Category: Uncategorized

The Executive Branch has recently promulgated Decrees No. 5306/2026 and No. 5307/2026, introducing a new public policy framework aimed at fostering the installation and development of energy, technology, and innovation-intensive industries in Paraguay.

Decree No. 5306/2026 establishes, as a sector-specific public policy, the development of "Convergent Industries." This concept encompasses highly sophisticated technical activities that utilize stable, renewable electric energy as a critical input for value creation. This includes high-performance computing (HPC) infrastructure, artificial intelligence, cloud services, advanced manufacturing processes, and other energy-intensive industrial transformations. Furthermore, the Decree creates a new electricity consumption category for these industries, applicable to various voltage levels (500, 220, 66, and 23 kV), with tariffs denominated in U.S. dollars and a horizon of up to 15 years, subject to update mechanisms.

As part of the same scheme, Decree No. 5306/26 creates a Biministerial Commission composed of the Ministry of Industry and Commerce (MIC) and the Ministry of Information and Communication Technologies (MITIC). This commission will be responsible for accrediting companies that qualify as Convergent Industries, based on the submission of a "Productive Linkage Plan" aimed at maximizing local economic and technological impact.

In addition to this general framework, Decree No. 5307/2026 introduces a specific treatment for "Power-to-X Convergent Industries" — projects that convert renewable energy into energy carriers and raw materials such as hydrogen, ammonia, methanol, synthetic fuels, and others. This Decree formally incorporates these ventures into the Convergent Industries regime and creates a specific consumption category for Power-to-X projects connected to Very High Voltage (220 kV), with tariffs also denominated in U.S. dollars and a planned duration of up to 15 years. Unlike the general regime, the MIC acts as the direct enforcement authority for the accreditation and authorization of these projects.

Both Decrees align with the objectives of the Paraguay 2050 National Development Plan and an investment attraction strategy based on leveraging the country's comparative energy advantage, promoting higher value-added activities, know-how transfer, and integration into global productive chains.

From a practical perspective, this framework is still in the implementation phase. While the National Electricity Administration (ANDE) must adapt its tariff structure and the Decrees provide for administrative periods for their rollout, the effective application of the new regimes will depend on additional regulations and the accreditation of specific projects, which will reasonably take time.

In conclusion, Decrees No. 5306/26 and No. 5307/26 constitute a significant signal in terms of industrial and energy policy. While they do not resolve the challenges of implementation, predictability, and institutional coordination on their own, they represent a positive step toward creating a more attractive environment for investments in strategic sectors such as technology, advanced industry, and energy transition in Paraguay.

To access the full text of the Decrees, click here: Decree No. 5306/26 – Decree No. 5307/26  

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For more information regarding these Decrees and other energy-related matters, please contact: Rodolfo G. Vouga (rgvouga@vouga.com.py); Manuel Acevedo (macevedo@vouga.com.py); Lucas Rolón (lrolon@vouga.com.py); Yvo Salum (ysalum@vouga.com.py).   

El RUN es un sistema nuevo, centralizado y único que fusiona el Servicio Nacional de Catastro y Registros Públicos en una sola estructura operativa, creada por la Ley 7424/2025 y reglamentada por Decreto del Poder Ejecutivo N° 5305/2026. Su finalidad es eliminar duplicaciones, reducir el riesgo inmobiliario y dar seguridad jurídica plena en las transacciones.

El RUN une en una sola institución funciones que antes estaban dispersas entre:

• Dirección General de Registros Públicos
• Servicio Nacional de Catastro
• Departamentos de Mensura y Geodesia del MOPC

Con la implementación del RUN toda información física y jurídica de un inmueble depende de un único órgano técnico-administrativo del Poder Judicial.

Qué cambio implica en la práctica la implementación del RUN:

• Un solo trámite, una sola mesa de entrada, una sola numeración. Desde enero 2026, cada trámite se ingresa en un solo lugar y recibe un número único para seguimiento.

