Valentino Coletto
Padua
According to Coletto, San Marino’s updated criteria are likely to deter casual applicants and attract only deeply committed retirees.
San Marino has introduced new financial requirements for its atypical residency program for foreign pensioners, effective April 28, 2025. The updated rules significantly reshape the criteria by requiring not only a high income but also the long-term placement of assets within the country’s banking system.
Applicants must now meet two conditions:
- A demonstrable annual gross income of at least €120,000, and
- A portfolio of movable financial assets—defined as liquid funds or investment securities—worth at least €300,000, held in a San Marino bank for the entire duration of their residency.
This marks a shift from previous rules that permitted foreign-held assets. Under the new regulation, applicants must transfer and retain their wealth locally, creating a direct financial tie to the country.
While the €120,000 threshold had already replaced the previous €50,000 minimum in late 2024, the asset custody requirement is entirely new. Professional interpretations confirm that income may include a range of sources beyond pensions, such as rental income, dividends, and financial returns.
Only movable assets qualify under the €300,000 requirement. Real estate, trusts, or other non-liquid holdings do not meet the criteria unless converted into deposit accounts or marketable securities held within the Republic. Applicants will likely need to verify continued compliance, although the law does not outline a specific enforcement process.
These rules apply exclusively to private-sector pensioners. Public-sector retirees, including those from Italy’s INPDAP system, remain excluded from the preferential 6% tax rate. That rate applies for 10 years and may be extended through permanent residency.
A parallel rule also remains in effect regarding rental contracts. Applicants must hold exclusive preliminary lease agreements, which are contingent on final residency approval.
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