Administrative fees

The administrative fees outlined in Art. 21 of CBSM Regulation BCSM n. 2019-01, apply to preliminary activities carried out by the Supervisory Department upon request from private parties that are not supervised under D elegated D ecree  n.117/2006 and subsequent amendments. The abovementioned fees refer to the following:
a) authorization applications
b) inquiries and requests for opinions
c) certification of data contained in public lists or registers.

A) AUTHORIZATION APPLICATIONS

The fees for authorization applications are based on the supervisory classification of the entity for which the Central Bank’s authorization is requested. To this end, entities are divided into "authorized entities," "other entities subject to supervision or required to register in CBSM’s lists/registers," and "other entities."
The fee amount is calculated against the maximum fee applied to banks, with other fees adjusted according to criteria such as the intermediary’s operational complexity and the variety of products and services offered.
For foreign financial companies, fees are lower than those required for a new incorporation, taking into account the prudential supervisory regime to which they are already subject in their home country. Additionally, a further distinction is made based on the entity’s geographical area (EU/non-EU), given the progressive and substantive alignment of San Marino banking and financial supervisory regulations with EU regulations, in accordance with the current Monetary Agreement. This alignment facilitates the Supervision’s preliminary assessment.

- Market entry authorizations – financial companies

QWhere the Central Bank already possesses relevant information and documentation for the assessment of an application, based on prior applications or prior roles held by the applicant within the banking and financial system, a 25% discount may be applied – upon decision of the Directorate – it being understood that a minimum fee of EUR 1,200 is applied in any case.

- Market entry authorizations – Registrations in Registers and Lists

Administrative fees were established based on the following criteria:

• Limited range of operations based on entity type
• Absence of financial and prudential parameters similar to those used for authorized entities
• Low systemic risk
• Possibility to operate as a natural person

In line with these criteria, the following fees were adopted: 

• EUR 500 for natural persons/sole proprietorships
• EUR 1,000 for legal persons/business entities 

for the registration in the following registers/lists:
a) Insurance intermediaries
b) Financial promoters
c) Independent financial advisors
d) Professional trustees
e) Servicers 


- Information prospectus and white papers
The procedures for the approval of the information prospectus pursuant to Article 107 of Law 165/2005 and those for the release/publication of the white paper pursuant to Article 8 Paragraph 1 of Delegated Decree 138/2024 require the payment of a fixed fee of EUR 4,000 and EUR 2,000, respectively, for each procedure.

B) INQUIRIES AND REQUESTS FOR OPINIONS

The cost for inquiries and requests for opinions is calculated on a case-by-case basis, taking into account the analysis, study, research, or interpretation activities required to provide the response, it being understood that a minimum secretarial fee of EUR 1,500 is applied. Administrative fees apply only when the inquiries require the interpretation of existing regulations or in-depth analysis to identify applicable rules, rather than simply referencing provisions or application methods of current supervisory regulations.

C) CERTIFICATION OF DATA CONTAINED IN PUBLIC LISTS OR REGISTERS

Regarding requests for formal certification of data contained in the public registers and lists maintained by the Central Bank for supervisory purposes, a fixed administrative fee of EUR 100 is applied for each register or list whose data, whether historical or current, is certified.

D) PROCEDURE FOR THE APPLICATION OF ADMINISTRATIVE FEES


Since the initiation of the investigation process by the Supervision Department is contingent upon the receipt of the administrative fees as described above, the following should be considered:

• For authorization and/or certification requests, the documentation must be submitted alongside a copy of the bank transfer order made to the Central Bank of the Republic of San Marino, using the following bank details (IBAN): SM93 V 03225 09800 000010017382, indicating the following reason for payment: ‘Diritti di segreteria ex art.21 Reg.2019-01- rif. Istanza [please, specify the name of the entity or register/list referred to in the request]’.
• For requests for opinions and/or inquiries, the Central Bank will promptly inform the applicant of the amount of the applicable administrative fees, as well as the estimated processing time for the request, along with the payment instructions.

Authorization requests, requests for opinions, and interpretation queries for which administrative fees have been applied will be considered withdrawn if the payment of the fees is not made within 30 days since their settlement. Similarly, certification requests for data in public registers, lists, or records, will expire 30 days thereafter if not submitted with a copy of the bank transfer order.

(The administrative fee chart was updated as per the Governing Council’s resolution dated 06/11/2024.)