We advised a company in the early stages of developing a large-scale electrofuel (eFuel) production facility in Paraguay within the RFNBO (Renewable Fuels of Non-Biological Origin) category. The client, a foreign investor in the renewable energy sector, identified a strategically located site in the District of Villeta, on the Paraguay River, for the development of an electrolysis plant and related infrastructure, including pipeline corridors, a dedicated electrical substation, and potential port facilities for bulk methanol exports.
Our engagement focused on structuring the legal framework for the acquisition of the target site and protecting the client's position during the pre-investment phase, ensuring legal certainty over the parcels of interest while technical, environmental, and commercial due diligence is carried out.
Our Role and Scope of Advice
Our advice included:
a. Structuring the acquisition, assessing alternative mechanisms to secure the client's rights over multiple parcels owned by different landowners, with different title histories and legal statuses, including parcels subject to ongoing judicial proceedings.
b. Drafting and negotiating two parallel pre-contractual instruments: a Letter of Intent (LOI) with one landowner and a Memorandum of Understanding (MOU) with the other, each tailored to the specific legal and commercial circumstances of the relevant parcels.
c. Conducting title review and legal risk analysis, including identification of a title overlap dispute affecting two key parcels, assessment of a pending revindicatory action and judicial survey proceeding, and analysis of a title consolidation issue arising from an acquisition made on behalf of a company in formation.
d. Designing a multi-layered acquisition structure covering outright purchases, irrevocable purchase options for future expansion phases, pipeline corridor rights (through ownership or easement, depending on due diligence findings), a conditional tank storage option linked to port feasibility, and acquisition of the electrical substation together with underground cable routing rights.
e. Drafting payment protection mechanisms, including deferred payment arrangements linked to indemnity conditions to mitigate double-payment risk arising from the title dispute, together with vendor indemnities covering potential professional fee claims by attorneys involved in the underlying litigation.
f. Coordinating both parallel transactions to ensure consistent treatment of the title overlap dispute affecting parcels owned by each counterparty.
Key Legal Challenges
The transaction involved several significant legal challenges:
Overlapping title dispute. Two strategically important parcels, one owned by each counterparty, were affected by an ongoing title overlap dispute subject to judicial proceedings. The planned access corridor to the port crossed the disputed area, directly linking title risk to the operational viability of the project. The transaction structure was designed to allow negotiations to progress while protecting the client from exposure to the underlying dispute.
Fragmented title structure. The parcels covered by the MOU were distributed across separate properties with differing ownership histories, requiring careful coordination of the acquisition structure.
Multi-layered acquisition framework. The project's phased development required five different acquisition mechanisms—outright purchase, purchase options, conditional options, easement or ownership rights depending on due diligence outcomes, and underground cable routing rights—each requiring tailored legal treatment while maintaining consistency across both framework agreements.
Regulatory and infrastructure considerations. The transaction also required anticipating regulatory requirements for the construction and operation of a dedicated electrical substation (ANDE authorization), underground cable crossings under public roads (municipal permits), and future port access arrangements, which were incorporated into the contractual framework through conditions precedent and cooperation obligations.
Outcome and Current Status
Negotiations of both framework agreements have progressed positively, and the parties have reached alignment on the principal commercial and legal terms. While the transactions remain subject to ongoing negotiations and execution of the final documentation, the proposed contractual framework provides the client with a solid legal basis to continue its due diligence and advance the project.
The proposed transaction structure is expected to provide the client with:
Exclusive rights over all target parcels for an 18-month period, covering the due diligence and contract negotiation phases, with both counterparties undertaking not to encumber or dispose of the relevant parcels.
A coherent legal framework for a phased acquisition covering the initial electrolysis site, future expansion areas, pipeline and substation infrastructure, and conditional port-related rights.
Protection against the title overlap dispute through conditions precedent, deferred payment arrangements, and vendor indemnities addressing both the underlying dispute and potential professional fee claims arising from the litigation.
A clear due diligence roadmap identifying the principal legal, cadastral, and regulatory workstreams required prior to closing, including recommendations on title verification, cadastral overlay analysis, and regulatory pre-assessments.
Throughout the engagement, our team has acted as a strategic legal adviser, anticipating risks, coordinating the parallel negotiations, and developing practical solutions aligned with the client's commercial and operational objectives.
Through Resolution SV.SG. No. 0022/2025, dated December 11, 2025, the Superintendency of Securities (“SIV”) of the Banco Central del Paraguay (“BCP”) approved the Regulation of the Central Information System for the Securities and Products Market (the “Regulation”), introducing changes to the current framework governing the submission of regulatory information.
