Costa Rica Company Email Rules: ACE and the New Deadline

Costa Rica has made registering a company’s official email address easier. Its new online system, ACE, allows eligible legal representatives to add or change that address without a notary.

But “online” does not mean anyone can do it. The representative must meet the Registry’s requirements and have a valid Costa Rican certified digital signature. Someone holding only a power of attorney cannot use ACE in that capacity.

Here is what owners need to know as of Sept. 29, 2026.

Registration deadline: Dec. 3, 2027, for existing commercial companies without a registered email.

Official ACE portal: rnpdigital.com/ace

What changed

Law 10.597, published Dec. 3, 2024, created the requirement by amending Article 18(10) of the Commercial Code, Código de Comercio. Companies must have an email address for official administrative and judicial notices, in addition to their physical address in Costa Rica.

Initially, registration used notarial documents. Law 10.962, effective June 3, 2026, added another option to Article 19: an electronic sworn declaration, declaración jurada, signed by the legal representative with a certified digital signature.

The Registry subsequently introduced Email Self-Service, Autogestión de Correos Electrónicos, known as ACE. It is operating as of September 2026.

The new option supplements the notarial procedures. It does not eliminate them.

Directive DPJ-002-2026, published Aug. 24, 2026, replaced Directives DPJ-002-2025 and DPJ-001-2026. It governs the current registration framework and explains the extended deadline.

Who must register an email

The requirement covers commercial companies, sociedades mercantiles: corporations, sociedades anónimas; limited liability companies, sociedades de responsabilidad limitada; general partnerships, sociedades en nombre colectivo; and simple limited partnerships, sociedades en comandita simple.

An S.A. or S.R.L. that merely holds real estate or a vehicle is not exempt because it has no business income. The requirement concerns its legal form.

New companies must include the address in their incorporation deed. The extended deadline for existing companies is not permission to incorporate a new company without one.

This particular registration does not apply to every legal entity. The directive excludes civil societies, individual limited liability enterprises, domestic associations under Law 218 and foundations under Law 5338. Certain foreign entities have separate rules.

Only one official email is recorded per company. Owners should choose an account that will remain accessible and be monitored regularly.

Who can use ACE

ACE is available around the clock to a registered, currently authorized legal representative with a valid certified digital signature for an individual under Costa Rican law.

The Registry says a representative can access the system whether the company’s representation is joint or separate. The person remains responsible for having the authority to act.

Being a shareholder is not enough. Nor is being the company’s accountant, lawyer, or attorney-in-fact, apoderado. The Registry expressly excludes attorneys-in-fact from using ACE solely under that authority. An attorney-in-fact with generalissimo powers, apoderado generalísimo, may instead use the traditional public-deed route through a notary, subject to the scope of those powers and applicable representation rules.

The company must be registered, and its corporate term must remain in force. It must also meet applicable compliance requirements, including corporate tax, beneficial ownership reporting, and, where applicable, social security and FODESAF obligations.

ACE does not require a notary or a separately prepared declaration. The system generates the declaration for the representative to sign.

How to register or change the address

1. Check the existing record

First confirm whether the company already has the correct email registered. If it does, ACE’s arrival does not require a duplicate filing. Check who has access to that mailbox and who handles official notices.

2. Prepare the representative’s digital signature

Use a valid Costa Rican certified digital signature, firma digital certificada. Follow the ACE portal’s setup instructions for the signing software and identification process. A scanned handwritten signature is not the credential the system requires.

3. Enter the official ACE portal

Open ACE on the National Registry website. Enter the representative’s identification information and complete digital authentication.

4. Select the company

ACE displays companies for which the user appears as a legal representative. Choose the correct company. Each company requires its request.

If the company does not appear, send a query to [email protected]. Its absence is not proof that it is exempt.

5. Enter and carefully review the email

Check every character before signing the system-generated declaration and completing the request. The representative supplies the address directly; a registrar does not transcribe it or review the request through ordinary registration examination.

6. Save the evidence and verify the result

The Registry says the company’s public record updates immediately when the request is completed. Download the receipt before leaving the transaction. The declaration is available for a one-time download within seven calendar days; afterward, it can be obtained through Registry channels using its reference numbers.

Verify that the public record shows the intended address. Keep the receipt with the company’s records.

What foreign owners should know

The practical questions are who holds the registered representative position and whether that person has the required digital signature.

A foreign owner without that credential cannot complete ACE merely by uploading a passport or signing a PDF. Another eligible registered legal representative may be able to act. Otherwise, the notarial route remains available.

Do not assume that an attorney-in-fact who files the company’s beneficial ownership declaration can also use ACE. These are different procedures with different eligibility rules.

As a practical precaution, assign someone to check the mailbox daily, including spam folders, and forward legal notices promptly. Maintain access when an employee, adviser, or property manager leaves. The registered address can be changed later as often as necessary.

Alternatives when ACE is unavailable

Companies may still use a public deed, escritura pública, or have a shareholders’ or members’ resolution incorporated into a notarial instrument, protocolización de acta.

For the deed route, the directive permits the legal representative or an attorney-in-fact with general or generalissimo powers, apoderado general o generalísimo, acting within the relevant authority and joint or separate representation rules. A notary should verify the authority before preparing the document.

Fees and La Gaceta publication

Ordinary ACE email registration and changes are exempt from government registration charges and Gazette publication during the transitional period ending Dec. 3, 2027.

An email-only inclusion or modification through the notarial route also benefits from the directive’s temporary exemption from registration duties, stamps, and related taxes. However, the notarial route still requires a notice in La Gaceta. The directive allows registration while publication is being processed.

Notarial fees and publication costs remain separate expenses. Combining the email request with other corporate changes can trigger charges for those additional acts.

Formal rectifications of errors originating outside the Registry have a separate fee provision. Do not assume every correction is exempt; ACE’s guidance directs users who enter an incorrect address to submit a new request.

From Dec. 4, 2027, the current guidance requires applicable fiscal charges for email registrations and changes. The present exemption should not be described as permanent.

Deadlines and consequences

Earlier guidance referred to June 2026, a subsequent September extension, and Dec. 31, 2026. These are not the current Registry deadline.

Law 10.962 contains both the December 2026 date and new transitional periods. Directive DPJ-002-2026 expressly reconciles them by applying the longer period: Dec. 3, 2027.

Beginning Dec. 4, 2027, the Registry of Legal Entities will not register documents relating to a company without a registered email and will identify the missing address as a defect.

There is also a notification risk. Article 20 of the Judicial Notifications Law provides for automatic notification when the company omits the required address. Proceedings can therefore carry legal consequences without an owner actually reading an email. The extended registration deadline should not be treated as protection against notification problems.

The reviewed email provisions do not establish automatic dissolution or a separate monetary fine merely for missing this requirement.

Special situations and the practical takeaway

Foreign company branches, certain foreign powers and foreign associations whose attorneys-in-fact are domiciled outside Costa Rica have special requirements. The Registry directs these cases to the relevant public-deed procedure. A Costa Rican S.A. owned by foreigners is a different situation.

Law 10.597 also abolished the resident-agent requirement. Registering an email does not automatically remove an old resident-agent entry from the record; removing it is a separate request.

For most owners, the next step is straightforward: check the company’s registered email, confirm an eligible representative can use ACE, and complete the update. If that route is unavailable, arrange the appropriate notarial filing. Then make sure someone actually monitors the account.