Category: Uncategorized

1. Client Background and Transaction Objective

We advised the investor consortium of a low-carbon fertilizer project on the acquisition of an equity interest in the entity carrying out the project, in connection with the project's USD 665 million financing.

The project is the world's first large-scale industrial plant dedicated to the production of low-carbon fertilizers, with a projected annual capacity of 260,000 tons, positioning Paraguay as a global pioneer in the production of low-environmental-impact agricultural inputs.

Our work consisted of advising the investor consortium on all matters of Paraguayan law related to the project's financing, providing legal certainty to the institutional investors and development entities involved throughout the structuring, negotiation and closing stages of the transaction.

2. Our Role and Scope of Advice

Our advice included:

1. Conducting comprehensive legal due diligence under Paraguayan law on the SPV and the assets related to the project, identifying legal risks relevant to the consortium's investment decision.
2. Analysis of the corporate and transaction structuring for the acquisition of the equity interest by the consortium's investors, taking into account the particular requirements of each of the participating entities (investment funds, international development finance institutions and local banking).
3. Review and negotiation of the transaction documents, including the subscription and investment agreements, the SPV's corporate documents and other instruments related to the acquisition of the equity interest.
4. Regulatory analysis applicable to the project and to the acquisition transaction under the Paraguayan legal framework, including corporate, foreign exchange, environmental and sector-specific aspects relevant to the project's industrial activity.
5. Advice on local aspects related to the project's USD 665 million financing, providing support in coordinating with the financial and legal advisors of the other jurisdictions involved.
6. Comprehensive support during the closing of the transaction, including coordination of conditions precedent, review of closing documentation and follow-up on formal requirements under Paraguayan law.
7. Advice on the negotiation of the project's Power Purchase Agreement (PPA), analyzing its regulatory and commercial implications under the Paraguayan energy framework.
8. Design of, and advice on, the project's management incentive scheme (Management Incentive Plan), aligning the interests of the management team with the objectives of the consortium's institutional investors.

3. Main Legal Challenges

The transaction presented significant legal complexity on several fronts:

Multijurisdictional investor consortium. The investment structure brought together a hydrogen infrastructure fund, a Danish impact fund, two international development finance institutions and a local bank, each with its own regulatory, fiduciary and governance requirements, which required a corporate structure capable of accommodating diverse interests and standards.

Scale and complexity of the financing. The project's USD 665 million financing required coordinating Paraguayan law aspects with the international financing structures typically used in large-scale project finance transactions, including the interaction between the acquisition of the equity interest and the project's financing conditions.

Pioneering nature of the project. As the world's first large-scale industrial plant dedicated to the production of low-carbon fertilizers, the project had no directly comparable regulatory or transactional precedents in Paraguay, requiring careful legal analysis on corporate, environmental and sector-specific matters.

PPA negotiation. Negotiation of the project's Power Purchase Agreement raised specific issues related to the energy supply required for the plant's operation, requiring a coordinated analysis between the commercial aspects of the contract and the applicable energy regulatory framework.

Alignment of management incentives. Designing the incentive scheme for the management team required reconciling local management's retention and performance objectives with the corporate governance standards demanded by the institutional investors and development entities participating in the consortium.

The Ministry of Labor, Employment and Social Security (“MTESS”) approved, through MTESS Resolution No. 780/2026 (the “Resolution”), the regulation of Article 259 of the Labor Code, establishing a special, summary and expedited procedure for the processing of complaints regarding the non-payment of the difference or supplement necessary to meet the applicable statutory minimum wage, in accordance with the annual salary readjustments.

The Resolution was issued on July 30, 2026 and entered into force on August 1, 2026. It applies to private sector employers subject to the Labor Code, both with respect to miscellaneous unspecified activities and those specific activities whose minimum wages are set by the MTESS.

The main aspects are as follows:

1. Commencement of the procedure

The procedure is initiated at the request of the affected worker or workers, by filing a complaint through the official channels made available by the MTESS.