The Central Information System is mandatory for broker-dealers, fund management companies, stock exchanges, central securities depositories, and other market entities and participants as determined by the SIV.
The Regulation establishes a single and mandatory standard for the submission of information by supervised entities. From an operational standpoint, the Central Information System operates as a centralized platform through which entities must submit their reports in standardized formats and in accordance with uniform technical specifications.
Additionally, the Regulation introduces stringent data quality standards, including the obligation to perform pre-submission validations, the automatic rejection of files containing critical errors, and requirements regarding the traceability and completeness of the information. In this regard, supervised entities will bear direct responsibility for the integrity, accuracy, and quality of the data submitted.
Through Circular SB.SG. No. 00101/2026, dated July 1, 2026, the Superintendency of Banks ("SIB") established a new procedure for the submission and processing of documents through its filing desk, applicable to banks, finance companies, exchange houses, electronic payment service providers, credit bureaus, general warehouses, the Development Finance Agency (AFD), and trust companies (the "Circular"). This new submission procedure will become effective on August 1, 2026.
The Circular provides that documents submitted by the above mentioned entities must bear a qualified electronic signature issued by a trust service provider authorized by the Ministry of Industry and Commerce (MIC) and must be submitted in PDF format to the SIB's official filing desk email address. In addition, the Circular establishes general guidelines governing the submission of documentation.
The Circular also sets out the procedure for the receipt and registration of submitted documents, allowing the SIB, where appropriate, to require the physical submission of certain documents. Where no physical submission is required, receipt of the filing will be confirmed by email through the assignment of a filing number.
Through Resolution G.G. No. 83/2026, dated June 29, 2026, the Central Bank of Paraguay ("BCP") approved the Operational Regulation for the Registration of Payment Service Providers ("PSP") within the National Payment System (the "Regulation"), establishing the procedure, deadlines, and requirements applicable to the registration provided for under Law No. 7503/2025 on the National Payment System.
The Regulation provides that all PSPs must register with the BCP through an electronic registration form. The registration is declaratory in nature and does not constitute an authorization or license to operate. Each PSP is responsible for the accuracy and updating of the information submitted.
The Regulation also establishes a sixty (60) day deadline for existing PSPs to complete their registration and for new PSPs to register from the start of their operations, as well as a thirty (30) day deadline to notify the BCP of any changes to the information previously provided. The required information includes institutional, functional, and technical data covering corporate, operational, technological, cybersecurity, and business continuity matters.
The Financial Operations General Sub-Management (SGGOF) is responsible for administering the registry, requesting additional information where appropriate, and issuing supplementary provisions for its implementation. In addition, the BCP may publish a list of registered PSPs as a measure aimed at enhancing transparency within the country's payment ecosystem.
Through Resolution No. 13, Act No. 7, dated April 8, 2026, the Banco Central del Paraguay (“BCP”) approved the Regulation on the Liquidity Coverage Ratio (“LCR”), formally incorporating this indicator as a key tool for liquidity risk management in financial intermediation entities (the “Regulation”).
The purpose of the Regulation is to establish the obligation to calculate and maintain the LCR, understood as the indicator that measures an entity’s capacity to meet its net cash outflows over a 30-day period through the holding of sufficient high-quality liquid assets.s
From a technical standpoint, the LCR is defined as the ratio between high-quality liquid assets and projected net cash outflows for such period, which must be equal to or greater than 1. This implies that entities must maintain an adequate level of liquidity to withstand stress scenarios.
One of the most relevant aspects of the Regulation is the definition of the components of the ratio, particularly High-Quality Liquid Assets (HQLA), which are classified into different categories based on their level of liquidity and credit quality.
Additionally, the Regulation sets out specific criteria for calculating cash outflows and inflows under a 30-day stress scenario, including differentiated treatment for retail and wholesale deposits, wholesale funding, derivatives, and other relevant exposures.
With respect to its implementation, a progressive phase-in schedule is established, under which entities must gradually meet the minimum required ratio: 50% as of May 31, 2026; 70% as of August 31, 2026; 90% as of November 30, 2026; and 100% as of March 31, 2027.
Furthermore, in the event of non-compliance with the minimum ratio, entities must justify the causes of the shortfall and submit a remediation plan within a maximum period of 90 days, failing which such non-compliance may be deemed a serious breach under applicable regulations.
The National Directorate of Public Procurement (DNCP) published the call by the Ministry of Public Works and Communications (MOPC) for the construction of sustainable housing in Bañado Sur (Barrio Tacumbú).
