Category: Uncategorized

Circular SV.SG. No. 018/2026 is addressed to investment fund management companies and concerns the use of the Agent Registration Tool (HRA).

The Securities Superintendency of the Central Bank of Paraguay (BCP) has published Circular SV.SG. No. 018/2026, titled "AFPISAs – Herramienta de Registro de Agentes (HRA)".

The published file bears a reference date of October 28, 2026. The circular is addressed to investment fund management companies (AFPISAs) and concerns the use of an electronic platform for administrative registrations in the securities market.

Digitalization of regulatory procedures

Electronic platforms for submitting and managing administrative filings can help simplify procedures, improve document traceability and reduce application processing times.

For supervised entities, these changes also create a need to adapt internal processes and ensure effective coordination among legal, compliance and operations teams.

Implementing new technology involves more than having the appropriate systems in place. It also requires clearly defined internal responsibilities, document review procedures and controls to ensure the integrity and consistency of information submitted to the regulator.

What does this mean for investment fund managers?

Registration and information-update procedures are particularly important for investment fund management companies, given the nature of their activities and the supervisory requirements applicable to them.

Any changes to regulatory management tools should therefore be assessed alongside institutions' internal procedures and the regulations currently governing administrative registrations.

Capital markets law considerations

Modernizing regulatory procedures can help improve market efficiency and transparency.

However, the introduction of digital tools must be accompanied by clear rules defining their scope, documentary requirements and the responsibilities of market participants.

From a legal perspective, digitalization should help improve the certainty and predictability of regulatory procedures without creating uncertainty about compliance obligations.

Scope of the circular

The full text of Circular SV.SG. No. 018/2026 has not yet been verified.

It is therefore not possible to confirm whether the circular introduces new obligations, documentary requirements, deadlines or specific procedures, or to establish its effective date.

A review of the complete circular is necessary before assessing its implications for the entities concerned.

As of October 15, 2026, banks, finance companies and fiduciary companies must submit trust agreements, amendments and related documentation through the Financial Communication Network (RCF).

The Superintendency of Banks of the Central Bank of Paraguay (BCP) has introduced a mandatory procedure for submitting documentation related to fiduciary transactions.

Under Circular SB.SG. No. 166/2026, dated October 15, 2026, trust establishment agreements, amendments and other related documents must be submitted exclusively through the Financial Communication Network (RCF).

The measure implements Article 11(d) of Resolution No. 12, Act No. 9, dated February 15, 2011, and applies to banks, finance companies and fiduciary companies.

What changes under the new procedure?

Previously, institutions could submit this documentation through the Superintendency of Banks' document reception office.

Under the new circular, all submissions must be made through the designated RCF module, following this path:

Planinfo → Fideicomiso → Mantenimiento → Negocios Fiduciarios.

Documents must therefore no longer be submitted through the Superintendency's document reception office.

The new procedure applies from October 15, 2026, the date the circular was issued.

Implications for affected institutions

Although the circular does not substantially change the legal framework governing trusts, it introduces a change to regulatory compliance procedures.

Banks, finance companies and fiduciary companies will need to adapt their internal document-submission processes, ensure that responsible teams understand the new procedure and verify that they have the necessary system access.

Institutions should also review their internal procedures for approving, executing and submitting trust agreements, particularly when multiple departments are involved.

Considerations for fiduciary transactions

Trusts are frequently used in structured finance and project finance transactions to manage assets, cash flows and collateral.

In these transactions, coordination among the parties, legal advisers and the fiduciary institution is essential to ensure that contractual documentation is properly executed and submitted.

The digitalization of regulatory procedures also requires institutions to adapt their internal document-control and traceability mechanisms.

From a legal perspective, it is important to distinguish between the proper execution of a trust agreement and compliance with administrative obligations to submit documentation to the regulator.

Both aspects should be addressed within institutions' compliance procedures, alongside effective coordination among legal, fiduciary and compliance teams.

Source: Banco Central del Paraguay – Circular SB.SG. N.º 166/2026

The new functionality, known as SIP por Aproximación, will enable contactless payments using NFC technology. Implementation will take place in stages, with full production scheduled for June 14, 2027.

The Central Bank of Paraguay (BCP) has approved a mandatory implementation schedule for SIP por Aproximación, a new feature of the Instant Payment System (SPI) that will enable contactless payments using Near Field Communication (NFC) technology.

