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San Marino e-Invoicing
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Sammarinese operators have invoiced Italian buyers electronically through the Ufficio Tributario's HUB SM since 1 July 2022. Decreto Delegato 133/2026 extends the duty to trade between Sammarinese operators: optional from 1 October 2026, compulsory from 1 January 2027. Firms below EUR 100,000 of prior-year revenue are excluded.
San Marino e-Invoicing Overview
B2B
phased
since 1 July 2022Two regimes run side by side. Article 18 of Decreto Delegato 5 agosto 2021 n.147 opened a voluntary window on 1 October 2021 and made electronic invoicing compulsory from 1 July 2022 for goods sold to Italy; article 5 of Decreto Delegato 20 settembre 2021 n.163 sets the same two dates for contract work and for services under Legge 23 ottobre 1991 n.131. Trade inside the Republic is still on paper. Decreto Delegato 4 settembre 2026 n.133 changes that, by option from 1 October 2026 and compulsorily from 1 January 2027. Both regimes exclude operators that declared under EUR 100,000 of revenue in the previous calendar year, and both bind an operator for later years once it crosses that figure or opts in.
B2G
planned
There is no separate public procurement rule. Article 2 of Decreto Delegato 4 settembre 2026 n.133 lists the State and public and private bodies holding an economic operator code among those obliged to issue electronic invoices, but article 11 holds the decree back from the State, the public administration and public bodies until implementing provisions are adopted by regulation of the Congress of State, so no date binds them. Supplies to Italian public bodies follow the Italy interchange instead: the Ufficio Tributario's FAQ treats Italian authorities, bodies and associations that hold a VAT number before the transaction as economic operators, which puts them under the Italy interchange rules and its 1 July 2022 deadline.
B2C
none
Sales to private customers sit outside the electronic invoice regime. Under article 100 of Legge 16 dicembre 2013 n.166 , retail sales in premises open to the public, food and drink served in public establishments and services to private customers are certified through electronic devices connected to a telematic network, in place of an invoice. The Ufficio Tributario's FAQ applies the same answer where a Sammarinese operator works for an Italian private individual: the revenue is certified telematically and any invoice stays on paper. The 2027 duty does not reach these sales, because article 2 of Decreto Delegato 4 settembre 2026 n.133 covers only supplies to holders of an economic operator code.
Next deadline1 October 2026 · Domestic e-invoicing opens by option
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Implementation Timeline(14 events)
Key mandate dates. Select a date for detail, or show all updates below.
Recipient code published
31 August 2021
B2B
Ufficio Tributario circular prot. n. 92466/2021 gave 2R4GTO8 as the recipient code registered for the office as hub for receiving and sorting invoices, active from 1 October 2021. The circular prints the letters of the code in bold, so the sixth character is a letter O, and tells operators to pass the code to their counterparties in advance.
Technical and procedural rules adopted
8 September 2021
B2B
Phase 1 opens, e-invoicing optional
1 October 2021
B2B
Ufficio Tributario circular prot. n. 103321/2021 of 28 September 2021 described phase 1 to 30 June 2022: paper still allowed both ways, electronic invoicing by option, and an operator receiving an electronic invoice obliged to transmit it to the office. The production web service went live the same day.
Phase 2, electronic invoicing becomes compulsory
1 July 2022
B2B
Domestic e-invoicing opens by option
1 October 2026
B2B
Article 11 of Decreto Delegato n.133/2026 lets an operator or its delegate transmit invoices and credit notes to the Ufficio Tributario electronically instead of on paper, for supplies to holders of a Sammarinese economic operator code, until 31 December 2026.
Domestic e-invoicing becomes compulsory
1 January 2027
B2B
From this date operators outside the EUR 100,000 exclusion must issue those invoices electronically, and the decree's provisions on paper invoices take effect.
Penalties start to apply
1 January 2028
B2B
The EUR 100 administrative penalty in articles 6 and 7 of Decreto Delegato n.133/2026 takes effect, covering omitted or late electronic invoices and credit notes, paper invoices that are not prepared or delivered, and buyers that fail to file a substitute document.
Premium Sponsors
Compliance Regime
CTC Model
Clearance
Nothing reaches the counterparty without passing the Ufficio Tributario. Operators send invoices to HUB SM, the office's hardware and software layer for collecting, sorting and forwarding electronic invoices, either by web service or by upload in TribWEB, and each file is limited to 5MB and named with the ISO country code, the economic operator code and a progressive suffix. A file rejected by HUB SM is treated as not issued under article 4 of Decreto Delegato 20 settembre 2021 n.163 . For sales to Italy the office checks the document and only then passes it to the Sistema di Interscambio; on purchases it checks the invoice before making it available to the buyer, who then self-assesses the import tax, and article 3 of the Italian decreto 21 giugno 2021 gives it four months to do so, after which the Italian seller issues a credit note free of penalties and interest. A digital signature on the XML is allowed, in XAdES-BES or CAdES-BES form, but annex A to Regolamento 8 settembre 2021 n.14 does not require it.