Regulation of the Renewable Energy Law
May 19, 2026
Renewable Energy | Promulgation of Decree No. 6034/2026, which regulates Law No. 7599/2025 "On the Modernization of the Regime that Regulates and Promotes the Generation of Electric Power from Non-Conventional Non-Hydraulic Renewable Energy Sources."
Infrastructure | International Public Tender
May 22, 2026
The DNCP published the MOPC call for the rehabilitation and maintenance of the following road sections: Cruce Primavera (PY22) – San Ramón (14.56 km); San Ramón – Concepción (PY22) (13.10 km); access to the Paracel plant site (3.99 km); Santa Rosa access – Route PY05 (4.68 km), with a total length of 36.33 km.
Infrastructure | International Public Tender
May 22, 2026
The DNCP published the MOPC call for the rehabilitation and maintenance of the Concepción – Vallemí – San Lázaro section, with a total length of 181.3 km.
Mobility | Suburban Rail Bill
May 26, 2026
Congress passed the bill "Amending and expanding Law No. 7434/2025 – On the Suburban Rail Reform – and establishing special provisions for the implementation of the project through Government-to-Government (G2G) agreements."
Executive Summary
I. Infrastructure | Construction of Sustainable Housing in Bañado Sur (Barrio Tacumbú)
General Overview
On May 13, 2026, the Ministry of Public Works and Communications (MOPC), through the National Directorate of Public Procurement (DNCP), published International Public Tender 485278 (MOPC Call No. 13/2026) (the "Call") for the construction of various types of sustainable social housing in the new Bañado Tacumbú neighborhood, covering all specialties, including the structural and installation works defined in the approved executive project design (the "Project"). The objective of the Project is to improve the housing conditions of the riverside population in the southern area of Asunción.
Key Features
Project Value and Financing
The works have an estimated value of Gs. 355,160,414,605 (approximately USD 58,000,000). The Project will be financed with funds from the loan granted by the Inter-American Development Bank (IDB) under Loan Agreement No. 4700/OC-PR, approved by Law No. 6424/2019.
The Project is divided into 9 lots: Lots 1 to 3 include 120 single-family homes each (approx. USD 4,600,000 – 4,700,000 per lot); Lots 4 to 6 include between 230 and 231 single-family homes each (approx. USD 8,900,000 – 9,100,000); and Lots 7 to 9 include between 8 and 10 multi-family buildings each (approx. USD 4,976,000 – 6,203,000). Each bidder may be awarded only one lot.
The anticipated execution periods are:
Lots 1, 2, and 3: 12 months from the notice to proceed.
Lots 4, 5, and 6: 14 months from the notice to proceed.
Lots 7, 8, and 9: 15 months from the notice to proceed.
Financial Conditions
An advance payment of 10% of the contract value is provided. Bid maintenance guarantees range between approximately USD 137,000 and USD 270,000 depending on the lot. The award system is based on the lowest qualifying bid that meets the substantive conditions of the bidding documents. Subcontracting is permitted with prior approval from the Works Manager.
Award System
The contract will be awarded to the lowest compliant bid that meets the substantive conditions of the bidding documents. The Call is governed by the IDB Procurement Policies (GN-2349-9).
Subcontracting
The contractor may subcontract works subject to prior approval from the Works Manager.
Contracting Authority
MOPC.
Key Dates
The key dates are: June 30, 2026 — deadline for submission of queries; July 6, 2026 — deadline for submission of bids (9:00 a.m.) and bid opening (9:30 a.m.) at the Main Hall of the MOPC Central Building.
II. Regulation | Non-Conventional Non-Hydraulic Renewable Energy Law
On May 19, 2026, the Executive Branch issued Decree No. 6034/2026 (the "Decree"), which regulates Law No. 7599/2025 "On the Modernization of the Regime that Regulates and Promotes the Generation of Electric Power from Non-Conventional Non-Hydraulic Renewable Energy Sources" (the "NCRE Law").
The Decree sets out the operational framework for the various categories authorized under the NCRE Law: Self-Generator, Co-Generator, Generator, and NCRE Exporter. It is important to note that not all mechanisms under the Decree apply equally to each category. The most relevant provisions are detailed below, organized by applicable category.
I. NCRE Co-Generators and Self-Generators – NCRE Reference Tariff
The remuneration that ANDE pays Self-Generators and Co-Generators for energy injected into the National Interconnected System (NIS) is determined based on the NCRE Reference Tariff. This tariff is set annually by MOPC through resolution, based on a technical report that ANDE must submit before March 31 of each year, detailing its generation costs by time block and voltage level.