Antes, había que ir al Servicio Nacional de Catastro, Registros Públicos, Mensura, etc.
Ahora, todo se hará en una sola ventanilla física o a través del sistema RUN.

• Un solo certificado para cualquier operación inmobiliaria

El RUN reemplaza dos certificados (catastral + dominio) por uno solo: el Certificado Catastro Registral Inmobiliario, incluirá en un único documento:

• Ubicación
• Superficie y mensura
• Linderos
• Superposiciones existentes
• Restricciones ambientales o de seguridad
• Titularidad jurídica
• Hipotecas, embargos y otras medidas

Esto cambia totalmente la práctica notarial y será el documento básico para comprar, vender, hipotecar, etc.

• Publicidad obligatoria de las superposiciones

El RUN permitirá visibilizar si un inmueble tiene superposición o conflicto antes de firmar la escritura.

Esto:

• Reducirá el riesgo histórico de títulos duplicados.
• Permitirá que comprador y vendedor sepan exactamente el riesgo antes de cerrar una operación.
• Limitará reclamos o juicios posteriores.
• Cada inmueble tendrá una identidad única (Código Único Catastral Registral)

El RUN asignará un código alfanumérico inmutable para cada propiedad del país, lo que asegurará coherencia entre el plano, la mensura y el título.

• Trazabilidad total del expediente

Una vez se encuentre totalmente implementado el RUN, cualquier ciudadano con contraseña podrá ver en qué etapa está su trámite en tiempo real.

• Cómo se podrá realizar un trámite en el RUN

El escribano público o el usuario deberá ingresar la escritura y la documentación técnica en una única mesa de entrada, y obtendrá un número RUN.

Un mismo órgano verificará:

• Mensura (coherencia geográfica)
• Titularidad (coherencia jurídica)
• Superposiciones
• Restricciones legales

Si bien la implementación del RUN en las primeras semanas presentó retrasos en las gestiones y trámites debido a problemas en la fiscalización electrónica, se espera que una vez que se solucionen los problemas de la transición y se avance hacia la digitalización total de los documentos, el sistema asegure mayor agilidad, trazabilidad y seguridad.

Through Decree No. 5,154/2025 (the "Decree"), the Executive Branch established an exceptional and temporary regime for the regularization of certain tax debts, with the aim of facilitating compliance with past-due tax obligations and reducing the financial impact of accumulated surcharges and interest.

This special regime will remain in effect until August 31, 2026, and provides for the application of a monthly interest rate or surcharge of 0% and the possibility of requesting payment plans for overdue tax obligations corresponding to:

1. Monthly tax periods closed through December 2023, and
2. Annual obligations corresponding to fiscal years closed on December 31, 2023.

The special regime applies to: (i) final, liquid, and enforceable tax debt certificates; and (ii) tax adjustments and penalties (pending or finalized) provided that there is express agreement or acquiescence by the taxpayer.

Debts arising from the filing or amendment of tax returns, as well as advance payments of corporate income tax (IRE), are excluded from the regime.

Development

The benefits established in the Decree apply to the following tax debts:

1. Final, liquid, and enforceable debt certificates, even when they are being collected by the Treasury Attorney's Office.
2. Tax adjustments and penalties that are pending, arising from tax assessments, audit processes, administrative proceedings, or appeals for reconsideration, whether in administrative or judicial proceedings, provided that the taxpayer expressly agrees or acquiesces to the total amount owed.
3. Adjustments arising from completed audit processes or administrative proceedings, under the same conditions of express agreement or acquiescence.

The regime does not apply to IRE advance payments or debts arising from payment facilities that have lapsed due to non-compliance. Likewise, debts arising from the filing or rectification of tax returns are excluded.

To qualify for the regime, taxpayers must submit the note authorized by the National Tax Revenue Directorate ("DNIT"), available on its websitehttps://www.dnit.gov.py/web/portal-institucional/pagos), which must be submitted exclusively through the institutional reception desk of the DNIT or the Ministry of Economy and Finance ("MEF"), as applicable. For all purposes, the date recorded in the respective administrative file shall be considered the valid date. Debts that do not qualify for the regime will continue to be subject to the interest and surcharges provided for in the general regime.