Network
Clearance
Standards
N/A
Record-keeping & Reporting
Archiving
Electronic invoices issued and received must be archived by 30 September of the year after the invoice date, under article 8 of Decreto Delegato 20 settembre 2021 n.163 , and Decreto-Legge 29 settembre 2023 n.139 moved invoices for 2021, 2022 and 2023 to 31 December 2024. Retention itself runs for five years, excluding the tax period the records relate to and in any case until assessments for that period are settled, under article 100 of Legge 16 dicembre 2013 n.166 . The Ufficio Tributario does not act as a conservator for third parties; it offers consultation and download from an area of HUB SM, and conservators must give the tax administration effective and prompt access to the data, including remote access, whichever country it is held in.
Technical Formats
XML (FormatoTrasmissione FPR12)
Penalties
Omitted or late invoice
EUR 100 for each electronic invoice or credit note omitted or transmitted late, under article 6 of Decreto Delegato 4 settembre 2026 n.133 , imposed and notified under Title IV of Legge 28 giugno 1989 n.68. The same figure covers a paper invoice that is not prepared, delivered or sent, and article 11 delays it to 1 January 2028.
Buyer's substitute document
A buyer that has not received an invoice or credit note must wait two months past the deadline and then has thirty days to file a substitute document with the Ufficio Tributario through HUB SM, on paper if it is not obliged to transmit electronically. Failing to do so carries the same EUR 100 penalty under article 7 of Decreto Delegato 4 settembre 2026 n.133 .
Import tax self-assessment
Exemptions
Revenue below EUR 100,000
An operator that declared revenue below EUR 100,000 in the previous calendar year is excluded, both from the Italy interchange under article 18 of Decreto Delegato 5 agosto 2021 n.147 and from the domestic duty under article 2 of Decreto Delegato 4 settembre 2026 n.133 . It may still opt in, and the choice is not reversible: once an operator passes the figure or opts in, it must keep invoicing electronically in later years.
Cross-border Conditions
Goods sold to Italy
The seller transmits the invoice to the Ufficio Tributario with the goods type and, where VAT is charged, the payment receipt; article 7 of Decreto Delegato 5 agosto 2021 n.147 then gives the office 15 days to pass the VAT and the summary lists to the Agenzia delle Entrate. The FAQ requires document type TD01 with nature code N3.1.
Goods bought from Italy
Purchase invoices arrive through HUB SM and must be presented to the Ufficio Tributario on an electronic form stating the goods type, the rate and the import tax for each purchase, under article 4 of Decreto Delegato 20 settembre 2021 n.163 . The ordinary deadline is 60 days from the document date, per the Ufficio Tributario FAQ .
Services
Italian suppliers may invoice Sammarinese operators electronically for services under article 20 of the Italian decreto 21 giugno 2021 , with the Sistema di Interscambio passing the file to the Ufficio Tributario for delivery. Invoices a Sammarinese operator issues for contract work and Legge n.131/1991 services run the other way and are not sent to the Sistema di Interscambio at all.
Transport documents
Every sale of goods to an Italian operator that moves them into Italy must travel with a transport document, and the fattura accompagnatoria can no longer be used, per the Ufficio Tributario FAQ . A missing reference to the transport document fails the HUB SM semantic checks, and where an invoice covers several transport documents each line must point to its own.
Italian counterparty document codes
An Italian buyer that receives an invoice from a Sammarinese supplier without VAT charged must integrate it through the Sistema di Interscambio with document type TD19, and where a supplier outside the electronic duty issues a paper invoice with VAT charged the buyer sends document type TD28 instead. Italian sellers use nature code N3.3 for sales to Sammarinese operators. All three are set out in the Agenzia delle Entrate Guida alla compilazione delle fatture elettroniche e dell'esterometro , version 1.10 of 1 April 2025.
Related Countries
Frequently asked questions about e-Invoicing in San Marino
San Marino is currently implementing e-Invoicing in a phased rollout. B2B is in a phased rollout and B2G is planned for future implementation.
B2B e-Invoicing in San Marino is in a phased rollout since 2022-07-01. Two regimes run side by side. Article 18 of Decreto Delegato 5 agosto 2021 n.147 opened a voluntary window on 1 October 2021 and made electronic invoicing compulsory from 1 July 2022 for goods sold to Italy; article 5 of Decreto Delegato 20 settembre 2021 n.163 sets the same two dates for contract work and for services under Legge 23 ottobre 1991 n.131. Trade inside the Republic is still on paper. Decreto Delegato 4 settembre 2026 n.133 changes that, by option from 1 October 2026 and compulsorily from 1 January 2027. Both regimes exclude operators that declared under EUR 100,000 of revenue in the previous calendar year, and both bind an operator for later years once it crosses that figure or opts in.