The NCRE Reference Tariff is differentiated by time of day (Peak and Off-Peak) and by the type of energy injected:
Interruptible Energy — energy whose supply cannot be permanently guaranteed and whose dispatch is not firm: remuneration equals ANDE's Average Generation Cost (AGC). The advantage for the licensee is that it bears no obligation to guarantee a minimum supply. The limitation is that the price received is only the AGC, with no additional capacity or ancillary service components.
Non-Interruptible Energy — energy that is firmly and permanently assured: remuneration considers the AGC plus firm capacity, ancillary services, and, potentially, the injection point location. The price is potentially higher, but requires the licensee to guarantee supply firmness, which may require storage systems or other backup sources.
As of the date of publication, the AGC has not yet been determined, nor has the methodology for its calculation — including whether ANDE's own hydroelectric generation will be included or excluded — been established by MOPC. This is a pending definition of high relevance for the economic viability of Self-Generation and Co-Generation projects.
NCRE Generators – Tender Process
Tender, Reference Price, and Contracting Modalities
Unlike NCRE Self-Generators and Co-Generators, NCRE Generators sell their energy to ANDE (when not selling to Large Consumers) through competitive international public tender processes. The Decree regulates three central aspects of this process:
Reference Price. The Decree establishes that MOPC will determine the methodology for calculating the Reference Price applicable to Generator tenders, based on a prior technical report from ANDE. This price considers the specific characteristics of each NCRE source, storage systems, the geographic location of the connection point to the NIS, and the voltage level. The Reference Price published in each call for tenders will constitute, as is common in all competitive processes, the maximum award value — i.e., it operates as a ceiling for bids, not as a fixed price — thereby preserving the competitive incentive and allowing the effective price to be lower depending on the bids received. As of the date of this publication, the methodology for calculating the Reference Price has not yet been established by MOPC.
Contracting modalities. Bidding documents and contracts may include three energy acquisition modalities:
Open Modality: ANDE undertakes to purchase a minimum quantity and may require up to a maximum quantity defined in the bidding documents.
Defined Quantity Modality: ANDE acquires a fixed and unique quantity of energy.
Modality for Interruptible Sources: The NCRE Generator is not obligated to supply a minimum quantity, and ANDE undertakes to purchase all the energy that the NCRE Generator is able to produce. This modality is best suited for variable generation sources such as solar or wind.
In all cases, ANDE must have budgetary authorization to cover the maximum quantity of energy to be acquired.
Tender procedures may also include electrical energy storage systems or be called solely for storage. Tenders will be governed by Law No. 7021/2022 on Public Supply and Procurement, with the exceptions set forth in the NCRE Law.
Incorporation of the Special Purpose Vehicle (SPV)
The successful bidder (NCRE Generator) in an NCRE tender must incorporate a Special Purpose Corporation (Sociedad Anónima de Objeto Específico – SOE) in Paraguay within 60 business days from the date the award resolution becomes final. The SPV will be the contracting party in the NCRE Connection and Supply Agreement. The awardee must maintain a majority shareholding in the SPV, with a minimum of 51%, which the bidding documents may increase.
In the case of a consortium award, the SPV must be incorporated with the same partners and in the same proportions as the consortium at the time of the award. Prior to contract execution, the SPV must be registered with the DNCP State Suppliers Registry.
Public Tender Award – Guarantees
The Decree establishes three mandatory guarantees applicable to the Generator:
Bid maintenance guarantee: between 0.5% and 5% of the estimated total project cost.
Performance bond – construction phase: required prior to contract execution; amount and term to be defined in the bidding documents, with a maximum of 5% of the total awarded amount.
Performance bond – operation and maintenance phase: required prior to commencement of supply; maximum of 5% of the total awarded amount, decreasing in proportion to annual contract execution.
All guarantees may be provided by deposit, bank guarantee, surety bond, standby letter of credit, or insurance policy, issued by entities authorized by the Central Bank of Paraguay and the Superintendency of Insurance.
NCRE Administration and Payment Trust
The Decree establishes the complete operational framework for the NCRE Supply Administration and Payment Trust, with the MEF as settlor and the AFD as trustee. The trust is declared a matter of public utility and priority.
ANDE must fund it at least 12 months in advance of each scheduled payment. Its establishment is optional and conditioned on whether the call for tenders provides for it: if the bidding documents do not include it, the applicable payment regime is that of Law No. 7021/2022. The trust's obligations may be partially guaranteed by multilateral credit agencies, at the Generator's cost.