The complaint must include the worker's personal data, the salary received, the months in question, the job position, and the available data of the employer. The lack of knowledge of all the employer's data shall not prevent the admission of the complaint, provided that, at a minimum, the employer's corporate name and address are indicated.

Upon receipt of the complaint, it shall be referred to the General Directorate of Inspection and Oversight (“DGIF”) within 24 hours. Within the following three business days, the DGIF shall issue a Digital Inspection Order and a Summary Proceedings Hearing and Document Request Order.

2. Notice and appearance

As a general rule, proceedings shall be notified to the employer via the officially registered email address. If an email address cannot be identified, the inspector shall attempt to obtain it through the data provided in the complaint and, exceptionally, may order an in-person inspection at the employer's premises. If the address cannot be identified either, the complaint shall be dismissed and archived.

The employer may appear:

• In person, by attending the scheduled hearing and physically submitting its defense and supporting documentation; or
• Digitally, by sending its defense and scanned documentation to the DGIF's institutional email address.

In-person appearance is the default option. To opt for the digital modality, the employer must expressly communicate this choice.

The hearing must be scheduled within five business days from the issuance of the orders. Where the complaint involves 10 or more workers, an exceptional extension of up to five business days may be granted. Under the digital modality, the deadline for submitting the defense and documentation is five business days from notification, extendable by an additional five business days in such cases.

3. Documentation and burden of proof

The employer must submit the documentation necessary to evidence the correct payment of the minimum wage, including:

• Salary payment receipts for the complaining workers;
• Employer-employee social security contribution payment records to the IPS for the last three months;
• Employment contracts;
• Bank deposit or transfer statements, where applicable; and
• Any supplementary documentation requested by the DGIF.

Documentary evidence must be submitted in a concentrated manner, in a single hearing or digital submission.

A particularly relevant aspect is that the Resolution places the burden of proof exclusively on the employer, who must demonstrate through the required documentation that the applicable statutory minimum wage was correctly paid.

4. Analysis and payment order

Upon receipt of the documentation, the inspector shall conduct the corresponding analysis and submit its report to the DGIF within the following five business days .

If the employer is found to be in compliance with the applicable statutory minimum wage, the file shall be archived.

Conversely, if a salary shortfall is identified, the DGIF shall issue a Payment and Settlement Order, specifying the affected workers, the months in arrears, and the amount of the corresponding supplement.

The employer shall be ordered to pay the difference within a period that shall not exceed three business days, and must submit documentation evidencing payment. The MTESS may subsequently verify with the complaining workers whether payment was effectively made.

5. Non-compliance and sanctioning procedure

The violation may be deemed established when the employer:

• Fails to submit the required documentation;
• Fails to evidence payment of the supplement following the payment order; or
• Fails to pay the salary difference within the granted period.

Once the documentary submission stage has expired, the inspector shall prepare the Violation Report, which shall be referred to the DGIF and subsequently to the Highest Authority of the MTESS.

The Highest Authority shall issue the Final Resolution, determining whether a violation occurred and, if applicable, imposing the corresponding sanction. If the violation is not established or procedural defects are found that invalidate the proceedings, the case may be archived.

6. Fines and payment obligation

When non-compliance is established, the conduct shall be classified as a violation of Article 259 of the Labor Code, and a fine of 30 minimum daily wages per affected worker shall be imposed.

In the event of recidivism, the fine may be doubled.

The imposition of the fine does not replace or extinguish the obligation to pay the outstanding wage supplement; therefore, the employer must comply with both obligations. If the fine becomes final and is not paid, the proceedings may be referred for the commencement of the corresponding enforcement action.

7. Appeal and other proceedings

An appeal may be filed against the Final Resolution within three business days following its notification. If filed in due time and form, it shall be referred to the Labor Court of Appeals.

Where a complaint includes other alleged labor violations, these shall be referred to the corresponding administrative procedure, without affecting the continuity of the special procedure regarding the minimum wage.

