Electronic promissory notes and bills of exchange. For everyone, or just for some?

Articles22 June 2026
It took the country far too long to move from the legislation passed in 2021 to actual implementation in 2025. Furthermore, the regulatory framework meant that, in practice, only an entity with the characteristics of a central securities depository could take on the role of registrar. The result was a legal framework that was slow to be implemented.

"In 2021, Costa Rica passed Law 10069, which allows for the issuance and dematerialisation of electronic bills of exchange and promissory notes. The idea was sound: to replace paper, physical custody and in-person signatures with secure, traceable digital documents. In a country seeking to modernise its business and financial markets, this reform was intended to benefit SMEs, banks, retailers and individuals who document payment guarantees on a daily basis,” commented Arturo Guerrero, a partner at ECIJA in Costa Rica, in his column for La República.


Several years on, the promise has only been partially fulfilled. SUGEVAL authorised InterClear as a centralised registration entity. It launched a document registration product for banks. This shows that the system works; at least, there are no documented complaints. It also highlights a problem, however, because its implementation today should not be aimed solely at banks handling high volumes of transactions; it should be accessible to everyone.


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