Assignment of Rights and Arbitration
The Connection and Supply Agreement and the SPV's shares may be assigned to third parties once supply has commenced, provided the assignee demonstrates technical and financial capacity, obtains the corresponding NCRE License, and receives prior authorization from ANDE.
The Decree provides for the possibility of agreeing to institutional or ad hoc arbitration for the resolution of contractual disputes, seated in Asunción, although the parties may agree on a foreign seat when the scale of the project or other relevant factors so justify. ANDE will be a necessary party in the arbitral proceedings, and the Attorney General's Office (Procuraduría General de la República) will intervene as an accessory party. ad hoc para la solución de controversias contractuales, con sede en Asunción, aunque las partes pueden consensuar una sede en el extranjero cuando la envergadura del proyecto u otros factores relevantes lo justifiquen. La ANDE será parte necesaria en el proceso arbitral y la Procuraduría General de la República intervendrá como coadyuvante.
Overall Assessment
The promulgation of Decree 6034/2026 is a significant milestone for the sector: for the first time, Paraguay has a complete operational framework for private participation in non-conventional renewable energy generation. The framework is more robust and bankable than the previous regime — terms of up to 30 years, payment trust, arbitration, Large Consumer provisions — and addresses several of the limitations that had constrained market development under Law No. 6977/2023.
However, the full functioning of the regime depends on the issuance of additional regulatory instruments still pending: the AGC methodology and the NCRE Reference Tariff for Self- and Co-Generators; the Reference Price methodology for Generators; the NIS connection guidelines; and the resolution defining which sources qualify as interruptible or non-interruptible. The speed with which MOPC and the Vice Ministry of Mines and Energy issue these instruments will be decisive for the market to begin operating at the scale the country needs.
Infrastructure | Rehabilitation and Maintenance of Road Sections: Cruce Primavera – Concepción and Access Roads
General Overview
On May 22, 2026, the Ministry of Public Works and Communications (MOPC), through the DNCP, published International Public Tender 488092 (MOPC Call No. 07/2026) (the "Call") for the rehabilitation and maintenance by service levels of the following road sections: Cruce Primavera (PY22) – San Ramón (14.56 km), San Ramón – Concepción (PY22) (13.10 km), access to the Paracel Plant (3.99 km), and Santa Rosa access – Route PY05 (4.68 km), with a total length of 36.33 km (the "Project"). The Call was issued as a single lot.
Key Features
Project Value and Financing The Project has an estimated value of Gs. 269,224,597,643 (approximately USD 44,000,000) and will be financed with funds from the joint CAF/OFID loan approved by Law No. 7517/2025. The Call was issued ad referendum, with MOPC in the process of obtaining the corresponding budgetary extension.
Execution Period
The contract execution period is 84 calendar months from the notice to proceed, with an initial 4-month period for the elaboration of the executive design, followed by 20 months for construction from the physical notice to proceed, and 60 months for maintenance services.
Advance Payment 10% of the contract.
Bid Maintenance Guarantee Bidders must submit a bid maintenance guarantee (bank guarantee or insurance policy) equivalent to 5% of the total bid amount.
Award System Bid evaluation will be based solely on price.
Subcontracting The permitted subcontracting percentage is 20% of the total contract amount.
Contracting Authority MOPC.
Key Dates June 23, 2026 — deadline for submission of queries; June 29, 2026 at 9:00 a.m. — deadline for submission of bids. Bid opening will take place the same day at 9:30 a.m. at the Main Hall of the MOPC Central Building.
Infrastructure | Rehabilitation and Maintenance of Road Sections: Concepción – Vallemí – San Lázaro
General Overview
On May 22, 2026, the Ministry of Public Works and Communications (MOPC), through the DNCP, published International Public Tender 488061 (MOPC Call No. 06/2026) (the "Call") for the rehabilitation and maintenance by service levels of the Concepción – Vallemí – San Lázaro section, with a total length of 181.3 km (the "Project"). The Project is divided into 3 lots as follows:
Lot 1: Km 0+000 to Km 52+300 (52.3 km)
Lot 2: Km 52+300 to Km 113+000 (60.7 km)
Lot 3: Km 113+000 to Km 181+300 (68.3 km)
Each bidder may be awarded only one lot; if the same bidder submits the lowest price for more than one lot, the award will be made for the lot where the price combination is most advantageous to the State.
Key Features
Project Value and Financing The Project has an estimated value of Gs. 819,864,270,021 (approximately USD 134,000,000), distributed as approximately USD 40,000,000 for Lot 1, USD 47,000,000 for Lot 2, and USD 47,000,000 for Lot 3. The Project will be financed with funds from the CAF/OFID loan approved by Law No. 7517/2025, and the call was issued ad referendum.
