New National Registry Criteria for Representation and RTBF Filings

By Diana Granados, GM Attorneys at Law

Table of Contents

Costa Rica continues to refine its regulatory framework for the Annual Transparency and Final Beneficiaries Disclosure (RTBF), which all obligated entities are required to file with the Central Bank (BCCR) this April.

All companies registered in Costa Rica are legally required to file the Annual Transparency and Final Beneficiaries Disclosure (RTBF) this April. A recent update introduces changes designed to make the process more accessible across a wide range of corporate situations.

Recent Circular: Expanded Options for Companies

On February 19, 2026, the National Registry issued Circular DPJ-002-2026. This circular introduces new criteria for the registration of legal representatives and General Powers of Attorney, making the process more accessible for companies in a variety of corporate situations.

Two Valid Options for Granting Power of Attorney

The circular confirms that companies have two mechanisms to grant the necessary authority for RTBF filings:

A) Direct Grant by the Legal Representative

If the company’s legal representative is in Costa Rica and authorized under the bylaws or corporate records (personería) to grant powers of attorney, they may do so directly before a notary public.

B) Grant by Shareholders’ Meeting

If the legal representative is unavailable, resides abroad, lacks authority, or the position is vacant, the shareholders’ meeting may issue the power of attorney. For many companies, this route is the most practical and efficient.

Requirements for Power of Attorney

In all cases, the necessary instrument is a Full Power of Attorney (Poder Generalísimo) with a strictly limited scope: it must be granted exclusively for matters related to the RTBF Ultimate Beneficial Owners filing before the BCCR.

Complying with this obligation is essential to avoid fines and administrative penalties that may impact the company.

We’re Here to Assist

Our team is available to guide you through the registration process and provide tailored support based on your company’s structure and needs.

You can reach us at info@gmattorneyscr.com, and you’ll find additional resources and updates on our blog: https://gmattorneyscr.com/blog/.

THANK YOU!

Why Is Costa Rica So Biodiverse?

Stand on a misty ridge in Monteverde at sunrise, then head down to the Pacific by afternoon, and you feel the answer before anyone says a word. In a country smaller than West Virginia, the air changes, the trees change, the birds change, and even the smell of the...

Prostitution in Costa Rica: What to Know

Some Costa Rica questions arrive in a whisper, usually late in the conversation, after the talk about beaches, rainforest villas, school options, and where to find the best coffee. One of them is prostitution in Costa Rica - or, more accurately, prostitution in Costa...

Colone vrs the Dollar in Costa Rica

You feel it almost immediately in Costa Rica - not in the jungle air or the first sip of coffee, but at the cash register. A lunch special looks like a bargain in colones, your credit card statement lands in dollars, and suddenly the question of colone vrs the dollar...