The Council of Ministers of Cuba published a decree in the Official Gazette this Tuesday that regulates foreign commercial representations on the island, confirming that representative offices cannot import or export for commercial purposes, nor engage in wholesale or retail trade, issue invoices, or distribute or transport goods within the national territory.
The regulation, signed by Prime Minister Manuel Marrero Cruz, is an updated version of Decree 32 from February 2021 and comes into effect 30 days after its publication in the Official Gazette.
The text establishes an important distinction between two legal entities: representative offices, which face the strictest restrictions, and branches, which according to the Decree 183/2026 published on October 2, are allowed to import and export for commercial purposes, engage in wholesale trade, issue invoices, and distribute goods. The only activity that is still prohibited for branches is general retail trade.
The decree specifies that both representative offices and branches "do not have their own legal personality, nor independent assets from the foreign entity that establishes them", meaning that the parent company is responsible for all its obligations and debts under Cuban law.
The regulation also requires these representations to receive and process court summons, citations, and notifications from Cuban courts in any proceedings involving the foreign company that establishes them.
As part of the new regulation, the decree establishes the National Registry of Foreign Commercial Representations, affiliated with the Chamber of Commerce of Cuba, where all entities operating under these modalities must register.
The registration license will have a maximum validity of five years, and the entities already active on the island will have 180 days from the entry into force of the decree to complete this process.
The regime justifies the measure by stating that the "transformations in foreign trade and the accumulated experience suggest eliminating the existing regulatory dispersion" and adapting the rules "to the terms and practices of international use."
This regulation is part of the package of 176 economic and social reforms approved in June 2026, which Marrero Cruz himself presented to the National Assembly. According to the government's most recent report, 91% of those measures —160 out of 176— are already underway, supported by 197 ratified legal norms.
The reform package promises to liberalize and decentralize the Cuban economy, but in practice, the state maintains control over the crucial points of commerce: licenses, banks, customs, ports, importers, storage, and access to foreign currencies.
The Cuban private sector is also going through a fragile moment: in 2025 it recorded its first historical decline in active companies since its legalization in 2021, with a net closure of 816, while the government closed dozens of small and medium enterprises in a program of "correction of distortions."
Foreign entities operating in Cuba that must register in the new registry have up to 180 days from the date of entry into force of the decree to regularize their situation with the Chamber of Commerce.
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