Likewise, the application of this procedure does not limit the DGIF's authority to conduct ordinary inspections and oversight actions when circumstances so warrant.

8. Implications for employers

The Resolution establishes a specific and expedited mechanism to monitor compliance with the minimum wage, with particularly short deadlines for the employer to submit its defense, provide documentation, and, if applicable, pay any identified shortfalls.

In this context, it is particularly important for employers to be in compliance with the current statutory minimum wage amounts and to maintain properly backed-up and readily available salary, employment, and social security contribution records for their workers, in order to timely evidence the correct payment of wages in the event of a request by the MTESS.

This content is for general informational purposes only and should not be construed as specific legal advice. Should you require specific guidance, please do not hesitate to contact us. Si precisa asesoramiento específico no dude en contactarnos.

The Ministry of Labor, Employment and Social Security (“MTESS”) issued MTESS Resolution No. 805/2026, dated August 7, 2026 (the “Resolution”), whereby it grants an exceptional, one-time extension of the deadline for the confirmation of Employment Information Books corresponding to fiscal year 2025.

The purpose of the extension is to grant employers additional time to complete the organization, review, and validation of employment information corresponding to fiscal year 2025.

1. New confirmation deadline

MTESS Resolution No. 462/2026 had established a schedule of deadlines for the confirmation of Employment Information Books corresponding to fiscal year 2025, with dates between August 17 and August 28, 2026, based on the last digit of the employer registration number.

Resolution No. 805/2026 exceptionally establishes a single new deadline for all employers: October 31, 2026.

Accordingly, employers now have until that date to complete the review, validation, and confirmation of Employment Information Books corresponding to fiscal year 2025.

2. ¿What does the extension entail?

The extension is limited exclusively to the Books corresponding to fiscal year 2025 and does not modify the general regime applicable to subsequent fiscal years.

Consequently, employers must continue to comply with the obligations set forth in Resolution No. 462/2026 regarding the preparation and confirmation of Employment Information Books through the Employer-Employee Registry system (“REOP”).

Likewise, the confirmed information retains the status of a sworn statement; therefore, we recommend verifying beforehand that the registered data is complete, accurate, and consistent with the company's employment records.

3. Non-compliance and sanctions

Once October 31, 2026 has elapsed, the failure to confirm the Books corresponding to fiscal year 2025 shall constitute the non-compliance provided for in Resolution No. 462/2026 and shall give rise to the corresponding sanctions and fines.

The applicable fines are as follows:

• 10 minimum daily wages: employers with up to 30 workers;
• 20 minimum daily wages: employers with between 31 and 50 workers; and
• 30 minimum daily wages: employers with more than 50 workers.

Payment of the fine does not exempt the employer from the obligation to maintain and confirm the Books.

4. Recommendation

We recommend that employers take advantage of the additional time to review and validate employment information corresponding to fiscal year 2025, particularly verifying that the communications filed in the REOP are complete and consistent before proceeding with the confirmation.

In summary: la fecha límite para la confirmation of Employment Information Books corresponding to fiscal year 2025 es ahora el October 31, 2026 for all employers, regardless of the last digit of the employer registration number. The extension is exceptional, one-time only, and does not modify the deadlines applicable to subsequent fiscal years.

This content is for general informational purposes only and should not be construed as specific legal advice. Should you require specific guidance, please do not hesitate to contact us.

The Ministry of Economy and Finance (MEF) announced the entry into force of MEF Resolution No. 337/2026 (the “Resolution”), which sets forth supplementary provisions for the management of communications filed by obligated parties pursuant to Law No. 6446/2019, as well as for compliance with the accountability and transparency obligations applicable to Non-Profit Organizations (NPOs) subject to Law No. 7363/2024.

The regulation will be implemented through the Integrated Administrative Registry Management System (SIARA) and is intended to operationalize the mechanisms for the filing, recording, and disclosure of information required under the applicable legal framework.

