Transparency and Final Beneficiaries Registry: 2026 Annual Ordinary Filing
Transparency and Final Beneficiaries Registry: 2026 Annual Ordinary Filing
With the arrival of April, the deadline to comply with the annual ordinary filing before the Transparency and Final Beneficiaries Registry (RTBF) before the Central Bank of Costa Rica is once again approaching.
This obligation applies to legal entities and other legal structures registered in the country, which must annually report information related to their ownership structure and their ultimate beneficial owners. For the 2026 period, the deadline to submit the filing is April 30, and entities are therefore encouraged to review in advance the information currently registered and prepare the documentation required to comply with this obligation in a timely manner.
Unlike previous years, it is no longer possible to submit the filing through special powers of attorney. Consequently, if the legal representative does not have a digital signature or is unable to complete the filing directly, it will be necessary to grant a general power of attorney authorizing a third party with a digital signature to submit the declaration before the RTBF.
This power of attorney may be granted:
If your company has experienced any changes in its shareholding structure or ultimate beneficial owners, we kindly ask that you inform us in a timely manner so we may analyze the applicable requirements and prepare the corresponding documentation.
If no changes have occurred, we will inform you accordingly whether it is necessary to update supporting documentation or complete additional information for purposes of complying with the applicable regulations.
Monetary
Should there be any updates or changes related to the RTBF filing process, we will keep you duly informed.
For any questions or assistance you may require, please feel free to contact us at rbf@bdo.cr
This obligation applies to legal entities and other legal structures registered in the country, which must annually report information related to their ownership structure and their ultimate beneficial owners. For the 2026 period, the deadline to submit the filing is April 30, and entities are therefore encouraged to review in advance the information currently registered and prepare the documentation required to comply with this obligation in a timely manner.
Relevant changes in the filing procedure
According to the applicable regulations, the filing must be submitted by the legal representative of the entity using their digital signature, or by a duly registered general power of attorney holder (generalísimo).Unlike previous years, it is no longer possible to submit the filing through special powers of attorney. Consequently, if the legal representative does not have a digital signature or is unable to complete the filing directly, it will be necessary to grant a general power of attorney authorizing a third party with a digital signature to submit the declaration before the RTBF.
This power of attorney may be granted:
- Directly through a public deed executed by the legal representative, provided that such representative has sufficient authority to do so; or
- Through a resolution adopted by the shareholders, partners, or the relevant corporate body.
If your company has experienced any changes in its shareholding structure or ultimate beneficial owners, we kindly ask that you inform us in a timely manner so we may analyze the applicable requirements and prepare the corresponding documentation.
If no changes have occurred, we will inform you accordingly whether it is necessary to update supporting documentation or complete additional information for purposes of complying with the applicable regulations.
Penalties
Failure to submit the RTBF filing may result in the following sanctions:Monetary
- A fine equivalent to 2% of the gross income from the fiscal period preceding the violation.
- Minimum amount of three base salaries and a maximum of one hundred base salaries.
- Inclusion in the non-compliant entities list maintained by the General Directorate of Taxation.
- Restrictions on the issuance of legal status certificates or the registration of documents before the National Registry of Costa Rica.
- The obligation to state the non-compliance status in notarial certifications.
Should there be any updates or changes related to the RTBF filing process, we will keep you duly informed.
For any questions or assistance you may require, please feel free to contact us at rbf@bdo.cr