If you own a Costa Rican corporation, whether a Sociedad Anónima or a Sociedad de Responsabilidad Limitada, there is a new compliance requirement on your radar. The National Registry has formalized an obligation for all mercantile companies to register an email address, and two concrete developments in 2026 are putting that obligation into motion.
The Legal Basis: Directriz DPJ-002-2026
First, the Dirección Registro de Personas Jurídicas published Directriz DPJ-002-2026 in La Gaceta, with an effective date of August 24, 2026. The directive, addressed to public officials, notaries, and the general public, clarifies the legal obligation that already exists under Laws No. 10,597 and 10,962 for companies to have a registered email address on file with the National Registry.
We want to be transparent here: we are in the process of confirming the exact titles, subject matter, and enactment dates of those two laws directly against La Gaceta, and we will update this post as needed. Misidentifying the governing legislation is not something we take lightly.
The New ACE Self-Service System
Second, the Junta Administrativa of the Registro Nacional approved the launch of a new self-service platform called ACE, which stands for Autogestión de Correos Electrónicos. This system is set to go live on September 20, 2026, and is designed to allow legal representatives to register or update their company's email address directly, without going through a notary public each time.
Based on the information available, access to the ACE system appears to require the legal representative to hold a valid digital signature, though we recommend confirming this procedural detail before relying on it, since eligibility requirements or exceptions may apply that are not yet fully documented publicly.
What This Means for Expat-Owned Companies
What does this mean in practice for expats who own Costa Rican companies? In plain terms: Your company needs a registered email address on file with the National Registry. Many corporations held by expats, often used for property ownership, business operations, or investment purposes, may not have this in place yet, particularly if the company was formed years ago and has not been actively updated.
Consequences of Non-Compliance
We want to be straightforward about one thing: The specific consequences of non-compliance are something our attorneys are actively reviewing. The directive and the underlying laws may include deadlines, transitional provisions, or concrete sanctions, and we will not speculate about those details until we have confirmed them directly from the source documents. What we can say is that having an unregistered or outdated company profile with the National Registry generally creates friction, whether you are trying to sell property, execute a contract, or make changes to your corporate structure.
What to Do Next
If you are unsure whether your corporation has a registered email address, now is a good time to find out. If you hold a digital signature as the legal representative of your company, the ACE system may allow you to handle registration directly once it launches. If you do not, or if you are uncertain about your company's current status, reaching out to a local attorney is the straightforward path forward.
At Fortuna Lawyer, we work with expats and locals, both in Costa Rica and abroad, on exactly these kinds of corporate compliance questions. If you have questions about your company's standing or what this new requirement means for your specific situation, we are happy to take a look.
This article is for general informational purposes only and does not constitute legal advice. Reading it does not create an attorney-client relationship. For guidance on your specific situation, contact an attorney here.