Key aspects of the Resolution:

• Establishes the applicable procedures for the management of communications and filings submitted through SIARA.
• Approves the forms that NPOs must use to comply with accountability and transparency obligations.
• Determines the minimum information that must be reported by the entities subject to the regulation.
• Regulates specific matters concerning NPOs incorporated abroad that carry out activities subject to the regime established by Law No. 7363/2024.
• Defines the procedures and deadlines for compliance with the corresponding legal obligations.

This measure is part of the process of strengthening the mechanisms of oversight, transparency, and traceability of information administered by State-dependent public registries.

Obligations and Deadlines for Fiscal Year 2026

NPOs subject to Law No. 7363/2024 shall observe the following deadlines for the initial implementation of the regime:

1. First Accountability Report

• Reporting period: July 1 through December 31, 2026.
• Filing deadline: June 30, 2027.

2. First Transparency Disclosure

• Reporting period: July 1 through December 31, 2026.
• Filing deadline: January 31, 2027.

Subsequent accountability reports and transparency disclosures shall comply with the ordinary deadlines set forth in the Resolution and other applicable regulatory provisions.

Practical Implications for Organizations

The entities subject to this regulation should promptly review their internal corporate governance, administration, and document management processes in order to ensure:

• The adequate collection and retention of the required information.
• The preparation of reports in accordance with the official forms approved by the MEF.
• The implementation of internal control mechanisms to evidence compliance with transparency and accountability obligations.
• The uploading and filing of information within the established deadlines through the SIARA platform.

Failure to comply with these obligations may result in administrative observations and the imposition of sanctions provided for under applicable law.

1. Client Context and Project Objective

We advised an engineering and electrical infrastructure company on the legal feasibility of developing a utility-scale solar photovoltaic project in Paraguay under the private initiative Public-Private Partnership (PPP) regime, in combination with the recently enacted Renewable Non-Conventional Energy (RNCE) framework.

The project contemplates an estimated investment of USD 23 million and includes the development of a solar power plant, a dedicated electrical substation and a high-voltage transmission line. Its business model combines the long-term sale of electricity to ANDE with direct supply to a Large Consumer, requiring analysis of the interaction between both regulatory schemes.

Our engagement focused on assessing the legal feasibility of the project, identifying the principal interactions between the applicable regulatory frameworks, analysing key bankability considerations, and preparing a regulatory roadmap for the potential submission of the private initiative to the competent authorities.

2. Our Role and Scope of Advice

Our Infrastructure and Energy team acted as legal counsel throughout the regulatory structuring phase of the project. Our work included:

a. Analysing the applicable regulatory framework, including the interaction between Law No. 7452/2025 on Public-Private Partnerships and its Implementing Decree No. 5441/2026, Law No. 7599/2025 on Renewable Non-Conventional Energy and its Implementing Decree No. 6034/2026—issued during the course of our engagement—and Law No. 966/1964 (ANDE's Organic Charter).

b. Preparing a regulatory memorandum intended to form the legal component of the pre-feasibility study required under the PPP regime for a potential submission to the General Directorate of Public Investment (DGIP) of the Ministry of Economy and Finance. The memorandum addresses the project's regulatory eligibility, the Special Purpose Vehicle structure required under the applicable regimes, the interaction between the different regulatory frameworks, and relevant bankability considerations.

c. Analysing project finance-related issues, including the guarantee mechanisms available under the PPP Law, lenders' step-in rights, the structure of a potential Direct Agreement, the trust structures available under both regulatory regimes, and the legal framework governing financial close.

d. Updating the regulatory analysis following the enactment of Implementing Decree No. 6034/2026, assessing its implications for the legal and commercial structure of the project.

e. Advising on the contractual interaction between the future PPP Agreement and the RNCE Connection and Supply Agreement, including observations regarding term, renewal, asset reversion, and tariff mechanisms.

3. Key Legal Challenges

The project raised several regulatory issues requiring an integrated legal analysis.

