The Central Bank of San Marino has opened a public consultation on a draft Regulation on independent financial advisors, intended to implement Article 25-bis of Law No. 165/2005 (LISF) and replace the existing 2020 framework. The draft is designed to integrate and align the advisor regime with the investment services rulebook issued at the end of 2024 in connection with, among others, the transposition of Directive 2014/65/EU (MiFID II). The proposed rulebook expands and updates the definitional perimeter, establishes a public register with separate sections for individuals and independent advisory companies (SCFI), and sets entry and ongoing requirements on honourability, professional competence (including an accredited assessment), independence and incompatibilities. It also introduces detailed conduct and organisational rules, including client classification, suitability assessment, cost and charges disclosures, conflicts of interest controls, record-keeping, annual submissions to the supervisor, mandatory continuing professional education (30 hours annually) and professional indemnity insurance with minimum coverage of EUR 1 million per claim and annual aggregates of EUR 2 million for individuals and EUR 5 million for SCFI. The draft reinforces the “independent” model by prohibiting advisors from holding client money, financial instruments or crypto-assets and from receiving fees or benefits from third parties, and includes provisions governing cross-border activity for Sammarinese and foreign advisors. The consultation closes on August 29, 2025.
Central Bank of San Marino 2025-07-01
Central Bank of San Marino launches consultation on new regulation for independent financial advisors
The Central Bank of San Marino has launched a public consultation on a draft Regulation for independent financial advisors to implement Article 25-bis of Law No. 165/2005, replacing the 2020 framework. The draft aligns with the investment services rulebook and MiFID II, expanding definitions, establishing a public register, and setting requirements for honourability, competence, and independence. It prohibits advisors from holding client assets or receiving third-party fees and mandates professional indemnity insurance and continuing education.