The Registration of Shareholders Has Been Delayed

Official Notice Issued by Costa Rican Authorities

The Ministerio de Hacienda, together with the Banco Central de Costa Rica (BCCR) and the Instituto Costarricense sobre Drogas (ICD), issued an official notice on February 22 addressing the implementation timeline for the Registration of Shareholders.

According to the notice, “with the objective of facilitating the fulfillment of the obligation that companies have to provide the composition of their social capital, as well as the identification of the final beneficiaries,” and based on the Law to Improve the Fight against Fiscal Fraud, the month of September was established as the starting month for legal entities to submit the required information to the BCCR.

This information must be reported through the Central Bank of Costa Rica, which is the authority designated to receive and manage the shareholder and beneficial ownership data.

Online Platform Ready, Registration Temporarily Postponed

The BCCR confirmed that it has already developed and enabled the corresponding online platform to receive shareholder and beneficial ownership information from Costa Rican legal entities.

However, despite the platform being operational, the BCCR decided to delay the registration process temporarily. This delay is intended to allow additional time to review several factors that may affect the registration process, including the interaction of these reporting obligations with the enforcement of the new tax legislation.

Awareness Campaign for Business Owners

As part of this adjustment, the BCCR also agreed to implement an awareness and educational campaign aimed at business owners and legal representatives. The purpose of this campaign is to explain the scope of the obligation and to guide companies through the practical steps required to comply.

This campaign will focus, among other things, on:

• Understanding the shareholder and beneficial ownership reporting requirement

• How to obtain a digital signature

• How to access and properly use the BCCR online reporting platform

The intention is to ensure that companies are adequately informed and technically prepared before the reporting obligation becomes enforceable.

Updated Timeline: March to September

At this stage, it is sufficient to note that the original timeline has been formally adjusted. What was initially expected to begin in March has now been moved to September, giving legal entities additional time to prepare for compliance.

Further guidance and clarification are expected as the authorities move forward with the awareness campaign and finalize implementation details.

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