Interaction between three regulatory regimes. The proposed structure needed to comply simultaneously with the PPP framework, the RNCE regime and ANDE's Organic Charter, each of which pursues different regulatory objectives and contains distinct legal mechanisms. The analysis focused, among other matters, on ANDE's dual role as contracting authority and electricity purchaser, the interaction between the pricing mechanisms under both regimes, and the scope of ANDE's statutory distribution monopoly.

Regulatory developments during the engagement. At the outset of the engagement, the RNCE Law had not yet been regulated. The subsequent enactment of Implementing Decree No. 6034/2026 required the regulatory analysis to be updated in order to incorporate the new provisions and identify the issues that remained subject to further interpretation.

Dual commercial model. The client's proposal to combine electricity sales to ANDE with direct supply to a Large Consumer raised several regulatory questions, including the characterization of firm and interruptible supply, the use of a single RNCE licence for different voltage levels, and the interaction between the freely negotiated pricing mechanisms under the RNCE regime and the tariff approval requirements applicable to PPP projects.

Project finance considerations. The bankability analysis was conducted in the context of two recently enacted regulatory regimes with no transactional precedents in Paraguay. This required assessing the compatibility of the domestic legal framework with financing mechanisms commonly used in international project finance transactions, including step-in rights, Direct Agreements, debt service reserve arrangements (DSRA), take-or-pay obligations and lender protections.

Institutional coordination. The project required consideration of the sequential involvement of several public authorities—including the DGIP, the Ministry of Economy and Finance, ANDE, the Executive Branch, the Office of the Attorney General, the Vice Ministry of Mines and Energy, the National Council of Public Enterprises, the Ministry of Environment and Sustainable Development (MADES), and the Ministry of Public Works and Communications (MOPC)—as well as the regulatory approvals required at each stage of the process.

4. Current Status of the Engagement

The regulatory memorandum and the supporting legal analyses were prepared and delivered to assist the client in evaluating the project's legal feasibility and its potential structuring under the PPP framework.

The work product provides the client with:

• An integrated analysis of the three applicable regulatory frameworks, identifying their principal points of interaction, potential areas of regulatory tension and key considerations for structuring the project.
• A regulatory memorandum intended to serve as the legal component of the pre-feasibility study, should the client decide to proceed with the submission of a private initiative before the General Directorate of Public Investment.
• An assessment of key project finance considerations, including the principal guarantee mechanisms available under the applicable legislation and the regulatory issues relevant to a potential project finance structure. project finance.
• A regulatory roadmap identifying the principal stages of the approval process, the competent authorities, the applicable regulatory requirements and the legal issues likely to arise during subsequent phases of the project.
• An evaluation of the impact of Implementing Decree No. 6034/2026 on the legal and contractual structure of the project, including the regulatory issues addressed by the new regulation and those that remain subject to future interpretation or regulatory development.

Throughout the engagement, our team worked closely with the client and its technical and financial advisers, updating the regulatory analysis as the legal framework evolved and preparing documentation intended to support the client's ongoing assessment and structuring of the project.

Through Resolution No. 8, Minutes No. 31, dated July 13, 2026, the Board of Directors of the Central Bank of Paraguay (“BCP”) approved the new Regulation establishing the National Payments System Fee Framework (the “Regulation”), aligning the existing regulatory framework with Law No. 7503/2025 “National Payments System”.

Unlike the previous regime, which was limited to certain services provided through the Paraguayan Payment System (“SIPAP”), the Regulation significantly broadens its scope of application, encompassing not only services processed through SIPAP, but also acquiring, network operation and processing services within the card payments ecosystem, as well as payment services involving debit and/or credit transactions to accounts carried out through proprietary systems authorized by the BCP.

One of the Regulation's main objectives is to prevent regulatory arbitrage between functionally equivalent services and to ensure that fees adequately reflect the economic nature and costs associated with each service. In particular, the BCP identified that certain transactions initiated through QR codes were being marketed as debit card payments when, in fact, they correspond to account-to-account transfers with considerably simpler and less costly operational structures.

