San Marino: E-invoicing mandate for domestic transactions effective January 1, 2027

Delegated Decree No. 133, published on September 4, 2026, introduced mandatory e-invoicing for domestic sales of goods and services between economic operators, effective January 1, 2027.

Background

San Marino has progressively expanded digital reporting requirements, with prior regulations covering cross-border transactions. The new decree establishes mandatory e-invoicing for domestic sales between economic operators, including businesses, agricultural enterprises, the state, and public and private entities holding an economic operator code.

The implementation timeline includes an initial voluntary phase from October 1, 2026, to December 31, 2026, followed by mandatory adoption from January 1, 2027. Penalties for noncompliance apply from January 1, 2028.

Overview of amendments

• Entities in scope: All economic operators, agricultural enterprises, the state, and public/private entities with an economic operator code must issue e-invoices for domestic sales to other economic operators in San Marino. Entities with annual revenues below €100,000 are exempt but may opt in. Once an entity opts in or exceeds the revenue threshold, e-invoicing becomes mandatory in subsequent years.
• Transactions covered: Domestic B2B sales of goods and services, including continuous supplies and advance payments. Corrective documents (notes of variation) must follow the same format as the original invoice.
• Data formats and transmission: E-invoices must be prepared and transmitted electronically via the HUB SM to the tax authority, the Ufficio Tributario (UT). Each file is uniquely identified by a HASH code. Paper invoices must contain the same data as e-invoices but are not transmitted to the UT except in specific cases.
• Deadlines: E-invoices must be transmitted by the second month following delivery (for goods) or completion (for services). For continuous supplies without payments, the deadline is the second month after each calendar year.
• Penalties: Administrative fines of €100 apply for late or omitted e-invoice or note of variation transmission, effective January 1, 2028.
• Archiving and consultation: E-invoices are accessible via HUB SM but archiving and conservation are regulated separately. Conservators must ensure timely access for the tax authority.
• Public sector: The mandate applies to the state and public entities upon adoption of implementing regulations.

Next steps

• Voluntary phase: From October 1, 2026, to December 31, 2026, economic operators may opt to issue e-invoices for domestic transactions.
• Mandatory phase: From January 1, 2027, e-invoicing is required for all in-scope entities unless exempted by the revenue threshold.
• Penalties: Enforcement of penalties begins January 1, 2028.
• Technical guidance: The UT will issue technical instructions and circulars outlining schema, procedural rules, and implementation details.
• Pending details: Stakeholders are awaiting technical specifications and implementation guidance from the UT.

For more information, contact a KPMG tax professional:

Philippe Stephanny | philippestephanny@kpmg.com

Ramon Frias | ramonfrias@kpmg.com