Execution Period The contract execution period is 84 calendar months from the notice to proceed, with an initial 4-month period for the elaboration of the executive design, followed by 20 months for construction from the physical notice to proceed, and 60 months for maintenance services.
Advance Payment 10% of the contract.
Bid Maintenance Guarantee Bidders must submit a bid maintenance guarantee (bank guarantee or insurance policy) equivalent to 5% of the total bid amount.
Award System Bid evaluation will be based solely on price.
Subcontracting The permitted subcontracting percentage is 20% of the total contract amount.
Contracting Authority MOPC.
Key Dates June 22, 2026 — deadline for submission of queries; June 26, 2026 at 9:00 a.m. — deadline for submission of bids. Bid opening will take place the same day at 9:30 a.m. at the Main Hall of the MOPC Central Building.
Mobility | Chamber of Deputies Passes "Suburban Rail" Bill
On May 26, 2026, the Chamber of Deputies approved the Senate version of the bill "Amending and expanding Law No. 7434/2025 – On the Suburban Rail Reform – and establishing special provisions for the implementation of the project through Government-to-Government (G2G) agreements" (the "Bill"). With this approval, the Bill has been passed and is now submitted to the Executive Branch for promulgation.
Below are some of the most relevant provisions of the Bill:
Direct Award under G2G Regime: The Ministry of Public Works and Communications (MOPC) and Ferrocarriles del Paraguay S.A. (FEPASA) are authorized to directly negotiate, execute, implement, and supervise agreements with foreign governments — or companies or entities designated by them — for the implementation of the Project. This empowers the authorities to select the sub-concessionaire without a competitive tender process.
State Financial Backing: The Ministry of Economy and Finance (MEF) must record as commitments of the Paraguayan State all financial obligations arising from the Project's contracts, including commitments for deferred investment payments, availability payments, and early termination amounts — which shall be recorded as firm and contingent obligations, as applicable. The MEF must also issue a prior approval opinion on the Project Implementation Agreement.
Dispute Resolution: In agreements executed under the G2G modality, the parties may expressly agree to submit to a specific jurisdiction in the Project Implementation Agreement, designating in each case the applicable law and the jurisdiction chosen. Additionally, the parties may agree to submit their disputes to arbitration, with the seat located within or outside Paraguay.
Special Purpose Vehicle: For the implementation of the Project, a Special Purpose Corporation (Sociedad de Objeto Específico – SOE) governed by Paraguayan law must be incorporated, whose exclusive purpose will be determined by the Sub-concession Agreement, the Project Implementation Agreement, and the Project documents. Under the G2G scheme, any public or private company designated by the allied foreign government may be selected as the majority shareholder of the SPV, subject to approval by MOPC and FEPASA. The minimum duration of the SPV will be the contract term plus two additional years, plus the validity period of the works and services guarantees.
Fiscal Incentives: The "Suburban Rail" Project will benefit from the incentives established in Law No. 7548/25 "Establishing the New Fiscal Incentives Regime for National and Foreign Investment," Law No. 117/91 "On Investments," and Law No. 5542/15 "On Guarantees for Investment and Promotion of Employment Generation and Socio-Economic Development," applicable to all phases of the Project, including design, construction, and operation.
FEPASA Participation and Capitalization: FEPASA is authorized to participate as a majority shareholder of the SPV and to allocate the resources it receives — whether from budgetary appropriations, capital contributions, financing, or other legitimate sources — to the capitalization of the SPV.
Budgetary Provision and Trust: MOPC, FEPASA, and the MEF undertake to provide for and manage the allocation of resources necessary to meet the State's financial obligations under the Project. They must also take the necessary measures to ensure the timely funding of the Project's trust, at least twelve months in advance of scheduled payments.
Guarantee for Creditors: The SPV may establish, in favor of its creditors, a special guarantee consisting of a pledge or security trust over the rights arising from the Project Implementation Agreement, including the future cash flows generated by the Project, and the shares representing the SPV's share capital.
Approval of the UAE Agreement: The agreement executed between MOPC, FEPASA, the Ministry of Industry and Commerce (MIC), and Etihad Rail PJSC of the Government of the United Arab Emirates is hereby approved and incorporated as an annex, forming an integral part of the law upon promulgation.
El Poder Ejecutivo dispuso el reajuste de los sueldos y jornales mínimos de los trabajadores del sector privado mediante el Decreto N° 6225/2026 (el “Decreto”), estableciendo un incremento del 5% respecto de los valores vigentes.
