Cuba Publishes New Rules for Foreign Commercial Representations (Gaceta Oficial No. 82)

What changed

Gaceta Oficial No. 82 Ordinaria (2 October 2026) contains five measures: (1) Decreto-Ley 137/2026 (Consejo de Estado) regulates the hiring of workers for administrative, technical and service positions by foreign representations in Cuba; eligible foreign commercial representations can now hire workers directly instead of being required in all cases to use an authorized state employment entity. (2) Decreto 183/2026 (Consejo de Ministros) modifies Decreto 32/2021, the regulation governing the establishment of foreign commercial representations. (3) Resolución 151/2026 (MINCEX) regulates the importation of non-commercial goods by foreign commercial representations established in Cuba. (4) Resolución 152/2026 (MINCEX) modifies Article 14 of Resolución 74/2021 on the regulatory framework for foreign commercial representations. (5) Resolución 62/2026 (Ministerio de Trabajo y Seguridad Social) establishes the labour regime for people hired to provide services to foreign representations, regulating both direct hiring and hiring through authorized employment entities.

Who it affects

International companies with or considering a foreign commercial representation in Cuba · Foreign investors · Cuban workers employed by foreign representations · Advisers to foreign companies

What it means in practice

These measures primarily concern foreign commercial representations and their operation in Cuba; they do not give Cuban MiPyMEs new import/export rights. The broader 2026 reforms on MiPyMEs and direct foreign trade are a related but separate legal development. A foreign commercial representation is not a Cuban MiPyME and is not automatically authorized to conduct unrestricted retail or wholesale business in Cuba. These rules do not create a general right for foreigners to buy Cuban residential property, do not automatically provide Cuban residency, and direct hiring does not automatically mean salaries can freely be paid in foreign currency. The measures modernize the overall framework for foreign commercial representations, but they do not turn a representative office into a Cuban trading company and do not eliminate licensing or registration requirements.

CPS note

These measures are relevant for international companies considering a more permanent commercial presence in Cuba, because they reduce some administrative barriers, particularly around staffing and the operation of foreign commercial representations. For property and investment clients, the correct legal structure still matters: property ownership, a foreign commercial representation, formal foreign investment and participation through or with a Cuban MiPyME remain legally distinct routes. Official source: Gaceta Oficial de la República de Cuba, No. 82 Ordinaria, 2 October 2026.

Last verified: 6 October 2026