Starting a business in Cuba

The real journey — from choosing a legal vehicle to constituting the company, getting permits, importing, and understanding the US-embargo dimension. This explains the process and points to official sources. CubaAtlas does not broker, sell, or advise. This is not legal advice.

Reviewed weekly against the primary sources. Last reviewed 2026-07-26. For changes as they break, see the legal & sanctions watch on Cuba Now.

1 · Forms of business

The vehicle decides everything downstream — who can own it, how it’s taxed, and how it imports.

2 · The step-by-step journey

Timelines below are legal ceilings, not observed reality — Cuban administrative processes routinely run longer, and the slowest points are noted.

A private MIPYME (Cuban-resident founders)

Everything runs through the MEP’s Plataforma de Actores Económicos (PAE).

1. 1

   Project & application (online)

   MEP · Plataforma de Actores Económicos (PAE)

   Founders' data, business plan (proyecto), statutes, any trademark cert, and a land-use opinion where required. The name is declared here. Reviewed by the municipal administration (CAM). Legal max ~30 business days — the biggest bottleneck.

2. 2

   Sight deposit account

   BANDEC / BPA / Banco Metropolitano

   Founders deposit the capital in CUP; the bank issues a deposit certificate. ~5 business days.

3. 3

   Notarial incorporation deed

   State notary (MINJUS)

   The escritura pública de constitución is signed before a state notary. Legal max ~30 business days — the second bottleneck (notary scheduling).

4. 4

   Registro Mercantil inscription

   MINJUS

   The inscription certificate confers legal personality on the company. ~15–30 business days.

5. 5

   Tax registration

   ONAT — Registro de Contribuyentes

   The company is entered in the taxpayer registry and assigned its NIT. ~5–10 business days.

6. 6

   Fiscal account & statistics

   Bank + ONEI

   Open the current/fiscal account and transfer capital; statistics registration with ONEI is automatic.

7. 7

   Sector & commercial licences

   MINCIN (RCC) + sector bodies

   Wholesale/retail/food-service register in the Registro Central Comercial (MINCIN); other sector and municipal licences as applicable.

A foreign-investment company (Law 118)

Channelled through MINCEX’s Ventanilla Única (VUINEX). The uncodified pre-submission phase is where most time is spent.

1. 1

   Negotiation & proposal

   Investor + Cuban partner / sponsoring organism

   Assemble the documentation (Decreto 325/2014). Recent reform removed the mandatory feasibility study as a filing prerequisite. This pre-submission phase has NO published deadline and is where most real time is spent — often 1–2+ years.

2. 2

   Submission to MINCEX

   MINCEX · VUINEX

   File through the Ventanilla Única de Inversión Extranjera.

3. 3

   Evaluation

   Comisión de Evaluación de Negocios

   The commission issues criteria — about 7 business days; roughly 7 more for the applicant to adjust if asked.

4. 4

   Authorization

   Consejo de Ministros / Consejo de Estado (or delegated minister)

   Final authorization by the top authority, or a delegated minister by size/sector. Legal max ~60 natural days.

5. 5

   Constitution & registration

   Notary → Registro Mercantil → ONAT → bank

   Notarial escritura de constitución, then Registro Mercantil (legal personality), tax registration, and a bank account (foreign-investment entities typically bank with BFI or another authorized foreign-currency bank).

3 · Permits & licences by area

4 · Imports & exports

Private actors (MIPYMES, CNA, TCP) cannot import or export directly. They must contract an authorized state trading enterprise (empresa importadora-exportadora / comercializadora) that holds the “facultad de importar/exportar” granted by MINCEX. The state keeps its foreign-trade monopoly.

• •Governing rule: Resolución 166/2024 (MINCEX) replaced the 2020 opening; it tightened rules (payment from Cuban bank accounts, declaration of fund origin, tax-compliance certificate).
• •Mechanism: the private firm and the state entity sign a contrato de comisión (one-off) or agencia/mandato (ongoing); the state entity acts on the firm's behalf, within its registered activity.
• •Cost: state intermediaries add a commercial margin (~3% of nominal value is cited by economists) plus duties/fees — verify against the MFP resolutions.
• •Customs (Aduana General de la República): a commercial Arancel de Aduanas for legal entities took effect 1 Jan 2022 on the Harmonized System; general ad valorem rate ~10% for most goods.
• •Much MIPYME “importing” is actually buying goods already in Cuba on consignment / in bonded warehouses; couriers and postal shipments are heavily used.
• •Personas naturales get repeatedly-extended MFP duty exemptions on non-commercial food, medicine and hygiene imports — each extension is a separate resolution with an end-date; check the current one.
• •The government has reaffirmed it will not license private import-export companies, allowing only limited discretionary exceptions. A 2024 wave of licence revocations hit STATE enterprises, not private ones — a widely mis-reported point.

5 · The US embargo dimension

General information, not legal advice. This whole section is time-sensitive: US policy swings with each administration. Confirm every point at the live primary source before relying on it.

• •The embargo runs through the Cuban Assets Control Regulations (31 CFR Part 515), administered by OFAC. The default is prohibition: essentially all transactions involving Cuba by persons subject to US jurisdiction are barred unless authorized.
• •Travel is allowed only within 12 categories (31 CFR 515.560) — tourism remains illegal by statute. These authorize travel, not general trade or investment.
• •“Support for the Cuban People” (31 CFR 515.574) authorizes travel and transactions that strengthen the independent private sector (casas particulares, paladares, cuentapropistas) under strict conditions — it does not authorize funding the state/military economy.
• •The State Department's Cuba Restricted List bars direct dealings with military-linked entities, notably GAESA and its holdings (CIMEX, Gaviota…). A Cuba Prohibited Accommodations List names hotels US persons may not pay to lodge at.
• •Most direct US investment is barred: the CACR give no general license for equity investment or general trade, and the Helms-Burton Act (1996) codified the embargo and — via Title III — exposes those who “traffic” in property confiscated after 1959 to US lawsuits.
• •As of this writing Cuba remains a designated State Sponsor of Terrorism (a Jan-2025 move to rescind was reversed). Confirm current SSOT, Restricted-List and Title-III posture at the live pages.

6 · Professional services

Foreign-facing legal work is state-dominated. Verify any firm’s details at its official site before engaging.

7 · Official sources

Cuban government sites are frequently slow or intermittently offline — expect timeouts and retry.

Compiled from primary and official sources (Gaceta Oficial, MINCEX, MEP, MTSS, MFP, Aduana, US Treasury/State), regulatory picture as of 2026. Information only and not legal advice — CubaAtlas does not broker, sell, or represent any party. Verify against the live sources before acting.