La medida fue adoptada sobre la base de las recomendaciones elevadas por el Consejo Nacional de Salarios Mínimos (CONASAM), considerando la variación interanual del Índice de Precios al Consumidor (IPC), su impacto en la economía nacional y la necesidad de preservar el poder adquisitivo de los trabajadores.
El Decreto establece lo siguiente:
Nuevo salario mínimo para actividades diversas no especificadas:
A partir del 1 de julio de 2026, el salario mínimo legal para actividades diversas no especificadas queda fijado en:
Salario mensual: Gs. 3.044.000 (guaraníes tres millones cuarenta y cuatro mil)
Jornal mínimo diario: Gs. 117.077 (guaraníes ciento diecisiete mil setenta y siete)
Estos montos reemplazan a los valores vigentes hasta el 30 de junio de 2026.
Salario mínimo para actividades específicas:
El Decreto autoriza al Ministerio de Trabajo, Empleo y Seguridad Social (MTESS) a reglamentar y publicar los nuevos salarios mínimos correspondientes a las actividades expresamente previstas y escalafonadas, aplicando el porcentaje de reajuste establecido.
Fecha de entrada en vigencia:
El reajuste salarial entrará en vigencia el 1 de julio de 2026, fecha a partir de la cual los empleadores deberán adecuar las remuneraciones de aquellos trabajadores cuyos salarios se encuentren vinculados al salario mínimo legal.
This content is for general informational purposes only and should not be considered as specific legal advice. If you require specific legal counsel, please do not hesitate to contact us.
It is hereby established that it is mandatory to provide information to the DNIT regarding transactions conducted with cryptoassets.
General Resolution No. 48/2026
March 23, 2026
Due to system failures in Marangatú, the filing deadlines for final and informational tax returns have been extended on an exceptional basis.
General Resolution No. 49/2026
March 24, 2026
Provisions are established for the disclosure of information on earnings, reserves, and distributable earnings in the Notes to the Financial Statements of obligated taxpayers (Obligation 948).
► General Resolution No. 47/2026 – Obligation to report transactions involving cryptoassets.
The National Tax Revenue Directorate (“DNIT”) issued General Resolution No. 47/2026, dated March 10, 2026, establishing for the first time in Paraguay the formal obligation to provide information on transactions involving cryptoassets. The measure does not create a new tax, but rather an information reporting obligation aimed at strengthening transparency and tax oversight in a sector of growing economic importance.
The regulation broadly defines the concept of a cryptoasset, encompassing any digital representation of value based on distributed ledger technology (“blockchain”), including value tokens, utility tokens, stablecoins, and NFTs, among others. Digital currencies issued by central banks (“CBDCs”) and financial instruments regulated by securities market laws are excluded.
The following are required to file the Informative Affidavit on Cryptoassets (“DJI – Cryptoassets”): (a) the owners, administrators, or managers of cryptoasset platforms operating in the country; and (b) individuals, legal entities, and other entities resident or incorporated in the country that trade in cryptoassets, when the annual transaction amount exceeds USD 5,000, whether through non-resident platforms or without the intermediation of any platform.
The minimum required information includes, for each transaction: date and time, identification of the parties involved—or wallet addresses—type of cryptoasset, amount traded, gross value in dollars, fees, and the transaction hash. The filing must be made annually through the Marangatú System, within three months following the close of the fiscal year. The first filing will correspond to the 2026 fiscal year and must be submitted in March 2027 for taxpayers with a fiscal year-end of December 31.
Reportable entities must include Obligation 959 – DJI Cryptoassets in their RUC. Late filing will be penalized with a fine of ₲ 1,000,000 for non-compliance. It should be noted that the resolution is not retroactive.
If you would like to learn more, we have prepared a more detailed article, which you can find here.
► General Resolution No. 48/2026 – Exceptional extension of deadlines due to system failures at Marangatú.
On March 23, 2026, the Marangatú system experienced significant outages due to cuts in the fiber-optic network, which affected connectivity at the DNIT data center. The outage coincided with a day of high tax volume, with multiple filing deadlines scheduled for that day.
In response to this situation, the DNIT issued General Resolution No. 48/2026, which exceptionally extended the filing deadlines for final and informational tax returns from March 23 to March 24, 2026, in order to avoid harm to taxpayers who were unable to complete their filings on time.
According to Internal Revenue General Manager Éver Otazú, the system did not go down completely, but it did experience slowness and intermittent outages. Cuts were detected at two points in the fiber-optic network, allegedly linked to acts of vandalism, which were repaired during the day. This is not the first time the DNIT has faced this type of issue, as thefts of fiber-optic cables have also been reported on previous occasions.