In this context, the Regulation introduces a differentiated fee regime for the various payment services. Among its most significant developments is the establishment of a maximum fee cap of 1.5% for payment initiation services, payment requests and direct debits carried out through proprietary systems, applicable exclusively to the beneficiary merchant.

Another noteworthy aspect is the expansion of the entities subject to the Regulation. The new fee framework applies to payment service providers regulated by the BCP.

Finally, although the Resolution entered into force upon its publication, the BCP granted entities a transition period until January 1, 2027, to implement the adjustments necessary for compliance. Failure to comply with the provisions of the Regulation may trigger the application of the sanctions set forth under the applicable legal framework.

1. Client Context and Transaction Objective

We advised a company in the early stages of developing a large-scale electrofuel (eFuel) production facility in Paraguay within the RFNBO (Renewable Fuels of Non-Biological Origin) category. The client, a foreign investor in the renewable energy sector, identified a strategically located site in the District of Villeta, on the Paraguay River, for the development of an electrolysis plant and related infrastructure, including pipeline corridors, a dedicated electrical substation, and potential port facilities for bulk methanol exports.

Our engagement focused on structuring the legal framework for the acquisition of the target site and protecting the client's position during the pre-investment phase, ensuring legal certainty over the parcels of interest while technical, environmental, and commercial due diligence is carried out.

2. Our Role and Scope of Advice

Our advice included:

a. Structuring the acquisition, assessing alternative mechanisms to secure the client's rights over multiple parcels owned by different landowners, with different title histories and legal statuses, including parcels subject to ongoing judicial proceedings.

b. Drafting and negotiating two parallel pre-contractual instruments: a Letter of Intent (LOI) with one landowner and a Memorandum of Understanding (MOU) with the other, each tailored to the specific legal and commercial circumstances of the relevant parcels.

c. Conducting title review and legal risk analysis, including identification of a title overlap dispute affecting two key parcels, assessment of a pending revindicatory action and judicial survey proceeding, and analysis of a title consolidation issue arising from an acquisition made on behalf of a company in formation.

d. Designing a multi-layered acquisition structure covering outright purchases, irrevocable purchase options for future expansion phases, pipeline corridor rights (through ownership or easement, depending on due diligence findings), a conditional tank storage option linked to port feasibility, and acquisition of the electrical substation together with underground cable routing rights.

e. Drafting payment protection mechanisms, including deferred payment arrangements linked to indemnity conditions to mitigate double-payment risk arising from the title dispute, together with vendor indemnities covering potential professional fee claims by attorneys involved in the underlying litigation.

f. Coordinating both parallel transactions to ensure consistent treatment of the title overlap dispute affecting parcels owned by each counterparty.

3. Key Legal Challenges

The transaction presented significant legal complexity on several fronts:

Overlapping title dispute. Two strategically important parcels, one owned by each counterparty, were affected by an ongoing title overlap dispute subject to judicial proceedings. The planned access corridor to the port crossed the disputed area, directly linking title risk to the operational viability of the project. The transaction structure was designed to allow negotiations to progress while protecting the client from exposure to the underlying dispute.

Fragmented title structure. The parcels covered by the MOU were distributed across separate properties with differing ownership histories, requiring careful coordination of the acquisition structure.

Multi-layered acquisition framework. The project's phased development required five different acquisition mechanisms—outright purchase, purchase options, conditional options, easement or ownership rights depending on due diligence outcomes, and underground cable routing rights—each requiring tailored legal treatment while maintaining consistency across both framework agreements.

Regulatory and infrastructure considerations. The transaction also required anticipating regulatory requirements for the construction and operation of a dedicated electrical substation (ANDE authorization), underground cable crossings under public roads (municipal permits), and future port access arrangements, which were incorporated into the contractual framework through conditions precedent and cooperation obligations.

4. Outcome and Current Status

Negotiations of both framework agreements have progressed positively, and the parties have reached alignment on the principal commercial and legal terms. While the transactions remain subject to ongoing negotiations and execution of the final documentation, the proposed contractual framework provides the client with a solid legal basis to continue its due diligence and advance the project.

