UBO Costa Rica 2026: Ultimate Beneficiary Owner Declaration (RTBF) — Who Can File, Deadlines & Compliance Steps
If your directors live abroad, your shareholders are layered, or your legal representative cannot access Costa Rica’s digital signature tools, the UBO process can become the bottleneck that delays banking, corporate transactions, and ongoing operations. This 2026 update explains who can file, what the “special POA exclusion” means, when the April annual window usually applies, and the cleanest way to stay compliant through a properly registered apoderado generalísimo when needed.
- 1) What is UBO / RTBF in Costa Rica?
- 2) Who can file in 2026 (and who cannot)
- 3) 2026 deadlines, annual window & updates
- 4) Digital signature: the real gating factor
- 5) Apoderado generalísimo: when it works (and how to do it right)
- 6) Penalties and common “compliance blockers”
- 7) How AG Legal handles RTBF filings end-to-end
- 8) Frequently asked questions (2026)
- 9) Sources & official links
- Talk to our lawyers
Author: AG Legal • Reviewed by: Corporate & Tax Compliance Team • Updated: Jan 13, 2026
1) What is UBO / RTBF in Costa Rica?
UBO stands for Ultimate Beneficial Owner. In Costa Rica, obligated entities must report their beneficial ownership information through the
Registro de Transparencia y Beneficiarios Finales (RTBF). The goal is to identify the natural persons who ultimately own or control an entity, even when ownership is indirect or layered.
2) Who can file in 2026 (and who cannot)
| Role | RTBF Filing Status (2026) | Notes |
|---|---|---|
| Legal Representative (president/manager/administrator) | Allowed | Must file using a valid Central Bank digital signature. |
| Apoderado generalísimo (general attorney-in-fact) | Allowed (exceptional route) | Must be a registered generalísimo; typically used when the legal representative cannot access the required digital signature. |
| Agent / accountant / lawyer with “special” POA | Not allowed | Special/limited mandates are excluded for RTBF/UBO filings. |
generalísimo solution so you don’t miss the annual window.
3) 2026 deadlines, annual window & updates
- Ordinary annual filing: Common practice is an annual compliance window during April (often referenced as April 1 to April 30).
- Event-driven updates: File an update when there are material changes in ownership or control, not just once per year.
- Important: In some years the government may adjust deadlines. Always confirm your specific situation and any official extensions before relying on a date.
4) Digital signature: the real gating factor
The RTBF platform is accessed using a digital signature certificate issued through Costa Rica’s Central Bank ecosystem. In practice, it is typically available to citizens and foreign residents with DIMEX. If your legal representative cannot obtain or use the certificate in time, a registered apoderado generalísimo is the most reliable compliance path.
5) Apoderado generalísimo: when it works (and how to do it right)
- When it works: Use it as an exceptional route—commonly when the legal representative does not have the certified digital signature needed to file.
- How it must be granted: Through a public deed and then registered at the National Registry so the attorney-in-fact can access RTBF properly.
- Who can grant it: In practice, the legal representative is the person expected to grant the generalísimo for RTBF purposes.
- Real-world tip: If the company appears as non-compliant, registry practice has allowed registration steps for the generalísimo to help companies become compliant again.
6) Penalties and common “compliance blockers”
- Fines and operational friction: Non-compliance can trigger penalties and practical blocks that complicate banking, restructurings, and other formal processes.
- Most common blocker: The legal representative is abroad and cannot obtain/use the digital signature within the filing window.
- Most common fix: Prepare and register the apoderado generalísimo early, then file with clean evidence and an internal compliance calendar.
7) How AG Legal handles RTBF filings end-to-end
- Diagnosis: Confirm legal representative, signatories, and whether a generalísimo is needed for 2026.
- Power setup: Draft the generalísimo deed, coordinate signatures (local or abroad), and manage the registration process.
- UBO data validation: Review share registers, ownership/control charts, and layered structures (including trusts, if applicable).
- RTBF filing: Submit via the legal representative’s digital signature or through the registered attorney-in-fact, then store acknowledgment evidence.
- Ongoing compliance: Keep a single calendar for annual filing + event-driven changes to remain “transaction ready.”
8) Frequently asked questions (2026)
- What does UBO mean in Costa Rica?
- UBO means Ultimate Beneficial Owner: the natural person(s) who ultimately own or control a company. In Costa Rica, UBO information is reported through the RTBF.
- Who can file the RTBF/UBO declaration in 2026?
- In general, only the legal representative can file using a valid digital signature. In exceptional cases, a registered apoderado generalísimo may file when the legal representative cannot access the required signature.
- Are “special” powers of attorney valid for RTBF filings?
- No. Special/limited POAs are not accepted for RTBF filings. Use the legal representative or the registered generalísimo route.
- What is the ordinary annual filing window for RTBF?
- Common practice is an annual filing window in April (often referenced as April 1–April 30). Always confirm if there is an official extension in a given year.
- What if our legal representative is abroad and cannot get a Costa Rican digital signature?
- The clean solution is to grant and register an apoderado generalísimo to a trusted attorney in Costa Rica so the filing can be completed on time.
- Does the generalísimo have to be registered?
- Yes. For RTBF purposes, it should be granted by public deed and registered at the National Registry before the attorney-in-fact can file.
- Do we need to file only once a year?
- No. Besides the annual filing, you should file updates when beneficial ownership or control changes.
- Can AG Legal handle the full UBO filing process?
- Yes. We can coordinate the generalísimo (if needed), validate ownership/control information, file the RTBF, and keep your compliance calendar organized for 2026 and beyond.
9) Sources & official links
Talk to our lawyers
Need to secure your UBO filing for 2026, appoint a generalísimo, or file an update after a corporate change?
We handle the process end-to-end—so your operations, banking, and transactions stay smooth.
This content is informational and does not constitute legal or tax advice. Rules and administrative criteria can change. Confirm current requirements for your specific structure with qualified counsel.