B2G e-Invoicing in San Marino is planned for future implementation. There is no separate public procurement rule. Article 2 of Decreto Delegato 4 settembre 2026 n.133 lists the State and public and private bodies holding an economic operator code among those obliged to issue electronic invoices, but article 11 holds the decree back from the State, the public administration and public bodies until implementing provisions are adopted by regulation of the Congress of State, so no date binds them. Supplies to Italian public bodies follow the Italy interchange instead: the Ufficio Tributario's FAQ treats Italian authorities, bodies and associations that hold a VAT number before the transaction as economic operators, which puts them under the Italy interchange rules and its 1 July 2022 deadline.
San Marino supports the following e-Invoice formats: XML (FormatoTrasmissione FPR12).
San Marino uses the following e-Invoicing standards: N/A. Archiving requirement: Electronic invoices issued and received must be archived by 30 September of the year after the invoice date, under article 8 of Decreto Delegato 20 settembre 2021 n.163 , and Decreto-Legge 29 settembre 2023 n.139 moved invoices for 2021, 2022 and 2023 to 31 December 2024. Retention itself runs for five years, excluding the tax period the records relate to and in any case until assessments for that period are settled, under article 100 of Legge 16 dicembre 2013 n.166 . The Ufficio Tributario does not act as a conservator for third parties; it offers consultation and download from an area of HUB SM, and conservators must give the tax administration effective and prompt access to the data, including remote access, whichever country it is held in..
Nothing reaches the counterparty without passing the Ufficio Tributario. Operators send invoices to HUB SM, the office's hardware and software layer for collecting, sorting and forwarding electronic invoices, either by web service or by upload in TribWEB, and each file is limited to 5MB and named with the ISO country code, the economic operator code and a progressive suffix. A file rejected by HUB SM is treated as not issued under article 4 of Decreto Delegato 20 settembre 2021 n.163 . For sales to Italy the office checks the document and only then passes it to the Sistema di Interscambio; on purchases it checks the invoice before making it available to the buyer, who then self-assesses the import tax, and article 3 of the Italian decreto 21 giugno 2021 gives it four months to do so, after which the Italian seller issues a credit note free of penalties and interest. A digital signature on the XML is allowed, in XAdES-BES or CAdES-BES form, but annex A to Regolamento 8 settembre 2021 n.14 does not require it.
San Marino has penalties for e-Invoicing non-compliance. Omitted or late invoice: EUR 100 for each electronic invoice or credit note omitted or transmitted late, under article 6 of Decreto Delegato 4 settembre 2026 n.133 , imposed and notified under Title IV of Legge 28 giugno 1989 n.68. The same figure covers a paper invoice that is not prepared, delivered or sent, and article 11 delays it to 1 January 2028. Buyer's substitute document: A buyer that has not received an invoice or credit note must wait two months past the deadline and then has thirty days to file a substitute document with the Ufficio Tributario through HUB SM, on paper if it is not obliged to transmit electronically. Failing to do so carries the same EUR 100 penalty under article 7 of Decreto Delegato 4 settembre 2026 n.133 . Import tax self-assessment: Inexact self-assessment of the import tax due on a purchase invoice falls under article 10 of Decreto 24 marzo 1993 n.50, unless the operator gives well founded and exhaustive explanations that rule out gross negligence or intent, as article 1 of Decreto Delegato 5 agosto 2021 n.147 provides.
The next e-Invoicing deadline in San Marino is 1 October 2026: Domestic e-invoicing opens by option. Article 11 of Decreto Delegato n.133/2026 lets an operator or its delegate transmit invoices and credit notes to the Ufficio Tributario electronically
Cross-border e-Invoicing in San Marino: The seller transmits the invoice to the Ufficio Tributario with the goods type and, where VAT is charged, the payment receipt; article 7 of Decreto Delegato 5 agosto 2021 n.147 then gives the office 15 days to pass the VAT and the summary lists to the Agenzia delle Entrate. The FAQ requires document type TD01 with nature code N3.1. Purchase invoices arrive through HUB SM and must be presented to the Ufficio Tributario on an electronic form stating the goods type, the rate and the import tax for each purchase, under article 4 of Decreto Delegato 20 settembre 2021 n.163 . The ordinary deadline is 60 days from the document date, per the Ufficio Tributario FAQ .
Exemptions from San Marino e-Invoicing may apply to: Revenue below EUR 100,000, Trade outside Italy. Check specific criteria as exemptions vary by transaction type and business size.