Critical January 30, 2026 Deadline for Act 60 Annual Report Compliance

What decree holders need to know now

If you hold an Act 60 decree in Puerto Rico, the January 15, 2026 deadline for filing the 2024 Exempt Business Annual Report, also known as the Informe Anual Exento (IANE), has now passed. The focus is no longer on extensions. It is now on avoiding penalties and protecting your decree.

What is the IANE and why it matters

The IANE is a mandatory Act 60 compliance filing submitted through the Incentives Portal. It is how the Puerto Rico Department of Economic Development and Commerce (DDEC) verifies that a decree holder continues to meet the terms and conditions of its Act 60 decree. This filing is separate from the Puerto Rico income tax return and is required even if the tax return was extended.

Prior to this year, the Incentives Portal was not enabled for all decree holders under Act 60. This limited which taxpayers could comply electronically and created uncertainty for decree holders under other incentives programs.  Historically reporting was only enabled for Act Nos. 73-2008, 20-2012, 22-2012, 135-1997, and 83-2010, as amended (“prior incentives laws”). DDEC Informational Bulletins No. DDEC 2025-007, 2025-008, and DDEC 2025-016 changed this. Now decree holders of Young Entrepreneurs, Scientists, Doctors, Tourism businesses, Private Equity, Historical Zones, Assisted Living, Social Interest Housing, Agroindustries and Bonafide Agriculturer, Film, Air and Maritime Transportation, and Cruise ships can and must file the annual report via the incentives portal.

What happens now that the compliance deadline has passed and the
January 30 relief window applies

Under DDEC Informational Bulletin No. DDEC 2025-016, decree holders who did not file the 2024 IANE are considered non-compliant. DDEC has provided a short relief period, but it is closing quickly.

If the IANE is filed on or before January 30, 2026, the non-compliance notice is voided and no automatic penalty applies. This is the final opportunity to file the IANE without financial consequences.

Penalties and decree risk after January 30

If the IANE is not filed by January 30, 2026, enforcement escalates:

  • An automatic $1,000 penalty applies effective January 30.

  • Failure to pay that penalty within 15 days may result in an additional $5,000 fine.

  • Continued non-compliance may trigger decree revocation proceedings.

Revocation can result in the loss of Act 60 benefits and the application of regular Puerto Rico income tax rates, which can reach up to 37.5 percent.

Who should take action now

This applies to Act 60 decree holders, as well as decree holders under prior incentives laws whose decrees are now reported through the Incentives Portal, who were required to file the 2024 IANE and have not yet done so. It does not apply if the report was already filed in accordance with the decree or if the decree does not require filing this report.

If you are unsure whether the IANE was required or whether it was properly filed, do not assume compliance.

Bottom line

January 30, 2026 is the last opportunity to correct non-compliance before penalties and potential decree revocation begin.

If you hold an Act 60 decree, now is the time to:

  • Review your decree language

  • Confirm whether the 2024 IANE was required

  • Verify that the report was actually filed

  • File immediately if it has not been submitted

Taking action before January 30 can avoid penalties and help protect your Act 60 benefits.

If you need assistance reviewing your compliance status or completing the filing, contact us at support@izquierdolawllc.com.