The schedule was established through Resolution G.G. No. 191/2026, dated October 16, 2026. The initiative is part of the ongoing development of Paraguay's Payment System (SIPAP) and expands the available options for initiating and processing electronic payments.

How will the new system work?

NFC technology allows compatible devices to exchange information when brought close together, without physical contact.

Under the new requirements, banks and finance companies must adapt their applications to enable the initiation and/or requesting of contactless instant payments.

Payment Initiation Service Providers (PISPs) must also implement mechanisms to transmit, via NFC, the information contained in QR codes generated through the SPI's QR Hub.

These requirements apply to banks, finance companies and PISPs participating in SIPAP.

Implementation timeline

The BCP has established a phased schedule covering the following milestones:

Stage	Date
Project submission and technical documentation	October 16, 2026
Proof of concept with selected participants	October 19 – December 30, 2026
Feedback and final technical documentation	January 4–29, 2027
Technical and operational development	February 1 – April 2, 2027
Pilot testing with selected participants	April 5–30, 2027
Pilot testing with remaining participants	May 3 – June 4, 2027
Controlled production	Start date pending confirmation
Full production	June 14, 2027

The resolution does not establish a general effective-date provision, although it sets implementation obligations and deadlines beginning on October 16, 2026.

Implications for financial institutions and payment providers

The new functionality creates opportunities to improve the payment experience for users while introducing additional technological and operational requirements.

Affected institutions will need to assess their systems, applications, security procedures and transaction-processing mechanisms.

From a regulatory perspective, it will be important to ensure that these developments comply with applicable requirements concerning information security, operational risk management and user protection.

Implementation will also require coordination among legal, technology, compliance and operations teams, together with appropriate arrangements for interoperability, risk management and the allocation of responsibilities among participants.

The challenge will be to ensure that the adoption of new payment technologies is supported by adequate legal and operational safeguards.

Source: Central Bank of Paraguay – Resolution G.G. No. 191/2026

The new regulation allows financial institutions to use up to 30% of their reserve balances in local currency and 20% in foreign currency, providing greater flexibility in liquidity management.

The Central Bank of Paraguay (BCP), through Resolution No. 1, Act No. 45, dated October 8, 2026, revised the parameters governing financial institutions' use of their mandatory reserve balances.

The new limits allow institutions to use up to 30% of their reserve balances in local currency and 20% in foreign currency.

The resolution amends the parameters established in Article 6 of the Regulation on Reserve Requirements in Local and Foreign Currency and repeals Resolutions No. 14 and No. 15, Act No. 8, dated January 29, 2015.

Why have the limits been revised?

Reserve requirements are among the main instruments used by central banks to regulate liquidity in the financial system. Beyond their prudential function, they can also play an important role in helping financial institutions manage temporary liquidity needs.

Through this amendment, the BCP aims to provide institutions with greater autonomy and flexibility in managing their resources, particularly in response to short-term liquidity fluctuations.

The decision also incorporates recommendations from an International Monetary Fund (IMF) technical assistance mission aimed at strengthening the role of reserve requirements in absorbing these fluctuations.

What does this mean for banks and finance companies?

The revised limits give institutions greater flexibility to use their mandatory reserve balances within the percentages authorized by the BCP.

From an operational perspective, this may help institutions manage temporary liquidity needs and provide additional flexibility in treasury decisions.

However, the amendment does not remove other applicable prudential obligations. Financial institutions must continue to maintain appropriate liquidity risk management, monitoring and control mechanisms.

From a legal perspective, institutions will also need to assess whether updates to their internal liquidity policies, treasury procedures and control mechanisms are necessary, taking into account the operational and accounting regulations to be issued by the BCP.

Effective date and implementation

The resolution took effect on October 8, 2026, and applies to financial institutions subject to mandatory reserve requirements.

It also instructs the BCP's General Management to regulate the operational and accounting aspects of the measure, while the Superintendency of Banks will oversee compliance.

The amendment highlights the importance of a regulatory framework that balances financial stability with operational efficiency as Paraguay continues to modernize its financial regulations.

Starting November 2, 2026, shareholder meeting notifications and share transfer filings can be submitted through the Integrated Administrative Records Management System (SIARA).

Paraguay's Ministry of Economy and Finance (MEF) announced that, as of November 2, 2026, shareholder meeting notifications and share transfer filings will be available through the Integrated Administrative Records Management System (SIARA).

