DLA Piper Puerto Rico | View firm profile
September 19, 2025
Written by: Miriam Figueroa, Adriana Perez-Rentas, Nikos Buxeda
Puerto Rico recently approved Law No. 102-2025 – known as the Universal Recognition of Occupational and Professional Licenses Act – simplifying the process for qualified professionals holding valid licenses in the US to apply for, and obtain, equivalent licenses in Puerto Rico.
Law No. 96-2025 was also recently approved to create a uniform process to grant licenses applicable to examining boards in certain professions and occupations under the helm of the Puerto Rico State Department.
This policy shift has been framed as an attempt to implement structural reforms that will ease the process of doing business in Puerto Rico. It also responds to one of the Puerto Rico Fiscal Plans’ objectives of facilitating participation in the labor force and incentivizing qualified workers to move to and stay in Puerto Rico, under federal Public Law No: 114-187 (Puerto Rico Oversight, Management, and Economic Stability Act or PROMESA).
Though reciprocal licenses have traditionally been allowed by the laws that regulate the respective occupations or professions in Puerto Rico, the processes vary and can be complex and time-consuming.
In an attempt to simplify and optimize these processes, Laws No. 96-2025 and 102-2025 aim to streamline applications for a number of occupational and professional licenses in Puerto Rico by providing a standardized process for all licenses and requiring decisions to be made within specified timeframes. The professions and occupations included in these reforms include, but are not limited to:
- Agronomists
- Architects
- Landscape architects
- Public accountants
- Real estate agents
- Interior designers
- Geologists
- Engineers
- Electricians
General application requirements
With the approval of Law No. 102-2025, any person holding a valid occupational or professional license and/or government certification (with certain exceptions, such as attorneys at law) issued by a state of the US, may apply for an equivalent license in Puerto Rico so long as they comply with the following requirements. The applicant must:
- Have held the license for a minimum of one year and have practiced in the relevant occupation or profession for at least three consecutive years prior to filing the application
- Have not been inactive for more than one year prior to the filing of the application
- Have been required to pass a test or comply with minimum education requirements in order to receive the license
- Be in good standing
- Have no criminal record
- Have not had their license revoked by a board due to negligence or bad acts, and
- Have no history of complaints or investigations related to their profession.
In addition to the above, each applicant must pay all relevant application and administrative fees and join local professional colleges, if so required.
Government certifications
With respect to the provision of certain professional or occupational services that do not require a license in the state of origin, but do require a license in Puerto Rico, Law No. 102-2025 provides that, in such cases, provisional licenses shall be issued upon submission of a government certificate from the state of origin while the applicant completes local permanent licensing requirements. Applicants must have a minimum of three consecutive years of experience in the relevant field and comply with all the other applicable requirements listed above.
Approval period for licenses
Laws No. 96-2025 and No. 102-2025 provide for an expedited review and application period for occupational and professional licenses, which requires the relevant local board to review and approve or deny applications within 30 days of their filing. If the local board does not approve or deny the application within the 30-day period, the applicant will be automatically issued a provisional license so that the applicant may practice the occupation or profession in Puerto Rico while the local board completes deliberations. The local board will have a maximum of 30 additional days to complete the review of the application.
Under Law No. 96-2025, if the board has not made a determination at the expiration of the additional 30-day period, it will be required to issue the license. Similar language is not included in Act 102-2025. However, given the clear language of Act 96-2025 and the fact that Act 102-2025 does not have a contradictory mandate, it appears that at least the examining boards under the helm of the Puerto Rico State Department, will be required to comply and issue permanent licenses if they have not acted upon application in 60 days. This is a key reform resulting from these new laws since it has the potential of imposing specific and short deadlines on board members and their support staff to evaluate and accept or reject applicants’ licenses.
Regulations and future amendments
The laws require the adoption of their respective regulations within 180 days from the approval of these laws. These regulations have not been adopted and may further provide clarity and guidance on how these laws will be interpreted and implemented in the future. Additionally, further statutory review may be forthcoming as the Governor of Puerto Rico has stated that amendments will most likely be required.
For more information, please contact the authors.