The Decree empowers the DNIT to grant exceptional payment plans, with a minimum payment equivalent to 10% of the debt and a financing rate of 0%, according to the following scale:

• Up to 24 monthly installments, when the debt does not exceed G. 500,000,000.
• Up to 36 monthly installments, when the debt exceeds that amount.
• Exceptionally, more than 36 installments, when the debt exceeds G. 1,000,000,000, with the express authorization of the National Director of Tax Revenue.

Failure to comply with the agreed installments will result in the loss of the benefits of the regime and the application of the interest and surcharges provided for in the general regime.

Additionally, a 50% discount on the penalty for fraud is provided for in cases of prompt payment, provided that the resulting amount is not less than the minimum legal penalty. In ongoing proceedings, the taxpayer's express agreement or acquiescence will allow for the direct application of the minimum penalty provided for such an offense. In cases being processed in court, adherence to the regime must be approved and communicated to the court or tribunal involved.

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We are proud to have advised FMO, the Dutch entrepreneurial development bank, on the granting of a USD 45 million loan to BANCOP S.A., intended to finance agricultural producers and green projects.

The primary objective of this loan is to support agricultural producers in rural areas, contributing to job creation in regions where nearly one-third of the population lives below the poverty line. 90% of the funds will be allocated to the financing of agricultural producers, while the remaining 10% will be dedicated to projects related to green lending.

We congratulate the team led by our partner Carlos Vouga, along with associates Belén Rodríguez and Yvo Salum, for their outstanding work on this transaction.

For us, it is a true honor to contribute to the development of projects that promote financial inclusion and sustainability, reaffirming our commitment to providing legal advice on sustainable finance, international lending, and economic development in Paraguay.

Vouga Abogados advised Las Ardenas S.A., part of Grupo Azeta, in the acquisition of Tigo Money, with the closing subject to regulatory approvals.

Grupo Azeta’s entry into this market will strengthen the development of the platform to meet demands for innovation and efficiency in the sector, thereby promoting financial inclusion for a large segment of the Paraguayan population.  

The Vouga Abogados team, led by partners Rodolfo G. Vouga and Manuel Acevedo, and comprising senior associate Cecilia Vera, associates Lucas Rolón, Belén Rodriguez, Camila Dutra, and other team members, was responsible for managing the legal and regulatory due diligence, drafting and negotiating the transaction documents, as well as advising on regulatory requirements before the Central Bank of Paraguay and the National Competition Commission.

At Vouga Abogados, we are proud to support strategic transactions of this magnitude, reaffirming our commitment to legal advisory in mergers and acquisitions, fintech, and financial regulation, while contributing to the development of the digital financial ecosystem in Paraguay.

Through Resolution SV. SG. No. 022/2025 dated December 11, 2025 (the "Resolution"), the Superintendency of Securities ("SIV") of the Central Bank of Paraguay approved the Regulations of the Central Securities Market and Products Information Center (“Central Information System”) and provided for the creation of a single and standardized scheme for the submission of regulatory information by supervised entities.

The Central Information System is a unique and mandatory standard for the submission of regulatory information. Its technical structure is detailed in the Annex to the Resolution and defines the formats, validations and quality rules that must be met by the reports submitted to the SIV.

The new regime is mandatory for the following: (i) brokerage firms; (ii) investment fund management companies; (iii) stock exchange; (iv) central securities depositories; and (v) other entities or market agents that the SIV determines.

Likewise, the Resolution introduces the principle of the reporting entity, prioritizing that the information is sent directly by the entity that originates the data, in accordance with its role within the securities market.

The SIV has provided for a pilot testing phase and technical validations, under the conditions and with the entities to be determined subsequently by Circular. During this period, the selected entities will be required to submit test information, report incidents, and participate in technical follow-up sessions, while, in parallel, the submission of information under the currently applicable reporting schemes will be maintained.

