The Central Bank of the Republic of San Marino announces that, following the most recent indications of the European Payments Council (EPC), San Marino Payment Service Providers (PSPs) cannot, at present, adhere to the new "Verification of Payee" (VOP) scheme, the use of which is mandatory as of October 9, 2025 for PSPs based in the European Economic Area (EEA). The limitation stems from regulatory and technical conditions defined at the European level independent of possible autonomous initiatives that can be activated by BCSM or San Marino PSPs.
In this regard, the EPC clarified that the adherence of non-EEA PSPs to the VOP scheme is, at the moment, also not feasible due to the absence of a legal "equivalence" framework for the use of VOP APIs and security requirements based on PSD2 QWAC certificates, which can only be issued in the EU/EEA today and are not yet subject to a full mutual recognition mechanism with non-EEA SEPA countries. The EPC has also represented that it will provide further guidance once the technical-operational feasibility analysis and related legal analysis are completed.
Who, besides San Marino, cannot directly join the VOP scheme
As specified above, the restriction does not only affect San Marino: in fact, PSPs located in non-European Economic Area (EEA) SE PA countries cannot currently join the VOP. These include - among others - Andorra, Switzerland, the United Kingdom, with the sole exception of individual institutions already authorized to operate through branches in EEA countries.
Initiatives launched by BCSM.
To facilitate the access of San Marino PSPs to the VOP as soon as possible, BCSM has already:
- initiated a formal interlocution with the EPC to represent the specificities of the San Marino system and define a path of adherence in compliance with the scheme;
- activated technical and legal in-depth discussions with operators and relevant European Authorities (including legal equivalence profiles for the use of the VOP API and the required certificates);
- asked local PSPs to continue technical preparations so that the VOP service can be quickly activated as soon as the regulatory and operational framework allows.
Continuity and security of payments
Pending the definition of the VOP accession path, San Marino PSPs will continue to guarantee the operation of SEPA transfers, both ordinary (SCT) and instant (SCT Inst), while maintaining high standards of security and control. Upon request, appropriate ceilings can be agreed upon for outgoing Instant Credit Transfers, on a daily or per transaction basis. BCSM reiterates that the temporary inability to join the VOP is determined by external factors and is working with EPC and other institutional contacts to enable San Marino PSPs to offer the service as soon as the necessary technical and legal conditions are finalized at the European level.
For more information, users can contact their PSP or consult the updates published by BCSM.
