The Central Bank of the Republic of San Marino has opened a public consultation on draft regulations to establish an Investor Compensation Fund for the investment services sector, providing investor protection similar to depositor guarantees. The proposed scheme would pay compensation of up to EUR 20,000 per investor when an investment service provider is placed into Administrative Compulsory Liquidation and, due to insolvency and asset commingling, cannot return client cash or financial instruments in the short term. Under the draft, the fund would be set up at the Central Bank under an asset-segregation regime but without separate legal personality. Membership would be mandatory for investment service providers, except those authorised exclusively for investment advice and firms that do not hold client money or financial instruments, with specific provisions for branches of EU/EEA and non-EU firms. Funding would be ex post only, with member contributions calculated on a solidarity basis and proportional to each member’s volume of protected investments, subject to a cap set at the lower of 10% of the firm’s protected investments or 50% of the average positive income recorded over the last three approved annual accounts, with any excess reallocated across other members. Governance would sit with an internal management body at the Central Bank tasked with claims assessment, levy calculation and disbursement, with monies held in a dedicated non-interest-bearing account only for the period needed to execute payments. The consultation closes on 8 September 2025.

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