Real estate
Brokers, intermediaries, promoters and developers who buy and sell property professionally and habitually.
For businesses SUGEF supervises
SUGEF registration, and the file it takes.
Who has to register, every document a company files, and how long each one stays valid. Written for real estate agents, developers, lawyers, accountants and anyone who has been told to bring SUGEF paperwork to the bank.
8kinds of business the rule lists
17items in a company's file
15daysa digital personería stays valid
40daysfor SUGEF to decide
Every rule read in SUGEF's own documents
Registro Nacional documents, pulled for you
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Built in Costa Rica
Short answer
Businesses that SUGEF's rule Acuerdo 11-18 lists, including anyone who buys and sells real estate professionally and habitually (brokers, intermediaries, promoters and developers), must register with SUGEF before operating, through the SUGEF Directo platform with a Costa Rican digital signature. A company files its legal standing, its board and representatives, its owners of 10% or more, criminal record certificates, sanctions checks and a sworn statement that it has an anti money laundering manual. Registration is not a licence to operate.
Acuerdo SUGEF 11-18, article 5
Who has to register
The non-financial businesses the rule lists. SUGEF's training material defines habitual as activity repeated within a twelve month period.
Lawyers and accountants
When they carry out transactions for clients: real estate purchases and sales, managing a client's money, or buying, selling and running companies.
Trust service providers
Below the significant amount of US$400,000 over twelve months. Guarantee, testamentary and custody trusts are excluded.
Lenders
Anyone who lends in an organised and habitual way, with an exemption at or below an average of US$5,000 a month over twelve months.
Pawn shops
Listed on their own line of the rule.
Casinos
Physical or online, when operated from Costa Rica.
Precious metals and stones
Dealers in precious metals, precious stones and products that contain them.
Some non profits
Those that move money with high risk jurisdictions.
Las personas físicas o jurídicas que se dediquen de forma profesional y habitual a la compra y venta de bienes inmuebles, lo que incluye, pero no limitados a estos, los corredores, intermediarios, promotores, así como los desarrolladores de proyectos inmobiliarios.
Acuerdo SUGEF 11-18, article 5(b), the real estate line, verbatim
Escrow and fund administrationA separate article of the same rule. They must be companies set up for that single purpose, and they upload more documents than everyone else.
Notaries are not supervised by SUGEFFor this purpose they answer to a specialised unit of the Dirección Nacional de Notariado.
Registration is a duty, not a licence
SUGEF's own help page says it plainly: the listed businesses must register, and registering is not an authorisation to operate. Where a missing registration bites first is the bank account.
Acuerdo SUGEF 11-18, article 7
The file a company builds
What a sociedad anónima or S.R.L. gives SUGEF when it registers. The application itself counts as a sworn statement.
The company
- Company name, cédula jurídica, trade name and exact main office address in Costa Rica
in the application - The activities that require registration, described in detail, plus an email for notices
in the application - Registro Nacional or notarial certification of representatives, board, fiscal, address and term (the personería)
in the application
The people
- Name, ID, nationality and phone of legal representatives and attorneys in fact
in the application - Board members, the fiscal and the general manager
in the application - Criminal record certificates from country of birth, nationality, residence and Costa Rica
kept on file
Owners and money
- Owners of 10% or more, backed by a notary's certification or the RTBF declaration with the Central Bank seal
kept on file - Where the working capital and share capital came from
kept on file - IBAN of a Costa Rican account at a SUGEF supervised bank, used only for the activity
in the application
Compliance
- Proof of checks against the UN and OFAC sanctions lists
kept on file - Sworn statement that the board approved an anti money laundering manual and risk procedures
kept on file - Registration on the UIF platform for suspicious transaction reports
in the application
in the applicationstated in the filingkept on filefor real estate and the other article 15 bis businesses, the proof is kept for SUGEF with a backup copy in a second location, not uploaded
Escrow and fund administration companies must upload those papers instead, plus an assurance report from a CPA on the manual and procedures. Foreign public documents must be apostilled or legalised and come with an official Spanish translation.
The validity clock
How long each document stays valid
Some of the file expires in two weeks. Order the time sensitive documents last.
From file to registered
How the registration runs
SUGEF assigns each registrant a type. Type 1 must name a compliance officer; types 2 and 3 name a liaison person instead. If SUGEF tells a business it must register, it has 30 business days.
Gather the file
Order the time sensitive documents last: the personería and the RTBF declaration expire fastest.
File in SUGEF Directo
Through IPO, SUGEF's registration system, signed by the legal representative with a Costa Rican digital signature.