The obligation to submit information exclusively through the Central Information System will become effective as of the date of final production launch to be established by the SIV.

Through Circular UIF-SEPRELAD/SE No. 02/2025 dated November 14, 2025 (the "Circular"), the Secretariat for the Prevention of Money or Property Laundering ("SEPRELAD") reminds the obligated entities of the continued validity of reporting obligations and the applicable deadlines for their compliance through the Integrated Operations Reporting System ("SIRO").

The Circular does not introduce new obligations; rather, it consolidates the required reports, their respective deadlines, and the administrative procedures associated with SIRO. It is addressed to obligated entities in general and, in particular, to sectors such as: remittance companies, real estate companies, non-profit organizations (NPOs), importers and dealers of motor vehicles, dealers in jewelry and precious metals, virtual asset service providers (VASPs), pawnshops, lawyers, accountants, cash-in-transit companies, custodial services and safe-deposit box rental services, among others.

The Circular details the reports that must be submitted through the SIRO:

Obligation	Expiration
Annual Form	May 31
Objective Operations Report	Remittance companies: Monthly, from 20 to 30 Other obligated entities: Quarterly, from 11 to 20
Negative Report	Quarterly
Internal Audit Report	March 30
External Audit Report	June 30
Compliance Officer's Report	As triggered in accordance with each applicable sectoral regulation
Suspicious Transaction Report	In accordance with the applicable sectoral regulation

Likewise, the Circular recalls the administrative procedures that must be carried out before SEPRELAD through the SIRO, and that are subject to the payment of tariffs. Among them:

Procedure in SIRO environment	General
Registration of an obligated entity in the registry of non-naturally supervised obligated entities before SEPRELAD	Resolution No. 07/2018 – Collection of Fees Resolution No. 235/2020 – Extension of Resolution No. 07/2018
User of SIRO	Resolution No. 48/2025 – Annual fee for obligated entities, by the ROS_WEB application, for the fiscal year 2025
Registration in the Registry of Specialized AML/CFT/CPF Auditors	Resolution No. 29/2023 – Five minimum wages established for various activities not specified in the Republic of Paraguay

Finally, the Circular clarifies that external management or advisory services are authorized for the purpose of processing compliance with the obligations applicable to obligated entities, specifically in matters related to AML/CFT/CPF prevention and control measures. Such assistance may include the preparation and updating of prevention manuals, codes of ethics, self-assessments and risk matrices, internal and external audit reports, verification mechanisms and watchlist screening and monitoring, as well as the preparation and submission of the reports required by SEPRELAD.

Through Resolution No. 25 Minute No. 58 dated December 18, 2025, the Board of Directors of the Central Bank of Paraguay ("BCP") approved the Regulations for the Definition of Roles, Registration and Information Transparency and Information Security for Payment Service Providers ("PSPs") of the National Payment System (the "Regulation").

The Regulation defines the roles that PSPs may perform, based on the payment services they provide and the responsibilities they assume towards users, merchants, other system participants and the BCP.

The roles defined include, among others, acquirer, issuer, payment gateway, payment processor, digital wallet provider, and sub-acquirer. The Regulation expressly admits that the same PSP can perform multiple roles, clarifying that this does not exempt it from the individual compliance of the obligations associated with each function.

The Regulation establishes the mandatory registration of PSPs in a registry administered by the BCP. The General Management will will determine, through supplementary regulations, the deadlines, forms and requirements for registration, and the BCP will be empowered to request additional information to verify compliance with the associated obligations.

PSPs that maintain a direct contractual relationship with users and/or businesses must comply with the following obligations of information transparency: (i) clear and accessible publication of commissions, rates and other applicable economic conditions; (ii) prior notice of contractual modifications thirty (30) calendar days in advance; (iii) the use of contracts drafted in clear and accessible language; and, (iv) the implementation of effective, free and documented mechanisms for attention and resolution of complaints.

In addition, PSPs must make available to merchants and/or users, on an ongoing basis, detailed and exportable reports on the status of transactions, the costs applied to each transaction, net amounts credited, and settlement timeframes. 