► DNIT General Resolution No. 49/2026 – New requirements for disclosing information on profits, reserves, and distributable earnings in financial statements.
Through General Resolution No. 49/2026, issued on March 24, 2026, the DNIT ruled that Corporate Income Tax (“IRE”) taxpayers required to file financial statements under Obligation 948 must include in the Notes to the Financial Statements detailed information on the composition and allocation of retained earnings and accumulated results.
The measure applies to financial statements for periods ending on or after December 31, 2025, and aims to strengthen control mechanisms and transparency in the accounting information submitted to the tax authorities. Specifically, the Notes to the Financial Statements must contain, at a minimum: (a) a reconciliation of retained earnings (net income for the year, prior-period results, and adjustments); (b) an identification of distributable earnings; and (c) a breakdown of the allocation of earnings, including dividends distributed, capitalized earnings, established reserves, and amounts pending distribution.
If you would like to learn more, we have prepared a more detailed article, which you can find here.
Through Resolution No. 2, Minutes No. 12 dated March 12, 2026, the Central Bank of Paraguay (the “BCP”) approved the new General Regulation of Paraguay’s Payment Systems (SIPAP), introducing a comprehensive update to the regulatory framework applicable to payment systems in the country, in line with Law No. 7503/2025 on the National Payment System (the “Regulation”).
From a structural standpoint, the Regulation organizes the operation of SIPAP into four main components: (i) general rules; (ii) the regime applicable to the Central Securities Depository (DEPO); (iii) specific provisions for the Real-Time Gross Settlement System (RTGS), the Automated Clearing House (ACH), and the Instant Payment System (IPS); and (iv) the operational rules of the Instant Payment System (IPS).
One of the most relevant aspects of the update is the expansion of the scope of participants. The Regulation expressly includes capital markets entities and payment service providers, including those that initiate payments.
In addition, new tools are incorporated, such as the QR Hub and digital savings deposit certificates (CDA-d), which are part of the initiatives promoted by the BCP to modernize the financial infrastructure.
The new regulatory framework also strengthens participants’ obligations, particularly in relation to information security, risk management, business continuity, and fraud prevention. In this regard, entities are required not only to comply with more demanding technical and operational standards, but also to ensure the availability and efficiency of the payment services offered to users.
Through Resolution SS.SG. No. 031/2026 dated January 30, 2026 (the “Resolution”), subsequently expanded by Resolution SS.SG. No. 117/2026 dated March 23, 2026, the Superintendence of Insurance (the “SIS”) approved an update to the registration and license renewal regime for insurance intermediaries and loss adjusters, introducing relevant changes to the requirements, timelines, and conditions applicable to the performance of such activities in Paraguay.
Under the new regime, applications for registration and renewal must be submitted in accordance with the deadlines, periods, and conditions established by the SIS through its institutional web platform.
For this purpose, registration will be opened once per calendar year, subject to limited quotas defined in each call, while renewals may be opened four times per year. The opening periods will be communicated by Circular, and the authority will have up to sixty (60) calendar days from the closing of each period to decide on the approval or rejection of the applications.
All information and documentation submitted in connection with registration or renewal processes must be filed exclusively through the institutional platform and will be deemed to have the status of an affidavit, with the applicant being responsible for its truthfulness, accuracy, and completeness.
In addition, licenses will be valid for up to three (3) years, except in the case of first-time registration, where the SIS may establish a different term to align expiration dates with the renewal schedule.
As a new development, applicants are required to disclose, under affidavit and through the institutional platform, all digital profiles used for commercial purposes (including social media accounts, websites, or other digital channels), providing the corresponding links and confirming that no other profiles related to the regulated activity exist. Such profiles must be publicly accessible to allow monitoring by the authority, and any false, incomplete, or inaccurate information may result in the rejection of the application, without prejudice to applicable sanctions.
Additionally, through Resolution SS.SG. No. 117/2026, the SIS introduced transitional measures to facilitate the implementation of the new regime during the 2026–2027 period. Certain requirements are temporarily relaxed, allowing the submission of either surety bonds or professional liability insurance policies for agents and brokers, and deferring the requirement for valid licenses for signatories acting on behalf of legal entities until January 1, 2028.
Finally, the regulation provides that granted licenses may lapse one year after issuance if the agent, broker, or loss adjuster does not carry out activities related to the authorized business within that period, unless a duly justified reason is provided and accepted by the SIS.