SUGEF decides
Within 40 calendar days, or 60 for complex cases. The application counts as a sworn statement.
Bank account goes live
A bank may open the account before, but may not activate it until the registration is shown.
Keep it current
Report any change within 3 business days. Display SUGEF's fixed warning text in the office and on the website.
Stop cleanly
A business that stops the activity asks to be deregistered within 10 business days.
Two different rulebooks
SUGEF asks, and so does your bank
Banks and escrow agents supervised by SUGEF follow Acuerdo CONASSIF 12-21. The documents overlap, the deadlines do not.
Registering with SUGEF
Acuerdo SUGEF 11-18
- Personería: digital 15 days, paper 1 month
- Owners of 10% or more: notary's certification within 1 month, or the RTBF declaration within 15 calendar days
- Criminal records, sanctions checks, manual, source of capital
- An account at a supervised bank used only for the activity
Opening the bank account
Acuerdo CONASSIF 12-21
- Personería: digital 15 days, paper 1 month (article 34)
- Owners of 10% or more: notary's certification within 1 month traced to the natural persons, or the RTBF declaration within 30 calendar days
- Identity of the legal representatives, and the resident agent's details when the representative lives abroad (article 35)
- Source of funds behind the activity, and for escrow clients, behind every international transfer
A bank may open an account for a business that has to register before the registration is done, but it may not activate it until the registration is shown, and it must stop the service if the registration is suspended, cancelled or revoked.
What we have not confirmed
- The current wording of articles 15 bis and 81 of Ley 7786 after the 2017 reform (Ley 9449). This page quotes SUGEF's registration rule, not the law itself.
- The current supervision fee and the current fines for not registering. SUGEF publishes the fee each March and it is paid in May; we did not find this year's amount published on 26 October 2026.
- Whether a non resident foreigner can register in their own name.
- Bill 25.129 would rewrite parts of the law and add notaries and some registered movable property to the list. Its committee text was published in La Gaceta on 22 April 2026. It is a bill, not law.
The document almost every filing starts with
The company's personería
SUGEF and the banks both ask for it, and a digital one counts for only 15 days, so order it close to the filing.
Issued by the Registro NacionalPersonería jurídica
$49
The Registro Nacional certification for any Costa Rica company:
- The company's legal existence
- Its representatives and their powers
- The certification SUGEF item 17 and bank article 34 both refer to
Pulled for you · delivered by email
Refunded if we cannot pull itStraight from the official registry. If the Registro Nacional cannot issue it, you do not pay.
Folio does not file SUGEF registrations. The company's legal representative files with a digital signature, usually with a lawyer or compliance adviser. Opening the company itself? See opening a Costa Rica corporation.
Questions
Frequently asked
Do real estate agents in Costa Rica have to register with SUGEF?
Yes, when they buy and sell property professionally and habitually. Acuerdo SUGEF 11-18 names brokers, intermediaries, promoters and developers of real estate projects among the businesses that must register.
What corporate documents does SUGEF ask for?
The company's legal standing and its representatives, board, fiscal and manager; its owners of 10% or more backed by a notary's certification or the RTBF declaration; criminal record certificates; sanctions list checks; a sworn statement on its anti money laundering manual; the source of its capital; and a bank account used only for the activity.
How long is a personería jurídica valid for a SUGEF filing?
A digital Registro Nacional certification counts for 15 days and a paper one for 1 month under Acuerdo SUGEF 11-18.
Is SUGEF registration a licence to operate?
No. SUGEF states that registration is not an authorisation to operate. It is a supervision duty for the listed businesses.
Do notaries register with SUGEF?
No. Under Acuerdo SUGEF 11-18 notaries are supervised for this purpose by a specialised unit of the Dirección Nacional de Notariado.
Sources. Every rule on this page was read in SUGEF's own published documents on 26 October 2026. Costa Rica changes these rules from time to time; check the current version before you file.
This page is general information, not legal advice. Folio is not a law firm.
- SUGEF, Acuerdo SUGEF 11-18, registration rule for businesses under articles 15 and 15 bis of Ley 7786 (version 11, 23 October 2023)
- SUGEF, training on Acuerdo SUGEF 11-18 (18 March 2025)
- CONASSIF, Acuerdo CONASSIF 12-21, what supervised banks must ask clients for (version 7, 10 November 2022)
- SUGEF, methodology for the supervision fee (version 1, 9 November 2020)
- SUGEF, information and help for registered non-financial businesses (APNFD)
- Imprenta Nacional, La Gaceta, Alcance 40 (22 April 2026): bill 25.129, committee text
This page is general information, not legal advice. Folio is not a law firm.