The proposed transaction structure is expected to provide the client with:

• Exclusive rights over all target parcels for an 18-month period, covering the due diligence and contract negotiation phases, with both counterparties undertaking not to encumber or dispose of the relevant parcels.
• A coherent legal framework for a phased acquisition covering the initial electrolysis site, future expansion areas, pipeline and substation infrastructure, and conditional port-related rights.
• Protection against the title overlap dispute through conditions precedent, deferred payment arrangements, and vendor indemnities addressing both the underlying dispute and potential professional fee claims arising from the litigation.
• A clear due diligence roadmap identifying the principal legal, cadastral, and regulatory workstreams required prior to closing, including recommendations on title verification, cadastral overlay analysis, and regulatory pre-assessments.

Throughout the engagement, our team has acted as a strategic legal adviser, anticipating risks, coordinating the parallel negotiations, and developing practical solutions aligned with the client's commercial and operational objectives.

Through Resolution SV.SG. No. 0022/2025, dated December 11, 2025, the Superintendency of Securities (“SIV”) of the Banco Central del Paraguay (“BCP”) approved the Regulation of the Central Information System for the Securities and Products Market (the “Regulation”), introducing changes to the current framework governing the submission of regulatory information.

The Central Information System is mandatory for broker-dealers, fund management companies, stock exchanges, central securities depositories, and other market entities and participants as determined by the SIV.

The Regulation establishes a single and mandatory standard for the submission of information by supervised entities. From an operational standpoint, the Central Information System operates as a centralized platform through which entities must submit their reports in standardized formats and in accordance with uniform technical specifications.

Additionally, the Regulation introduces stringent data quality standards, including the obligation to perform pre-submission validations, the automatic rejection of files containing critical errors, and requirements regarding the traceability and completeness of the information. In this regard, supervised entities will bear direct responsibility for the integrity, accuracy, and quality of the data submitted.

Through Circular SB.SG. No. 00101/2026, dated July 1, 2026, the Superintendency of Banks ("SIB") established a new procedure for the submission and processing of documents through its filing desk, applicable to banks, finance companies, exchange houses, electronic payment service providers, credit bureaus, general warehouses, the Development Finance Agency (AFD), and trust companies (the "Circular"). This new submission procedure will become effective on August 1, 2026.

The Circular provides that documents submitted by the above mentioned entities must bear a qualified electronic signature issued by a trust service provider authorized by the Ministry of Industry and Commerce (MIC) and must be submitted in PDF format to the SIB's official filing desk email address. In addition, the Circular establishes general guidelines governing the submission of documentation.

The Circular also sets out the procedure for the receipt and registration of submitted documents, allowing the SIB, where appropriate, to require the physical submission of certain documents. Where no physical submission is required, receipt of the filing will be confirmed by email through the assignment of a filing number.

Through Resolution G.G. No. 83/2026, dated June 29, 2026, the Central Bank of Paraguay ("BCP") approved the Operational Regulation for the Registration of Payment Service Providers ("PSP") within the National Payment System (the "Regulation"), establishing the procedure, deadlines, and requirements applicable to the registration provided for under Law No. 7503/2025 on the National Payment System.

The Regulation provides that all PSPs must register with the BCP through an electronic registration form. The registration is declaratory in nature and does not constitute an authorization or license to operate. Each PSP is responsible for the accuracy and updating of the information submitted.

The Regulation also establishes a sixty (60) day deadline for existing PSPs to complete their registration and for new PSPs to register from the start of their operations, as well as a thirty (30) day deadline to notify the BCP of any changes to the information previously provided. The required information includes institutional, functional, and technical data covering corporate, operational, technological, cybersecurity, and business continuity matters.

The Financial Operations General Sub-Management (SGGOF) is responsible for administering the registry, requesting additional information where appropriate, and issuing supplementary provisions for its implementation. In addition, the BCP may publish a list of registered PSPs as a measure aimed at enhancing transparency within the country's payment ecosystem.