15 April 2025). The licence is issued immediately online via the OPEC portal (pa.sm) upon self-certification; competent offices verify self-certifications within 180 days (30 days for health/security-risk sectors). Annual renewal fee applies. Certain sectors require prior Government authorisation: energy/water/gas/telecom, road construction, waste disposal, private security, precious metals wholesale, and education/training. Most commercial activities are liberalised. The same licenza document satisfies both the operating_license and tax_certificate slots (carries the COE).
• Sector-Specific License: The Banca Centrale della Repubblica di San Marino (BCSM) is the single supervisory authority for banking, financial services, insurance, and payment services under the Law on Banking, Financial and Insurance Enterprises and Services (LISF, Law No. 165/2005 as amended). Licence types include: banking authorisation; payment institution / electronic money institution authorisation (Regulation No. 2020-04 on Payment Services); insurance company/intermediary authorisation (Insurance Act); investment firm authorisation; fiduciary company authorisation. BCSM maintains public registers of supervised entities at bcsm.sm. The AIF (Agenzia di Informazione Finanziaria, Law No. 92/2008) supervises AML/CFT compliance for designated non-financial businesses and professions (DNFBPs). For non-financial activities requiring Government prior authorisation (energy, telecom, private security, etc.), the relevant sector ministry issues the authorisation.
• Governance Records: Directors, sole administrators, and auditors are listed in the Registro Pubblico delle Società maintained by the Ufficio Attività Economiche under Law No. 47/2006 and Decreto Delegato No. 152/2022. The company registration certificate issued by the Ufficio Attività Economiche includes the organi sociali section listing current directors and their powers. Updates must be filed within 30 days of any change. For the Registro delle Imprese (ASE-CC), the same officer data is mirrored. Collect the company registration certificate from either authority as evidence of current directors.
• Signing Authority: Board resolution or notarial power of attorney authorising a named individual to act on behalf of the company. No mandatory registration with the Ufficio Attività Economiche unless it alters the company’s registered signatory powers (in which case an amendment to the Registro Pubblico delle Società is required). For use outside San Marino or Italy, the document may require apostille under the Hague Apostille Convention (San Marino acceded to the Convention; competent authority is the Segreteria di Stato per gli Affari Esteri).
• Address: Conduit universal policy: lease (no time bound) OR utility bill OR bank statement, with utility/bank dated within 90 days. San Marino has domestic utility providers (AASS — Azienda Autonoma di Stato per i Servizi Pubblici, supplying electricity, water, gas, and waste services); bills from AASS are the standard utility document. Same evidence satisfies both registered-address and operating-address checks. Companies must demonstrate a place of business in San Marino compliant with building regulations to obtain a licence; the lease or ownership deed is accordingly a common supporting document.
• Good Standing: The Ufficio Attività Economiche issues a Certificato di vigenza (or certificato di stato attivo) confirming the company is currently registered in the Registro Pubblico delle Società, is in active status, and is not subject to insolvency, liquidation, or striking-off proceedings under Law No. 47/2006. Distinct from the ordinary company registration certificate (which captures static incorporation data) — the vigenza certificate reflects current legal status. Requested via the OPEC portal (pa.sm) or in person. Since June 2025 the ASE-CC (Camera di Commercio) also issues equivalent status confirmations from the Registro delle Imprese. Either authority’s certificate is acceptable; prefer the Ufficio Attività Economiche version for the company-law record.

​

Person roles

When you submit a person on the application body, set their role to one of Conduit’s canonical BusinessPersonRole values. Use this table to map a local corporate-governance title onto the right canonical role.

​

Notes

• San Marino is a microstate fully encircled by Italy and uses the euro (EUR) by monetary agreement with the EU (not an EU member). Its legal system is autonomous but heavily influenced by Italian civil law; primary corporate law is Law No. 47/2006 (Companies Act), last materially amended in 2022.
• Registry split: the Registro Pubblico delle Società (company-law record, Ufficio Attività Economiche) and the Registro delle Imprese (commercial/trade record, transferred to ASE-CC effective 1 June 2025 per resolution of the Congress of State of 15 April 2025) are distinct but carry the same COE. For KYB, the Ufficio Attività Economiche certificate is the authoritative document; the ASE-CC trade register certificate is supplementary.
• Bearer shares (Società Anonima, S.a.) were abolished effective 30 September 2010. Any legacy S.a. entity should be treated as a red flag requiring manual review to confirm conversion to S.p.A. or dissolution.
• No VAT: San Marino uses a single-phase import tax (imposta monofase) instead of VAT. Do not request a VAT certificate — none exists. The COE serves as both the trade registration number and the fiscal identifier.
• Language: all official documents are issued in Italian. No official English versions exist; commissioned translations should accompany documents used outside San Marino.
• Apostille: San Marino is party to the Hague Convention Abolishing the Requirement for Legalisation of Foreign Public Documents; the competent apostille authority is the Segreteria di Stato per gli Affari Esteri e Politici.