Nikolai Timofejev
15 years in FinTech and payments. Maps your token to the right class and regulator, and leads the file all the way to the registration decision, including banking and payment rails.
Get a crypto license in San Marino.
San Marino wrote a dedicated DLT law in 2019 and refined it in 2024: Type A financial tokens sit with the Central Bank, Type B utility tokens with San Marino Innovation. A euro-using microstate inside Italy, outside the EU - a national framework with no MiCA passport, and we say that up front. We build the file end to end.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Crypto licenses obtainedlicenses obtained
Updated
San Marino in brief
A purpose-built DLT jurisdiction, EU-adjacent.
San Marino built its blockchain framework early and on purpose. Delegated Decree No. 86 of 13 June 2019 - ratifying a February decree of the same year - created the rules for blockchain entities: they register with San Marino Innovation, the state Institute for Innovation, which runs the DLT registry and oversees token offerings. The decree defined utility and investment tokens, set whitepaper and summary-note duties for issuers, and required prospectus-grade disclosure for investment tokens in line with the LISF, the financial services law. A 2024 refinement sharpened the picture: Delegated Decree No. 138 of 29 August 2024 split tokens into Type A - crypto-assets, meaning financial instrument tokens, fiat-referenced e-money tokens and cryptocurrencies, supervised by the Central Bank of San Marino - and Type B, everything else including utility tokens, which stay with the Institute. An operator handling both answers to the Central Bank.
Geography does real work here. San Marino is a microstate of about 34,000 people enclaved in Italy; it uses the euro under a monetary agreement with the EU, yet it is not an EU member - so there is no MiCA passport, and we say that plainly rather than in a footnote. What you get instead is a purpose-built national framework with a clean two-regulator taxonomy, a registry run by a state institute since 2019, joint-stock company form for domestic DLT operators, AML supervision by the AIF under Law No. 92 of 2008, and a 17% corporate tax rate. It fits token issuers and DLT projects that want a dedicated, reachable European home - and for EU-wide retail distribution we pair it with a MiCA route rather than pretend one is included.
San Marino built a dedicated DLT framework with Delegated Decree No. 86 of 2019: blockchain entities register with San Marino Innovation, which runs the DLT registry and oversees token offerings.
Decree No. 138 of 29 August 2024 refined the taxonomy: Type A financial tokens under the Central Bank, Type B utility tokens under the Institute. Euro-based, EU-adjacent - but national-only, with no MiCA passport. Corporate tax: 17%.
The regime
Two token types, two regulators.
Since the 2024 decree, the supervisor follows the token: Type B utility projects go to San Marino Innovation, Type A financial tokens to the Central Bank. The first job is classifying your token honestly; the second is building the file. We do both.
The token decides the regulator - Type B to San Marino Innovation, Type A to the Central Bank. We classify yours first.
01 - TYPE B · SAN MARINO INNOVATION
Utility tokens and DLT operators
The Institute's side: registration as a blockchain entity, utility-token issuance with a whitepaper and summary note, and DLT services in Type B tokens - the route most non-financial projects take.
The Institute's side: registration as a blockchain entity, utility-token issuance with a whitepaper and summary note, and DLT services in Type B tokens - the route most non-financial projects take.
- ✓Blockchain-entity registration with San Marino Innovation
- ✓Utility-token issuance (ITO) with whitepaper and summary note
- ✓DLT services in Type B tokens
- ✓Joint-stock company form for domestic operators
- ✓AML/CFT under Law No. 92/2008, with the AIF
- ✓Institute for Innovation supervision
02 - TYPE A · CENTRAL BANK
Decree No. 138 of 2024Financial tokens and stablecoins
The Central Bank's side: crypto-assets - financial instrument tokens, fiat-referenced e-money tokens and cryptocurrencies - with prospectus-level disclosure for investment tokens and full supervisory powers.
Type A: financial instrument tokens, fiat-referenced tokens and cryptocurrencies - Central Bank supervision, prospectus-grade disclosure.
- ✓Financial instrument (investment) tokens
- ✓E-money and fiat-referenced tokens
- ✓Cryptocurrency-related services
- ✓Prospectus-grade disclosure, in line with the LISF
- ✓Mixed Type A + B operators - Central Bank competence
- ✓Central Bank of San Marino supervision
Costs and timelines are confirmed for your case before any work begins. This is a national framework - no EU passport attaches to it - so we also map where your clients sit and whether a parallel MiCA route is needed.
