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Last updated: 9 September 2026
A Costa Rica VASP can prepare six evidence groups now: corporate records, ownership and UBO details, key-person files, a business and flow note, AML/CFT/CPF controls, and operating or tech proof. This is a readiness pack, not an official SUGEF list. Law No. 10961 was published on 19 June 2026 and is due to take effect on 19 September 2026. By 9 September, the official sources reviewed showed no final VASP form or filing guide. Build a live matrix now, then verify all filing rules before you submit it.
Legal status on 9 September 2026: Law No. 10961 has been published but is not yet in force. Article 15 quater creates SUGEF registration and expressly states that registration is not authorisation to operate. Read the wider context in crypto regulation in Costa Rica after Law 10961.
Quick Answer: What Documents Should a Costa Rica VASP Prepare?
| Evidence group | Typical contents | Primary owner | Preparation approach |
| Corporate existence and authority | Constitutive records, registered name and address, directors and signatories | Legal or corporate | Compile current records |
| Ownership and UBO | Ownership register, UBO declaration and group chart | Legal and founders | Map current ownership |
| Relevant people | Identity, appointment, authority and role evidence | Legal and compliance | Compile current role evidence |
| Business model and flows | Services, customers, jurisdictions, custody and crypto or fiat flows | Operations and product | Document the operating model |
| AML/CFT/CPF controls | Risk assessment, policies, control owners and operating evidence | MLRO or compliance | Document controls and evidence |
| Technology and operations | Architecture, wallet controls, monitoring, vendors and continuity | Technology and operations | Match evidence to the operating model |
The table is not a submission checklist. The application form, annexes, channel and formalities must be confirmed against current SUGEF requirements before filing. Registration is not a licence and does not replace another regulatory or financial approval. For help organising the file, see Costa Rica VASP registration support.
Before Compiling the File: Confirm Scope, Entity and Filing Route
Answer five questions first.
- Does the activity fall within Article 15 quater?
- Which entity will apply?
- What is its Costa Rica nexus?
- Which group company performs each service?
- Does another financial superintendency also have jurisdiction?
Record one applicant name and one document owner. This prevents evidence from being mixed across entities or prepared for the wrong business model. A step-by-step filing overview is available in how to register a VASP with SUGEF.
Corporate, Ownership and UBO Documents
Connect the company’s legal existence to the people who own and control it. A practical readiness set may include constitutive records, registered name and registered address, directors, signatories, shareholder or participant registers, a UBO declaration and a group chart. Log the source, version, issue date, owner and change trigger.
Do not assume that good standing, tax clearance or a company formation record belongs in the filing. Include it only with a current official basis. Reconcile ownership percentages and control paths across the chart, register and UBO statement. More detail appears in how to prepare Costa Rica VASP corporate documents.
Directors, Representatives, Participants and Background Information
Create a schedule covering each person’s identity, role, authority, ownership or control link, evidence source and any required background declarations. Article 15 quater directs SUGEF to set measures for checking participants, associates and UBOs. It does not define the required certificate, issuer, validity or notarisation. Restrict sensitive files and assign privacy responsibility. Confirm the declarations and certificates against current SUGEF requirements before filing.
Business Model and Transaction-Flow Evidence
Write an operating memo stating the services involving virtual assets, customer types, countries served and relevant Article 15 quater activities. Map cryptocurrency and fiat flows, wallets, banks and bank accounts, custody or control, settlement, counterparties and outsourced steps. Use transaction types and volumes only when supported by plans or operating history.
The memo, contracts, product description and flow map must align. A crypto exchange, crypto payments provider and business supporting a virtual asset issuance need different evidence. Reconcile the model with the risk assessment and technology controls.
AML/CFT/CPF Risk and Control Documents
Start with a current money-laundering, terrorist-financing and proliferation-financing risk assessment. Map each risk to a control, owner, approval, review cycle and operating record. Cover applicable statutory themes:
- customer and UBO checks
- records
- politically exposed persons
- sanctions and freezing
- virtual asset transfers
- new technology
- third parties
- foreign branches
- high-risk countries
- suspicious transaction reports
- confidentiality.
Link each control to available proof such as approvals, review logs, screening outputs, case handling or training records. The law leaves thresholds and certain detailed measures to CONASSIF. Confirm the applicable requirements against the current official instrument before filing.
Technology, Custody, Outsourcing and Operational Evidence
Show how controls work in the operating model. Depending on the services, evidence can include architecture, access management, wallet and key governance, custody, monitoring, retention, incidents, vendors, outsourcing, continuity and reconciliation. Mark each artifact with its owner and last test or review. These are model-specific readiness materials, not a universal checklist created by Law No. 10961.
Foreign Documents, Translations, Signatures and Apostilles
No VASP-specific rule was identified for language, certified translation, apostille or legalisation, notarisation, original or copy, signature type, authorised signatory or certificate age. Confirm each point against current official requirements before filing and record its source and check date. Do not borrow requirements from another Costa Rica process or country.
Filing Forms, Declarations and the Document Update Matrix
By 9 September 2026, the official sources reviewed showed no final VASP form, annex list, public channel, fee or review period. Confirm them before submission. Track each document’s owner, issuer or source, version and date, status, validity, submission reference and update trigger.
Review and update the register whenever ownership, UBOs, representatives, services, flows, outsourcing, risk or material controls change. Article 15 quater requires current registration information, while the notification form and deadline still need official confirmation.
Frequently Asked Questions
Is there an official Costa Rica VASP document checklist?
Not in the official sources reviewed by 9 September 2026. Law No. 10961 establishes registration and preventive duties, but it is not an exhaustive filing checklist. Use the six evidence groups to prepare, then confirm the final SUGEF form, annexes, channel and formalities against current primary sources before submission.
Which corporate and UBO documents should be prepared first?
Start with constitutive records, current entity details, director and signatory authority, the ownership register, a UBO statement and a group chart. Reconcile names, percentages and control links across them. Treat good-standing, tax or similar certificates as conditional until an official VASP requirement confirms that they belong in the file.
Are translations, apostilles or notarised copies required?
No confirmed VASP-specific rule was identified for these formalities. The official sources reviewed did not specify language, translation, apostille, legalisation, notarisation, copy, signature or certificate-age requirements. Check each point against the current SUGEF or CONASSIF instrument and record the source and review date rather than importing another procedure’s rules.
Are AML policies submitted with the registration file?
The final submission set has not been officially confirmed in the sources reviewed. Compile the risk assessment, applicable AML/CFT/CPF policies, approvals, control ownership and operating evidence because Article 15 quater creates substantive preventive duties. Before submitting, confirm which documents must be uploaded, declared, retained or produced on request.
Does a VASP need bank, tax or accounting documents?
Possibly for business, banking or corporate accounting purposes, but no blanket VASP filing requirement for those records was identified in the official sources reviewed. Include bank, tax or accounting evidence only when the final rule, the application form or the applicant’s specific model supports it. Do not confuse provider onboarding with SUGEF registration.
Is VASP registration the same as a crypto licence?
No. Article 15 quater expressly says SUGEF registration does not represent authorisation to operate. The market phrase “VASP license” should not obscure that distinction. Registration also does not replace approvals that may apply when a service falls under another Costa Rican financial superintendency or a foreign jurisdiction.
Review Your Costa Rica VASP Document Pack
Gofaizen & Sherle can review document readiness, map evidence to owners and separate gaps that can be closed now from points needing official confirmation. Review your Costa Rica VASP document pack before the filing route opens. The review does not guarantee registration, timing or banking access.