On Monday, the Cuban Council of Ministers announced the release of Decree 32, a set of rules governing the establishment of foreign commercial representations, published in the Special Edition No. 20 of the Official Gazette for 2026. This updated version refines the original 2021 regulations that outline how foreign entities may operate within Cuban territory.
Signed by Prime Minister Manuel Marrero Cruz, the decree outlines the general regulations for the authorization, registration, modification, functioning, and closure of foreign representations in Cuba, which include representation offices, branches, and agency or representation contracts.
The special edition release follows the mandate of the Second Final Provision of Decree 183, dated September 21, 2026, which called for an updated and coordinated version of the original Decree 32 from February 2021. This amending decree was published in the Ordinary Edition No. 82 of the Official Gazette for 2026 on October 2.
National Registry of Foreign Commercial Representations
A key aspect of the regulation is the establishment of the National Registry of Foreign Commercial Representations, under the auspices of the Chamber of Commerce of the Republic of Cuba. All entities operating under these formats must be registered here as a requirement.
The license confirming this registration is valid for a maximum term of five years.
Authorization for Foreign Entities
Foreign entities—including commercial companies, individual entrepreneurs, and trade and investment promotion bodies—can apply for authorization from the Minister of Foreign Trade and Investment to open a representation office or branch, or to engage the services of an authorized agent.
The decree clearly defines the legal scope of each form. Representation offices are intended to offer informational and advisory services about the activities, products, or services of their parent companies and are prohibited from conducting independent commercial operations within Cuba. Branches, however, may carry out commercial transactions on behalf of their parent company, aligned with the main entity's business objectives.
In both cases, these representations "do not possess independent legal personality or separate assets from the foreign entity establishing them," meaning the parent company is accountable for any obligations or debts incurred.
Judicial Obligations and Expanded Activities
Both representation offices and branches are required to accept judicial summons, citations, and notifications from Cuban courts in legal proceedings involving the foreign entity that established them.
Decree 183/2026, which prompted this update, broadened the activities allowed for foreign branches, incorporating direct import and export for commercial purposes, wholesale trade, invoice issuance, and goods distribution. However, general retail trade remains prohibited for these entities.
Additionally, Decree-Law 137/2026, also published in Gazette No. 82, allows foreign commercial representations to hire workers directly in Cuba, removing the previously mandatory state mediation in employment.
The full text of the updated Decree 32 spans pages two to 11 of the Special Edition No. 20 of the Official Gazette for 2026 and is available for consultation and download.
Frequently Asked Questions on Foreign Commercial Representation in Cuba
What is the purpose of Decree 32 in Cuba?
Decree 32 establishes the regulations for authorizing, registering, modifying, operating, and closing foreign commercial representations in Cuba, including representation offices and branches.
What is the National Registry of Foreign Commercial Representations?
It is a registry under the Chamber of Commerce of the Republic of Cuba where all foreign entities operating as commercial representations must register.
How long is the registration license valid for foreign representations in Cuba?
The registration license for foreign commercial representations in Cuba is valid for up to five years.