Why San Marino
Small, early, and precisely drafted.
The framework rests on the 2019 blockchain decree and the 2024 token taxonomy, run by the Central Bank and San Marino Innovation - inside a euro-based microstate on Italy's doorstep.
✓
A purpose-built 2019 framework
San Marino wrote dedicated blockchain rules in 2019, ahead of most of Europe - Decree No. 86 was ratified on 13 June 2019. You build against a statute written for DLT, with seven years of practice behind it.Dedicated DLT rules since June 2019.
✓
A clean two-regulator taxonomy
Since Decree No. 138 of 29 August 2024, Type A financial tokens belong to the Central Bank and Type B utility tokens to the Institute. You know your supervisor from day one - no perimeter guessing.Your supervisor known from day one.
✓
EU-adjacent, euro-based
The euro under a monetary agreement with the EU, Italian banks and professionals next door, and Rimini forty minutes away. Operationally European - without EU membership, which cuts both ways.Euro books; Italy minutes away.
✓
17% corporate tax
A 17% general income tax on company profits, with token tax treatment written into the decree itself - utility tokens are assimilated to foreign currencies, so the position is knowable in advance.Token treatment written into the decree.
✓
A regulator you can reach
In a state of 34,000 people, the registry is run by a named institute that answers. Meetings happen, questions get replies - a working scale that large-jurisdiction applicants rarely experience.Microstate scale - questions get replies.
✓
Honest limits
National-only authorisation, no MiCA passport, a small home market. It fits issuers and DLT projects wanting a dedicated base; for EU-wide retail reach we add a MiCA licence rather than oversell this one.National-only; MiCA added where needed.
How it compares
How San Marino differs from other routes.
San Marino is the early, purpose-built microstate framework - national, not passported. The honest comparison is below.
San Marino vs other jurisdictions
| Feature |  San Marino | Other jurisdictions |
|---|---|---|
| Regulatory regime | DLT registration (Institute / Central Bank) | Licence or registration routes |
| Token taxonomy | Type A / Type B, set by decree | Often case-by-case |
| EU status | Euro user, non-EU - no passport | MiCA passport inside the EU/EEA |
| Corporate tax | 17% | Ranges widely |
Regulatory regime
San MarinoDLT registration (Institute / Central Bank)
Other jurisdictionsLicence or registration routes
Token taxonomy
San MarinoType A / Type B, set by decree
Other jurisdictionsOften case-by-case
EU status
San MarinoEuro user, non-EU - no passport
Other jurisdictionsMiCA passport inside the EU/EEA
Corporate tax
San Marino17%
Other jurisdictionsRanges widely
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| San Marino | DLT registration (Institute / Central Bank) | 17% corporate | Two-regulator taxonomy, national |
 Andorra | Digital Assets Act 2022 (AFA) | 10% corporate | National framework, supervised |
 Liechtenstein | TVTG + MiCA (FMA) | 12.5% corporate | EEA passport, premium bar |
 Monaco | Token-offering approvals | 25% corporate (activity-based) | Case-by-case, national |
San MarinoLicense typeDLT registration (Institute / Central Bank)
Taxation17% corporate
RequirementsTwo-regulator taxonomy, national
AndorraLicense typeDigital Assets Act 2022 (AFA)
Taxation10% corporate
RequirementsNational framework, supervised
LiechtensteinLicense typeTVTG + MiCA (FMA)
Taxation12.5% corporate
RequirementsEEA passport, premium bar
MonacoLicense typeToken-offering approvals
Taxation25% corporate (activity-based)
RequirementsCase-by-case, national
Before you apply
Requirements for the DLT registration.Requirements for the DLT registration.
The Institute and the Central Bank review files against the 2019 decree, the 2024 taxonomy and the AML law. The checklist below is what a passing registration is built around.
01
Sammarinese entity - joint-stock company form for domestic DLT operators, under Law No. 47 of 2006.
02
Correct regulator - Type A tokens to the Central Bank, Type B to the Institute; mixed books default to the Central Bank.
03
DLT-operator authorisation - the activity codes under Delegated Decree No. 50 of 14 March 2024.
04
Fit & proper management - directors and UBOs disclosed, with records the supervisor can verify.
05
Token documentation - whitepaper and summary note; prospectus-grade disclosure for investment tokens under the LISF.
