Act 60 Annual Requirements: What Every Decree Holder Owes, Every Year
A decree carries a permanent annual to-do list: report, fee, donation, CPA letters, residency logs, Puerto Rico tax filings. Since January 15, 2026, DDEC's Office of Incentives issues deficiency notices and fines automatically for an unfiled annual report, starting at $1,000 and escalating toward revocation.
Watch — the annual cycle in 2 minutes
The annual compliance calendar
| Obligation | Deadline | Consequence of failure |
|---|---|---|
| $10,000 donation ($5,000 CECFL-list + $5,000 Hacienda-qualified) | December 31 of the tax year | Decree non-compliance; a leading deficiency finding |
| DDEC annual report + supporting docs | November 15 (for the prior year) | Automatic $1,000 fine, escalating to revocation |
| Annual report filing fee ($5,000 — $300 DDEC + $4,700 Hacienda) | With the report | Report not accepted |
| PR income tax return (Hacienda) | PR filing deadline | Standard tax penalties + decree exposure |
| Federal obligations (incl. Form 8898 in start/end years) | Federal deadlines | Federal penalties |
The donation: where compliance actually breaks
- Wrong split. $5,000 to CECFL-list organizations (the Comisión Especial Conjunta de Fondos Legislativos para Impacto Comunitario) and $5,000 to Hacienda-qualified nonprofits — $10,000 to one charity in the wrong bucket is still a deficiency.
- Wrong organization. The recipient must be on the current list at the time of donation; lists change.
- Late. Wire delays and year-end processing have produced January receipts and compliance findings.
- Undocumented. No receipt, no proof.
The new portal requirements: proof, not promises
DDEC's updated portal requirements move annual compliance from attestation toward evidence: residency logs documenting presence and CPA verification letters supporting the filing. In practice the report now assumes the day counts and evidence file have been kept all year.
The enforcement escalator
Late filing → $1,000 automatic fine → continued non-compliance → deficiency proceedings → annulment or revocation. The 2025 numbers show every rung in use — ~1,800 decrees audited, 305 deficiency notices, 19 annulments, 4 revocations (what audits look like). Revocation isn't just prospective: it reopens the question of taxes on income you thought was covered.
The annual rhythm that works
Compliant holders converge on the same pattern: donations documented by early December (not the 31st), the evidence file maintained continuously rather than assembled annually, day counts tracked live, and the annual report prepared from records that already exist. The requirements are only burdensome as a once-a-year archaeology project.
Frequently Asked Questions
- Do the obligations pause if I travel for a year?
- No — and extended absence creates a bigger problem than filings: the residency tests are annual too.
- Can I donate $10,000 to one charity?
- Only if the split requirement is still satisfied — the two $5,000 buckets are separate legal requirements.
- What if I miss the report deadline by a day?
- The 2026 regime made the first fine automatic — the grace period is gone.