San Marino is introducing mandatory e-invoicing for domestic transactions between Sammarinese economic operators from January 1, 2027, for domestic supplies of goods and services made by in-scope Sammarinese economic operators to Sammarinese economic operators, or equivalent persons, holding an economic operator code (codice operatore economico, COE). Delegated Decree No. 133, enacted on September 4, 2026, establishes the legal framework for electronic and paper invoices in the exchange of goods and services between Sammarinese economic operators.
Scope and exemption
The e-invoicing requirement applies to economic operators, agricultural businesses, the State, public and private entities that hold a COE, for transactions carried out exclusively with economic operators established or identified in San Marino, or persons treated as equivalent, that also hold a COE.
A COE is a five-digit fiscal identifier assigned to Sammarinese economic operators and other entities and is also used as an identifier under the current e-invoicing obligation for cross-border transactions with Italy.
Operators with revenue below 100,000 EUR in the preceding calendar year are exempt but may opt in voluntarily. Operators that exceed the threshold or opt in must continue using e-invoicing in subsequent years.
The decree also includes the State and public entities within scope. However, the rules will apply to the State, Public Administration, and public entities only when implementing provisions adopted by the Congress of State enter into force.
E-invoice submission and deadlines
E-invoices must be prepared and transmitted electronically via the Hub SM to the Tax Office (Ufficio Tributario di San Marino). Invoices must be submitted by the end of the second month after delivery of goods, completion of services, or receipt of an advance payment.
Specific deadlines apply to continuous supplies of goods or services lasting more than one year where no full or partial payments are made during that period. In those cases, invoices must be prepared and transmitted by the end of the second month following the end of each calendar year, until the supplies or services are completed. Operators may also prepare and transmit invoices before the applicable deadline.
An e-invoice rejected by the Hub SM is considered not issued. Following the Tax Office checks, e-invoices will be made available electronically to buyers or service recipients.
Paper invoices
Exempt operators that do not opt into e-invoicing must issue paper invoices under existing legislation. Paper invoices must contain the same information required for e-invoices and must be issued, delivered, or sent within the same deadlines.
Paper invoices generally do not need to be transmitted to the Tax Office. However, special rules apply where a purchaser or service recipient does not receive an invoice or variation note.
Credit notes and missing invoices
Credit notes, or variation notes, relating to e-invoices must also be issued electronically through the Hub SM. Where the original invoice was issued in paper format, the related credit note must also be issued in paper format.
Where a buyer or recipient has not received an invoice or a variation note, it must act after two months have passed from the applicable invoicing deadline. It then has 30 days to prepare and submit a document through the Hub SM or, where the purchaser or recipient is not required to transmit e-invoices, to submit a paper document to the Tax Office. The document must include all information from the missing invoice.
Technical rules and retention
The Congress of State will issue technical and procedural rules for the preparation, transmission, and receipt of e-invoices. Separate regulations will govern the archiving and preservation of e-invoices.
The Tax Office will provide a service through the Hub SM for consulting and retrieving e-invoices but will not act as a third-party archiving provider. Electronic and paper invoice retention times remain subject to existing San Marino legislation, currently five years from the end of the relevant tax period, or until any related tax assessment is finalized.
Timeline and penalties
- October 1 to December 31, 2026: Voluntary e-invoicing period;
- January 1, 2027: Mandatory e-invoicing begins for Sammarinese economic operators that do not qualify for the 100,000 EUR revenue exclusion; the rules on paper invoices also take effect; and
- January 1, 2028: 100 EUR administrative penalties apply for omitted or late transmission of e-invoices and variation notes, as well as for failures to prepare, deliver, or send paper invoices as required. The penalty also applies for failure to comply with the missing-invoice procedure.
