BCSM Blog

Issuance of Regulation No. 2025-03 updating the provisions on payment transactions (SEPA)

Written by BCSM | 06 Oct 2025

The Central Bank of the Republic of San Marino announces that it has issued, Regulation No. 2025-03 updating the provisions on payment transactions (SEPA), which will enter into force on October 8, 2025.

The measure, as already indicated when the public consultation procedure was launched, intervenes in amending BCSM Regulation no. 2024-04, mainly to postpone, from October 9, 2025 to July 9, 2027, the deadline by which the obligation for San Marino payment service providers (PSPs) to also offer to their customers the service of sending instant euro credit transfers (the one in receipt is already operational), together with the instrumental service of beneficiary verification (Verification of Payee-VOP) on all outgoing credit transfers, even when not instantaneous, given the temporary unavailability, of this new instrumental service, for countries that, although adopting the euro as their national currency and being members of SEPA, are not members of the European Economic Area.
As a result of the consultation procedure, and in response to requests made by the San Marino Banking Association, some technical changes were made to the text of the measure.
In particular:
(a) the possibility for the customer to change the maximum amounts of outgoing instant credit transfers at any time, even upwards, has been maintained, as long as they are within the limits agreed with the PSP;
b) the possibility has been introduced for PSPs to implement such new payment services on a mass basis, i.e., avoiding the need for initiative on the part of customers and activation by PSPs one to one, by exceptionally resorting, within 60 days and in any case before the launch of such new services, to the procedure of unilateral generalized variation (VUG) provided that the temporary unavailabilityof the new VOP service is given adequate notice, so that each customer can make an informed decision whether to use outgoing instant credit transfers anyway or continue to use only ordinary ones, and, if so, also propose to the PSP the raising of the relevant ceiling.