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San Marino · Agentic software engineering

Software Development for Companies in San Marino

An easy mistake when a company in San Marino hires engineers abroad is to treat data protection as an EU question. The Republic is not an EU member state, and its own Law 171/2018 decides when personal data may leave the country. As of early October 2026, the EU Association Agreement that would oblige it to take over the GDPR was still waiting to be signed, so working with a studio in Türkiye needs a transfer basis under the Republic's rules.

Curiosive works from Ankara, Türkiye, building software end to end or joining as an embedded monthly engagement, with AI coding agents doing the implementation volume and a senior engineer reading every diff before it merges. Ankara is one or two hours ahead of you depending on the season, so most of a working day is shared; the exact numbers are below.

24
published portfolio projects
5+
years building for production
12
countries the work runs in
100%
of code read by a senior engineer
1 day
to hear back, from the engineer

Time zones: Ankara and San Marino share most of the working day

Ankara runs on UTC+3 all year because Türkiye does not use daylight saving time. San Marino is on UTC+1 in winter and UTC+2 in summer, so the gap changes with the season. In winter Ankara is 2 hours ahead: when our day starts at 09:00 it is 07:00 for you, our 18:00 is your 16:00, and your 09:00 is 11:00 for us, which leaves 7 shared hours in a standard 09:00 to 18:00 day. In summer Ankara is 1 hour ahead: our 09:00 is your 08:00, our 18:00 is your 17:00, your 09:00 is our 10:00, and the overlap grows to 8 hours. Work runs on Türkiye business hours. The one short weekly call fits inside the shared hours in either season, and everything else runs on written, asynchronous decisions.

Sending personal data from San Marino to engineers in Türkiye

Article 46 of Law 171/2018 lets personal data move without prior authorisation to and from EU member states, countries with a European Commission adequacy decision, and countries with which the Republic has signed bilateral data-exchange agreements. Türkiye is outside the EU and was not on the Commission's adequacy list as of 2 October 2026, so engineers in Ankara working with production data fall under Article 47 unless such an agreement covers it. Article 47 requires adequate safeguards, such as standard data protection clauses adopted by the Garante or the European Commission, or binding corporate rules, plus enforceable rights and effective remedies for data subjects. For EU personal data in the system, EDPB Guidelines 05/2021 treat remote access from a third country as a GDPR transfer when the transfer criteria are met, even if data is only shown on a screen. So: clauses before access, no production data in development, access granted per task. A lawyer should confirm the clause set once.

The EU Association Agreement and what changes in San Marino

Negotiations on the Republic's Association Agreement with the EU ended in December 2023. Coreper and the EU Council approved it for signature in July 2026, and as of early October 2026 signature was scheduled for 19 October 2026. The Consiglio Grande e Generale must then ratify it before provisional application, which the Foreign Affairs Secretary expects in January or at the latest February 2027. From then on the Republic must take over the EU digital acts in its annexes, among them the GDPR, the ePrivacy Directive, eIDAS, the Digital Services Act and the Digital Markets Act; Annex XI's artificial intelligence chapter does not list the AI Act. In the other direction, the European Commission has not adopted an adequacy decision for San Marino, so EU personal data sent to a system there needs another GDPR transfer mechanism.

Public tenders and startup status for software buyers in San Marino

A company from outside the Republic that wants to bid in its public tenders must register its legal representative in the Registro dei Domicili Digitali with a standard, non-PEC email address and a valid digital signature, upload digitally signed PDF/A documents, and join the Registro Unico dei Fornitori under Delegated Decree No. 87 of 26 May 2023 and Regulation No. 6 of 6 July 2023. Public buyers should allow for that step. Startups have a different route: the High Technology Enterprise regime (Delegated Decree No. 101/2019), certified by San Marino Innovation, lasts up to 12 years in three stages, with income-tax benefits, share capital from EUR 1 for the first 3 years and work-for-equity. The certificate is valid for 12 months and must be renewed each year.

How the agentic engineering loop handles San Marino personal data

An engineer writes a scoped task with acceptance criteria and the boundaries the agent must not cross; here one boundary is that agents work against test data, not the production records the Article 47 clauses cover. A coding agent such as Claude Code or Cursor reads the existing code, plans, implements, updates tests and runs the checks before proposing a change. A senior engineer reviews every diff and continuous integration re-runs the checks. Data models, authentication, authorization and anything touching personal data stay with engineers. Agents change how much ground is covered in a week, not who is accountable. We rebuilt Zing Coach (zing.coach) from Webflow to Next.js, revived RateItAll (rateitall.com) with its 12M+ reviews, and maintained the Detailed SEO Extension for 600,000 users through its acquisition by Ahrefs.

Questions

The things people ask before starting.

Can a San Marino company outsource software development to Türkiye under Law 171/2018?

Yes, provided safeguards are in place. Unless a bilateral data-exchange agreement covers Türkiye, the transfer relies on Article 47: standard data protection clauses adopted by the Garante or the European Commission, or binding corporate rules, with enforceable rights for the people whose data it is. Put them in place before engineers get access to personal data.

Does the GDPR apply to software built for San Marino?

Not as San Marino law yet. The Republic is outside the EU and applies Law 171/2018. As of early October 2026 the Association Agreement was due to be signed on 19 October 2026; once it applies, the Republic must take over the GDPR, with provisional application expected in January or at the latest February 2027. EU users of your product are a separate question.

What is the time difference between San Marino and Ankara?

Ankara is 2 hours ahead in winter and 1 hour ahead in summer, giving 7 shared hours in a 09:00 to 18:00 day in winter and 8 in summer. Your 09:00 is 11:00 in Ankara in winter and 10:00 in summer, because Ankara stays on UTC+3 all year.

How much does a monthly software development engagement cost?

The starting point is $2,000 per month for AI-accelerated development, with scope and capacity set out in writing once a discovery call has defined the work. Nothing locks you in. Contracting is cross-border, since Curiosive works from Ankara and has no office in San Marino, and a releasable increment every week shows what the month bought.

How it starts

What happens after you write to us.

  1. 01

    You describe the product

    One paragraph on what you are building, roughly when you need it, and who it is for. No brief, no form with fifteen fields.

  2. 02

    You get a reply within a day

    From the engineer who would do the work, not a sales team. If we are not the right fit we say so, and where possible we point you somewhere better.

  3. 03

    You get a scoped plan

    Scope, price and timeline in writing before anything is committed. You decide with the numbers in front of you.

No long contract to begin, no lock-in to our tooling, and the code is yours from the first commit.

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Looking for an engineering partner for the long haul?

A short note about the product, the timeline and who it is for is enough to start. You will hear back from the engineer who would do the work, not a sales team.

Ankara / Türkiye · Working across European and US time zones