06
AML/CFT framework - KYC, monitoring and reporting to the AIF under Law No. 92/2008, with a named officer.
07
Safeguarding of client tokens - custody policy and key-management design.
08
Systems and record-keeping the Institute or Central Bank can inspect.
09
Business plan - services, volumes and financials the supervisor can test.
10
Local substance - registered office and management in San Marino.
11
Honest scope - San Marino authorisation is national; EU distribution is planned separately, not assumed.
01
Joint-stock Sammarinese company.
02
Correct regulator by token class.
03
DLT-operator authorisation (Decree No. 50/2024).
04
Fit & proper directors, UBOs disclosed.
05
Whitepaper and summary note; prospectus for Type A.
06
AML/CFT to the AIF under Law No. 92/2008.
07
Safeguarding and key management.
08
Systems the supervisor can inspect.
09
Business plan the regulator can test.
10
Registered office and local management.
11
EU distribution planned separately.
Reflects Delegated Decree No. 86 of 13 June 2019 and Delegated Decree No. 138 of 29 August 2024, as of 2026. San Marino authorisation carries no EU passport - MiCA does not apply here.Decree No. 86/2019 + Decree No. 138/2024, as of 2026. No EU passport attaches.
How it works
From first call to the DLT registration.
01
Perimeter and token class
We classify your token against the Type A / Type B taxonomy, fix the competent regulator, and set scope, costs and timeline in writing.Type A or B fixed; scope in writing.
02
Sammarinese company
Joint-stock incorporation, registered office, directors and the governance layer the supervisor assesses behind the file.Joint-stock form, office, directors.
03
The registration file
Whitepaper, summary note or prospectus-grade disclosure, AML/CFT pack, custody and systems documentation - assembled to the decree's standard.Whitepaper, AML, custody - decree-grade.
04
Regulator review
The file before San Marino Innovation or the Central Bank, with every question round answered until the decision.Institute or Central Bank - answered fully.
05
Registration and operations
Entry in the DLT registry and the business live, with ongoing AML and reporting duties we can keep running - plus a MiCA route where EU reach is needed.Registry entry; MiCA added if EU reach.
Quick facts
RegulatorsCentral Bank · Institute
FrameworkDelegated Decree No. 86/2019
RefinedDecree No. 138 (29 Aug 2024)
TaxonomyType A / Type B tokens
Company formJoint-stock (SpA)
Corporate tax17%
CurrencyEuro - non-EU state
EU passportNone - national only
A small framework drafted with unusual precision - the taxonomy tells you your regulator before you file. The limit is reach: national authorisation, no passport, and we plan around that openly.
On the ground in San Marino
Run from our Dubai office, with Sammarinese counsel.
Prifinance - San Marino desk
City of San Marino · San Marino
City of San Marino, San Marino
01
Sammarinese incorporation
The joint-stock company formed under Law No. 47/2006, structured for DLT-operator registration from the first document.JSC built for the DLT registration.
02
The token classification
Your token assessed against the Type A / Type B taxonomy honestly - because the classification decides your regulator, disclosure bar and costs.Type A or B - it decides everything.
03
The registration file
Whitepaper, summary note, AML/CFT pack, custody and systems documentation - drafted by us and defended before the Institute or the Central Bank.Whitepaper, AML, custody - to standard.
04
Banking and operations
Euro accounts arranged on full disclosure, with Italian and Sammarinese options mapped to your flows before launch.Euro accounts on full disclosure.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
London
United Kingdom
7 Bell Yard
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of crypto companies in San Marino.
Company profits carry a 17% general income tax, and the blockchain decree wrote token treatment into law - a rarity that removes most of the guesswork.
17% corporate rate
The general income tax on company profits is 17%, with ordinary deductions. A registered DLT operator is taxed as a normal Sammarinese company - one clean figure to model.One clean figure to model.
Token rules in the decree
The 2019 decree assimilates utility tokens to foreign currencies and investment tokens to the underlying instrument - shares or debt of the issuer. Tax follows the classification, knowably.Treatment follows classification.
Issuance relief to test
The decree provided income-tax relief for qualifying token-transaction income at issuance. Whether your model qualifies is a legal question we answer in the opinion, not a promise we start from.Decree-based - confirmed per model.
Euro books, Italian doorstep
Accounting runs in euro under the monetary agreement, and cross-border work with Italian banks, auditors and counterparties is routine daily practice, minutes away.Cross-border routine, minutes away.
