Certified Professionals Under Act 60-2019: Preparing for the Next Phase of Puerto Rico’s Incentives Code

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A New Layer of Professional Oversight

Puerto Rico’s Incentives Code (Act 60-2019) continues to evolve as the government refines how tax-exemption decrees are administered and audited.  One of the most significant—but still pending—developments is the creation of the Certified Professional designation, a mechanism authorized in Section 6060.03 of the Code that empowers the Department of Economic Development and Commerce (DDEC) to accredit qualified professionals to assist exempt businesses and decree holders.

While the DDEC has yet to issue the implementing regulation, the statutory language already outlines the foundation of what could become a transformative compliance tool for Puerto Rico’s incentives ecosystem.

Legal Basis

Section 6060.03 of Act 60 establishes that:

“Every Exempt Business and its shareholders shall be entitled to receive assistance from any authorized person to represent them; however, Certified Professionals must be either attorneys admitted to the Bar or certified public accountants.”

This provision distinguishes between ordinary advisers and Certified Professionals, granting the latter formal recognition by the government to prepare, certify, and submit filings related to Act 60 decrees.  The DDEC is tasked with adopting a Regulation of Certified Professionals defining qualifications, duties, and disciplinary measures.

Anticipated Role and Scope

Once implemented, Certified Professionals are expected to:

  • Prepare and validate applications for new or amended tax-exemption decrees;
  • Certify annual compliance reports verifying that decree holders meet investment, employment, and residency commitments;
  • Serve as official intermediaries between businesses and the DDEC, helping streamline document review; and
  • Provide attestations that may carry evidentiary weight before the Treasury Department and other agencies.

Under the statute, only attorneys licensed in Puerto Rico and certified public accountants (CPAs) will be eligible for certification.

Expected Benefits

Area Anticipated Impact
Efficiency Decrease in application and compliance backlog as DDEC relies on pre-validated submissions.
Transparency Standardized reporting improves data integrity and confidence among investors and regulators.
Professionalization Creates a formal community of lawyers and accountants specializing in Act 60 compliance.
Reliability Decree holders gain assurance that filings certified by approved professionals carry official standing.
Administrative relief Allows the DDEC to focus on oversight, enforcement, and policy rather than routine review.

Why Implementation Matters

Puerto Rico’s incentive framework now involves more than 30 000 active decrees.  The DDEC’s limited administrative capacity has made annual compliance verification a persistent challenge.  Launching a Certified Professional system could decentralize that work while maintaining accountability through regulated practitioners.

The anticipated regulation would likely require:

  • Proof of Bar admission or CPA license in good standing;
  • Training or examination on Act 60 provisions and ethics;
  • Continuing-education obligations;
  • Annual renewal and fee payment; and
  • Publication of a public registry of Certified Professionals available to decree holders and investors.

Relationship to Qualified Promoters

Act 60 also introduces the figure of the Qualified Promoter (Promotor Cualificado) in Section 6060.04, managed through Invest Puerto Rico.  Whereas Qualified Promoters attract investment and new businesses to the Island, Certified Professionals will focus on technical execution and compliance after incentives are granted—two complementary roles in the same ecosystem.

What Businesses and Practitioners Should Expect

  • For decree holders: expect future DDEC guidance requiring that certain reports or certifications bear the signature of a Certified Professional.
  • For attorneys and CPAs: early preparation—training teams on decree reporting, developing compliance templates, and tracking upcoming rule-making—will position firms to apply as soon as the program opens.
  • For investors: engaging counsel or accountants likely to be certified can reduce processing time and increase regulatory predictability once the system goes live.

MZLS Perspective

At MZLS, we anticipate that the implementation of Certified Professionals under Act 60 will mark the next stage of modernization in Puerto Rico’s incentives administration—aligning government oversight with professional accountability.  The initiative, once activated, could mirror accreditation models used by the IRS or the SEC, improving both transparency and investor confidence.

MZLS advises decree holders, investors, and professionals on compliance and regulatory developments under the Incentives Code.  Learn more about our Business & Commercial Law and Litigation & Dispute Resolution practices, and explore additional analyses on MZLS Insights.

Further Reading on Act 60

This analysis builds on a series of MZLS Insights exploring how Puerto Rico’s Incentives Code (Act 60-2019) continues to reshape investment and compliance across multiple sectors.
For a broader understanding of Act 60’s structure, our publication Export of Services and Financial Incentives under Act 60 outlines the mechanics of Chapter 4’s 4 percent tax rate and dividend exemptions, while Tourism Incentives Under Puerto Rico’s Act 60-2019 examines visitor-economy benefits and investment credits.
Additional context can be found in Manufacturing Incentives in Puerto Rico: Key Benefits and Requirements, which analyzes export-manufacturing relief, and in Puerto Rico Tax Incentives: Benefits of the Individual Resident Investor, detailing individual-investor decrees.
Investors and institutional clients may also consult Why Puerto Rico Is the Best Destination for Private Equity Investment and Tax Incentives Under Act 60 for a private-equity perspective.

Regarding the financial sector, the National Law Review’s discussion of Act 60 provides additional perspective on the Code’s global-finance and fintech impact, complementing MZLS’s continuing coverage.