These new features will be added to the procedures already available on the platform for corporations and other for-profit legal entities, including limited liability companies, share-issuing corporations, publicly held share-issuing corporations, foreign companies operating through agencies or branches, and partnerships limited by shares.

With this update, the migration of corporate filings for legal entities to SIARA is complete.

What happens to BPM Simple?

The BPM Simple platform will remain available exclusively for legal structures that have not yet been incorporated into SIARA, until their gradual migration is completed.

Applications submitted through BPM Simple by November 1, 2026, will continue to be processed on that platform until completion.

Information for users

The General Directorate of Legal Persons, Legal Structures and Beneficial Owners (DGPEJBF), under the General Management, has made a user tutorial and a guide to the required supporting documentation available for each type of transaction.

For further information about this update, please contact Vouga Abogados' Corporate Law team at societario@vouga.com.py.

The free online tool allows companies to review their practices for collecting, protecting and deleting customers' and employees' personal data through 10 questions.

Vouga Abogados has launched its Express Data Protection Assessment, a free online tool designed to help companies identify their current personal data handling practices and areas that may need review.

The assessment consists of 10 questions and takes approximately 3 minutes to complete.

What does the assessment cover?

The tool allows companies to answer questions about how they manage customers' and employees' personal data, including information provided to data subjects, security measures, agreements with third parties and data deletion procedures.

Based on the answers provided, the assessment offers an indicative result regarding the organization's current practices and areas that may require further review.

How to access the assessment

The assessment is available online free of charge and takes approximately three minutes to complete.

Access the Express Data Protection Assessment

For a more detailed review of your organization's processes, the Vouga Abogados team is available to assist.

The results are indicative and based on the answers provided. This assessment does not replace legal advice.

Four recent resolutions establish new procedures and requirements for medicines intended to treat rare diseases, compassionate-use imports, nicotine pouches and advanced therapy medicinal products.

Paraguay's National Directorate of Health Surveillance (DINAVISA) has issued four resolutions introducing new procedures, requirements and marketing authorization rules for pharmaceutical products and other regulated products in Paraguay.

New procedure for medicines intended to treat rare diseases

Resolution No. 391/2026, dated September 23, 2026, establishes a special marketing authorization procedure for medicines intended to treat rare diseases, defined as conditions affecting one in 2,000 people or fewer.

The procedure provides for processing periods of 60 to 180 business days, depending on the case, and a five-year validity period for the marketing authorization.

The resolution is already in effect.

New requirements for compassionate-use imports

Through Resolution No. 396/2026, dated September 25, 2026, DINAVISA introduces new requirements for companies involved in importing medicines and medical devices without marketing authorization for compassionate use.

These requirements include authorization from the manufacturer or exporter.

The resolution also establishes a 10-business-day response period.

The resolution is already in effect.

Mandatory registration for nicotine pouches

Resolution No. 412/2026, dated October 1, 2026, introduces specific regulations for nicotine pouches in Paraguay for the first time.

Its main provisions include mandatory sanitary registration, a ban on advertising and child-resistant packaging requirements.

The resolution also sets a maximum nicotine content of 16.7 mg per pouch.

It took effect on October 26, 2026.

New regulatory framework for advanced therapy medicinal products

DINAVISA has also established a regulatory framework for advanced therapy medicinal products (ATMPs), covering gene therapies, somatic cell therapies, tissue-engineered products and combined therapies.

The regulation requires marketing authorization and provides for technical evaluation periods of 90 to 180 days, depending on the case.

It also establishes patient follow-up periods ranging from 5 to 10 years.

The resolution is already in effect.

The firm was ranked across nine practice areas, including six in Tier 1, and received 32 individual recognitions for its professionals.

Vouga Abogados has been recognized in the 2027 edition of The Legal 500 Latin America, one of the leading international legal directories.

This year, the firm received a total of 41 recognitions, including six practice areas ranked in Tier 1 and 32 individual distinctions awarded to members of its team.

Tier 1 Practice Areas

• Banking and Finance
• Competition and Antitrust
• Corporate and M&A
• Dispute Resolution
• Environment
• Labour and Employment

Tier 2 Practice Areas

• Administrative Law
• Intellectual Property
• Tax

These results reflect Vouga Abogados' longstanding experience, the strength of its practice areas, and its professionals' commitment to delivering high-quality legal services.

The firm thanks its clients for their trust and acknowledges the contributions of all team members who have helped achieve these results.

View the full results

Paraguayan labor law grants female employees two paid working days per year to undergo preventive screenings for breast and cervical cancer.

