Licda. Xochilt Quezada López.
A recent court ruling has introduced a significant change for companies and legal entities in Costa Rica regarding the mandatory Registry of Transparency and Final Beneficiaries (RTBF) declaration. Effective immediately, special powers of attorney can no longer be used to delegate the filing of this report.
The Court's Decision
On April 10, 2025, the Administrative and Civil Tax Court of San José issued resolution 2025-003672, rejecting a precautionary measure filed by the Costa Rican Bar Association. This ruling temporarily suspends the regulation that previously allowed the use of special powers of attorney for RTBF submissions.
As a result, until a final decision is reached in the ongoing case, legal representatives who cannot personally file the declaration must now grant a full power of attorney (poder generalísimo). This is a much broader authority that must be formally inscribed in the National Registry's Registry of Legal Entities.
Central Bank Confirms New Procedure
Reinforcing this change, the Central Bank of Costa Rica issued a communiqué (CD-012-2025) on August 13, 2025. The notice reminds all obligated parties that the only way to authorize a third party to file the RTBF declaration is through a registered generalissimo power of attorney.
The communiqué clarifies that this is considered an exceptional measure, intended for cases where the legal representative does not have a digital signature to complete the process themselves.
What This Means for Your Business
For all companies, trusts, and other legal entities required to file the RTBF declaration, this is a critical procedural update.
Special powers of attorney are currently invalid for submitting the RTBF declaration.
If a legal representative cannot file personally, they must grant a generalissimo power of attorney.
This power of attorney must be officially registered with the National Registry before the authorized person can access the RTBF system.
This measure is part of Costa Rica's ongoing efforts under Law 9416 to improve the fight against tax fraud. The Ministry of Finance and the Costa Rican Drug Institute define the rules for the RTBF, which are then administered by the Central Bank.
For more official information, please visit the Ministry of Finance website at https://www.hacienda.go.cr/
The information provided is for informational purposes and does not constitute legal or financial advice. Consult a qualified Costa Rican professional for your specific situation. ©2004-2025 Costa Rica Expertise. With credit (CC BY 4.0), you can use it for free. 1250815 ZZ!