Indirect tax differs
San Marino levies no VAT; a single-stage import tax applies instead. For a services-and-tokens model the indirect position is genuinely different from the EU - we map it per case.No VAT - single-stage import tax.
Records serve both
The AML and registry record-keeping the framework requires also underpins the tax position - regulator-grade books double as tax-office-grade books.Regulator-grade books serve tax too.
Tax summary
Corporate income tax17%
Token treatmentSet by the decree
Issuance incomeDecree-based relief, tested per case
Indirect taxSingle-stage import tax, no VAT
CurrencyEUR
EU passportNone
*As of 2026. Token tax treatment follows the decree's classification - we confirm the position for your instrument before you rely on it.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Sammarinese company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, registered business.
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San Marino · DLT
Launch your crypto project in San Marino with expert support.
Full-service assistance - from company registration to the DLT registry entry with the correct regulator.
Get a consultation →Free legal opinion
Is San Marino the right fit for your project?
Our legal team will analyze your case at no cost and provide a written legal opinion: which token class, regulator or route fits your business.
Written assessment within 2-5 business days
Request a free conclusion →FAQ
The San Marino DLT framework, answered.
Does San Marino regulate crypto?+
Yes - through a purpose-built framework. Delegated Decree No. 86 of 13 June 2019 created the blockchain-entity regime under San Marino Innovation, and Delegated Decree No. 138 of 29 August 2024 refined the token taxonomy and split supervision with the Central Bank.
Who regulates what?+
The token decides. Type A crypto-assets - financial instrument tokens, fiat-referenced e-money tokens and cryptocurrencies - sit with the Central Bank of San Marino. Type B tokens, utility tokens included, sit with the Institute for Innovation. An operator handling both answers to the Central Bank.
Can I passport into the EU?+
No. San Marino uses the euro under a monetary agreement but is not an EU member, so MiCA does not apply and no passport exists. For EU-wide retail distribution we pair the Sammarinese base with a MiCA licence in a member state - and we say this before you commit, not after.
What entity do I need?+
A domestic DLT operator takes joint-stock company form under Law No. 47 of 2006, registers with San Marino Innovation and obtains the activity authorisation under Decree No. 50 of 14 March 2024. We build the company for the registration from the start.
What does a token offering require?+
A whitepaper and summary note for utility tokens, with clearly identifiable and accurate offer publicity. Investment tokens need prospectus-grade disclosure in line with the LISF. The Institute can demand more information or suspend a non-compliant offer.
How are crypto companies taxed?+
A 17% general income tax on profits. The decree itself sets token treatment - utility tokens as foreign currencies, investment tokens as the underlying instrument - and provided issuance-stage relief we test against your model. San Marino has no VAT; a single-stage import tax applies instead.
Why San Marino at all?+
An early, precisely drafted national framework with a reachable regulator, euro accounting and Italy next door. For token issuers and DLT projects wanting a dedicated European base without the MiCA bar, it is a working answer - within its stated limits.
Is such a small jurisdiction credible?+
Small, but real: a state institute has run the DLT registry since 2019, the Central Bank supervises financial tokens with inspection and sanction powers, and AML reporting runs to the AIF under Law No. 92/2008. The framework's size is a fact; its seriousness is another.
Does San Marino regulate crypto?+
Yes - a dedicated DLT framework since 2019.
Who regulates what?+
Type A: Central Bank. Type B: the Institute.
EU passport?+
None - non-EU; MiCA paired where needed.
Entity?+
Joint-stock company, registered DLT operator.
Token offering?+
Whitepaper + summary note; prospectus for Type A.
Company taxes?+
17%; token treatment set by the decree.
Why San Marino?+
Early, precise, reachable - within stated limits.
Credible at this size?+
Yes - state registry since 2019, Central Bank powers.
Client notes
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Founders who wanted it done right.
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One message away from your San Marino registration.
Get a free legal opinion on your project - our legal team will analyze your case at no cost and provide a written legal opinion: which token class, regulator or route fits your business.Free legal opinion: which San Marino token class and regulator fit your project and what it will cost.
✓Written legal opinion within 2-5 business days - free of charge✓A clear recommendation on token class and regulator, not a sales pitch✓Transparent fixed fees, confirmed up front✓EN · RU · ES speaking team
Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Central Bank of San Marino, San Marino Innovation or any other public authority. Licences and registrations are granted by, and obtained directly from, the competent authorities.