As part of Breast Cancer Awareness Month, companies should be aware of the labor regulations that ensure female employees have access to preventive screenings for the early detection of breast and cervical cancer.

In Paraguay, Law No. 3,803/09, as amended by Law No. 6,211/18, grants female employees two paid working days per year to undergo Pap smears and mammograms.

What should employers consider?

To manage this leave appropriately, employers should take the following requirements into account:

Requesting leave

Employees must request leave in advance and indicate the scheduled date of their medical examination.

Coordinating the date

Leave must be arranged in accordance with the procedure established by law, taking into account the proposed date and the necessary coordination with the employer.

If a medical emergency prevents an employee from requesting leave in advance, she must inform her employer as soon as possible.

Justifying the absence

The regulations do not require screenings to be performed at a specific healthcare institution.

To justify the absence, employees must provide a certificate issued by the healthcare center, clinic, hospital or other medical facility where the examinations were performed.

Reviewing internal procedures

Companies are advised to review their internal regulations and Human Resources procedures to ensure that the request, approval and justification of this leave are properly addressed in accordance with applicable law.

This helps establish clear procedures for managing absences without introducing requirements that restrict employees' ability to exercise this right.

The ruling confirms that when an administrative authority denies a tax incentive on technical grounds, it must substantiate its conclusion in the administrative decision itself.

Vouga Abogados secured a favorable ruling on behalf of Alcogreen S.A. in administrative litigation challenging Joint Ministerial Resolutions No. 93/2023 and No. 115/2023, issued by the Ministry of Industry and Commerce and the Ministry of Economy and Finance.

The First Chamber of the Tribunal de Cuentas upheld the claim, set aside the exclusion of six vacuum distillation columns from the tax incentive regime under Law No. 60/90, which was in force at the time, and ordered that the incentives be granted for those assets (Acuerdo y Sentencia No. 120 of April 15, 2026, as clarified by Acuerdo y Sentencia No. 258 of August 19, 2026).

The administrative authorities had excluded the equipment on the grounds that “similar domestic production exists.” The Court found that this assertion lacked technical support and that the administrative decision therefore lacked adequate reasoning.

The project

Alcogreen is developing a USD 100 million industrial project to produce ethanol from corn, with a projected annual milling capacity of 424,000 tonnes and estimated bioethanol production of 165 million liters per year.

The project includes imports of technological equipment worth approximately USD 30 million. Among these assets, six vacuum distillation columns valued at PYG 18.552 billion (approximately USD 2.6 million) were excluded from the incentive regime by the challenged administrative decision. The equipment uses specialized, patented technology designed to reduce energy consumption and achieve thermal integration of the production process.

The Tribunal’s reasoning

Relying on Article 12(e) of Law No. 6715/2021 on Administrative Procedures, which requires a statement of reasons for an administrative decision to be valid, the Court held that the administrative resolution “lacks sufficient grounds to be considered adequately supported by the factual and legal considerations required for its lawfulness.”

The Court further held that merely reciting the background and applicable provisions is insufficient: the decision must result from a “reasoning process that is both demonstrable and demonstrated,” yielding a reasonable position supported by a “clear and reasoned statement of grounds.”

The Court did not find that similar domestic production did not exist. Rather, it held that the administrative authorities had not sufficiently substantiated that assertion to provide a lawful basis for the exclusion.

Why the ruling matters

The ruling is a significant precedent for administrative practice and investment projects in Paraguay because it:

Reaffirms that adequate reasoning is a condition of the lawfulness of an administrative decision, rather than a mere formality.

Requires administrative authorities to explain and substantiate the technical considerations on which they rely, particularly when those considerations form the basis for denying a tax incentive.

Although the case was decided under Law No. 60/90, subsequently replaced by Law No. 7,548/2025, the requirement for adequate reasoning remains fully relevant under the new investment incentive regime.

Administrative authorities have the power to decide; however, when an adverse decision rests on a technical consideration, they must demonstrate in the decision itself the reasoning process that reasonably leads to that conclusion.

Case reference: “ALCOGREEN S.A. C/ RES. BIMINISTERIAL N° 93 DEL 31/08/2023 Y RES. BIMINISTERIAL N° 115 DEL 16/10/2023 DICTADAS POR LOS MINISTERIOS DE INDUSTRIA Y COMERCIO Y MINISTERIO DE ECONOMÍA Y FINANZAS”. Case No. 576/2023.