The Regulation introduces the obligation to segregate funds for those PSPs that manage or custody funds of users or businesses, particularly issuers and sub-acquirers, by maintaining differentiated accounts that protect such funds against creditor claims. Acquirers, processors and payment networks that do not hold funds are exempt from this obligation, although they must guarantee the traceability, security and correct reconciliation of the transactions processed.

Another component of the Regulation is the establishment of minimum standards in terms of information security, based on a risk approach and proportionate to the scale and complexity of each PSP.

Among other aspects, PSPs must implement an Information Security Management System (ISMS) that includes formal security policies, access controls, data encryption, vulnerability management, business continuity plans, and incident notification procedures to the BCP. Compliance must be evidenced through external audits based on internationally recognized standards, such as ISO/IEC 27001.

Through Resolution No. 24 Act No. 57 dated December 11, 2025, the Board of Directors of the Central Bank of Paraguay ("BCP") approved the Regulation on Interoperability and Interconnection in the Credit and/or Debit Card System (the "Regulation"), establishing a mandatory regulatory framework aimed at guaranteeing non-discriminatory conditions of access, security, efficiency and competition in the card payment ecosystem.

The Regulation was issued within the framework of the powers conferred upon the BCP by Law 7503/2025 "National Payment System" and responds to the need to correct structural and contractual limitations that have hindered the development of a fully interoperable environment in the card payment market.

The Regulation is mandatory for all Payment Service Providers (PSP) that are directly or indirectly involved in the processing of credit and/or debit card transactions. This includes, but is not limited to, issuers, acquirers, subcontractors, processors, and other actors that intermediate in the processing of card payment transactions.

One of the key pillars of the Regulation is the obligation of the relevant entities to: (i) submit to the BCP, within six (6) months following the entry into force of the Regulation, the agreements and implementation plans for interoperability, and (ii) accompany said agreements and plans with a technical, operational and cybersecurity schedule that allows interoperability and interconnection to be achieved within a maximum period of thirty-six (36) months.

In the event of non-compliance, the BCP is empowered to unilaterally define the applicable technical, operational and security requirements.

Additionally, it is established that all payment terminals must allow the processing of credit and/or debit card operations of any national issuer, regardless of the initiation method used.

The Regulation introduces specific obligations in terms of transparency of promotions and benefits, interoperability of promotions, confidentiality of the commercial and strategic information of the participants. In addition, interoperability contracts may not contain clauses that are exclusionary, discriminatory or that condition access to the system.

The contracts signed between the parties must be available to the BCP and any breach thereof must be promptly reported both to the counterparty and to the Sub-General Management of Financial Operations (“SGGOF”).

The SGGOF may require reports of incidents that have occurred, detailing the affected systems or services, their impact and any other information it deems relevant.

Likewise, should the BCP identify indications of, or receive complaints regarding, conduct or practices that may constitute violations of competition law, it will forward the relevant information to the National Competition Commission (CONACOM). 

We are pleased to have advised the OPEC Fund for International Development (OPEC Fund) in the structuring and granting of a USD 45 million syndicated loan to Sudameris Bank S.A.E.C.A., aimed at strengthening financing for small and medium-sized enterprises (SMEs) in Paraguay. The loan is designed to boost key sectors of the Paraguayan economy, with a particular focus on the agricultural sector, which remains a cornerstone of the country’s economy.

This transaction highlights the OPEC Fund’s growing role as a trusted organizer and catalyst for development financing. Through its strong relationships with public and private institutions, including the commercial banks of its member countries, the OPEC Fund is creating a positive impact on emerging economies, promoting inclusive growth and job creation.

This agreement reflects the shared commitment of the parties to support entrepreneurship and foster productive investment, with an emphasis on women-led businesses and the strengthening of agricultural financing key elements for sustainable and resilient economic growth.

Congratulations to the team led by our partner Carlos Vouga, along with associates Belén Rodríguez and Yvo Salum, for their outstanding work on this transaction.