Written by: Anthony O. Maceira, Mabel Sotomayor, Francisco González-De la Matta
Puerto Rico has enacted Law 102-2025 and Law 96-2025, establishing a reciprocity regime for occupational and professional licenses issued in U.S. jurisdictions. The legislation introduces fixed review deadlines, authorizes provisional licensing if boards fail to act, and places oversight responsibility on the Puerto Rico Department of State.
Until 2025, professionals relocating to Puerto Rico were often required to repeat local licensing processes, despite holding valid credentials in other states. This created barriers in sectors already facing workforce shortages. With the adoption of Law 102-2025, Puerto Rico joins more than two dozen states that have implemented ‘universal recognition’ statutes. According to the National Conference of State Legislatures, this policy has been gaining traction across the country as a way to reduce barriers for relocating workers and the Instituto de Libertad Económica, states that Puerto Rico is now the 28th jurisdiction to adopt such legislation, strengthening the Island’s competitiveness in attracting skilled labor.
Law 96-2025 complements this framework by amending the Department of State’s examining-board procedures and creating a uniform, deadline-driven process. Similar provisions in states such as Arizona and Missouri have proven effective at streamlining licensing for mobile professionals, and Puerto Rico’s model is now aligned with these trends.
The reforms extend across the licensing boards overseen by the Department of State. Professions expressly included are:
The practice of law is excluded. The Department of State’s examining boards portal will publish guidance as regulations take effect.
To qualify, applicants must:
The law also provides for provisional licenses where the home jurisdiction does not require a license but Puerto Rico does, enabling immediate practice while local requirements are completed.
Law 96-2025 sets strict deadlines: within 30 days of a complete application, boards must approve or deny. If no action is taken, the applicant receives a provisional license. Boards then have an additional 30 days to finalize. At 60 days, if no decision has been issued, the license is deemed approved.
For professionals, the reforms provide certainty and predictability. Relocation planning is simplified by knowing that within 30 days provisional practice is possible, and within 60 days the application must be resolved.
For employers, the changes create opportunities to recruit from the mainland with less risk of delay. Hospitals, engineering firms, and construction companies should update onboarding processes to incorporate provisional licensing and monitor statutory timelines.
For licensing boards, the statutes transfer the risk of delay to the agency. Boards must adopt case-management systems capable of meeting the deadlines, as failure to act will now result in automatic licensure.
For policymakers, Puerto Rico’s alignment with the national reciprocity trend is a strategic step to attract talent, reduce barriers, and support economic development.
The Department of State must issue implementing regulations within 180 days. These rules will define documentation requirements, equivalency standards, and procedures for provisional licensing. Given that the statutes were signed on July 2, 2025, the 180-day period expires on December 29, 2025. As of the day of this publication, boards and applicants therefore have roughly three months before the first regulatory framework must be in place.
For more information, contact the authors of this article.
