What Are the Annual Requirements to Keep Act 60 Status in Puerto Rico?

Your decree is signed and the hard part feels over. Then a neighbor in Dorado asks whether you have filed your annual report yet, and you realize you have no idea what is due or when. Act 60 status has to be kept up every year. This guide covers each annual requirement, explains how the pieces connect, and gives you a calendar so the decree you worked hard for stays valid.

What Keeping Act 60 Status Actually Means Year After Year

When I received my own decree, I treated it like a diploma. I was wrong. Within a few months I learned that the decree works more like a membership. It stays active only while you keep meeting its conditions, and the government expects proof that you are doing so.

The Decree Is a Contract, Not a Gift

Your Act 60 decree is a legally binding agreement between you and the Government of Puerto Rico, administered by the Department of Economic Development and Commerce, known locally as DDEC. You receive tax benefits. In return, you commit to specific obligations. Read your own decree carefully, because the exact terms, deadlines and conditions are written into that document. Two people who moved in different years can hold decrees with different wording.

This matters because many annual obligations, including the annual report deadline, are “set in each decree.” Your neighbor’s deadline may not be yours. Keep a digital copy of your decree in a folder you can reach quickly, and reread it at least once a year. I do mine every January with coffee and a highlighter, and every time I find something I had half forgotten.

If you are still deciding whether to apply, or you want the full picture of how residency fits into the incentive, see The Complete Guide to Act 60 Residency Requirements in Puerto Rico (2027) before you go further.

Two Foundations: Bona Fide Residency and Decree Conditions

Your annual requirements fall into two groups:

• Federal residency rules. These decide whether you are a bona fide resident of Puerto Rico for US tax purposes. If you fail them, the federal tax advantages on your Puerto Rico-source income fall apart, whatever your decree says.
• Decree-specific conditions. These are set by Puerto Rico law and DDEC. They include the annual donation, the annual report, property ownership and filing your local tax return.

Both groups have to be satisfied every year. Being a bona fide resident is not enough if you skip the annual report, and filing a perfect report does not help if you spent too much of the year in Miami.

The Core Annual Requirements for Individual Resident Investors

This section focuses on Individual Resident Investors, the category most newcomers mean when they say “Act 60.” Business decree holders, such as export services companies, have their own operational conditions, which may include employment commitments. They should review those terms alongside everything below.

Staying a Bona Fide Resident Every Single Year

Bona fide residency rests on three tests: the presence test, the tax home test and the closer connection test. You have to pass all three for each tax year.

The presence test is the one people talk about most. The best-known way to pass it is to spend at least 183 days in Puerto Rico during the tax year, although other ways of meeting it exist. A day of presence generally means any part of a day spent physically on the island, but there are nuances and exceptions. Track them carefully. Do not count from memory in March of the following year. I keep a simple spreadsheet and save boarding passes, and many people use phone location history as backup. How to Document Your Days in Puerto Rico for the Presence Test walks through practical tracking systems.

The tax home test asks where your main place of business or employment is. If you work remotely, your tax home generally follows where you actually do the work. A laptop on a balcony in Condado is a much better position than flying back to a New York office every other week.

The closer connection test is the most subjective and the one I worry about most for friends. It asks whether your life is centered in Puerto Rico or somewhere else. Officials look at where your home, family, belongings, driver’s license, voter registration, bank accounts, doctors and social and religious ties are. Understanding What Counts as a Closer Connection to Puerto Rico covers this in depth. For the bigger picture, see Understanding the Three Residency Tests (Presence, Tax Home, Closer Connection).

A practical point about belongings: if most of your furniture, art and personal items are still in a storage unit in Texas, that weakens your closer connection story. When I finally shipped everything over, I compared international movers through Sirelo. Seeing several quotes side by side helped me pick a company that handled Caribbean shipments regularly. A fully furnished home on the island is part of your evidence.

The Annual Donation and How You Prove It

As of October 2026, Individual Resident Investors must make an annual donation of $10,000 to eligible nonprofit entities. Many decree holders get the rules for qualifying organizations wrong, and decrees issued at different times can have different requirements about which types of organizations qualify and how the donation must be split. Check your decree and DDEC’s current guidance before you write the check.

What trips people up most is how the donation is proven:

• Proof of the $10,000 donation is not filed separately.
• It must be included in your annual report, the Informe Anual de Negocio Exento, or IANE, submitted to DDEC.
• This starts with the second tax year of the decree.
• The deadline is the annual report deadline, which is the date set in your decree.

In practice, give yourself a comfortable buffer before the report is due. Make the donation, get a written acknowledgment from the nonprofit on its letterhead, keep the bank record showing the payment, and file all of it with your IANE materials. Understanding the Act 60 Annual Donation and Compliance Requirements has more detail on choosing qualifying organizations.

The Annual Report to DDEC

The IANE is the main compliance document for decree holders. Through it, you report to DDEC that you are meeting your decree conditions, including the donation proof described above. The report carries a filing fee set by law. Check DDEC’s current fee schedule each year instead of assuming last year’s amount still applies.

The due date depends on the law your decree was issued under. As of May 2026, the general rules were:

• Decrees issued under Act 22, the predecessor law later folded into Act 60: generally 30 days after the income tax return deadline, including extensions. For tax year 2025 without an extension, that was 15 May 2026.
• Decrees issued under Act 60: 15 November of the year following the tax year. For tax year 2025, that fell on 16 November 2026.

Your own decree controls. If your decree names a date, that is your date. For a broader look at how reporting and residency fit together, see Understanding the Act 60 Annual Reporting and Residency Compliance.

Filing Your Puerto Rico Income Tax Return

Every year you must file your Puerto Rico income tax return, called the planilla, with the Department of Treasury, known as Hacienda. This applies even if most of your income is exempt or taxed at a preferential rate under the decree. The return is how the government confirms you are reporting income correctly and claiming only the benefits you are entitled to.

The planilla deadline also affects the IANE deadline for Act 22 decree holders, since their report is generally due 30 days after the return deadline, including extensions. If you file an extension on your planilla, find out how it moves your IANE date under your specific decree. How to File Your Annual Income Tax Return (Planilla) in Puerto Rico explains the filing process step by step.

Owning Residential Property in Puerto Rico

Individual Resident Investors are generally required to buy residential property in Puerto Rico within a period set by law, and that property must serve as the principal residence. Once you buy, the ongoing requirement is to keep the qualifying property and actually live in it.

If you sell your home, plan the timing and your replacement purchase with your advisor before you sign anything. Owning a home here also helps your closer connection test. For the buying process itself, from title searches to closing, see How to Buy Property in Puerto Rico: The Full Guide (2027).

Annual Requirements at a Glance

Requirement	What It Involves	When	Where the Proof Goes
Bona fide residency	Pass the presence, tax home and closer connection tests	Every tax year	Your own records, plus tax filings as required
Annual donation	$10,000 to eligible nonprofit entities, as your decree specifies	Every year, starting with the second tax year of the decree	Included in the IANE to DDEC, not filed separately
Annual report, Act 22 decrees	IANE submitted to DDEC with donation proof and fee	Date set in decree; as of May 2026, generally 30 days after the income tax return deadline including extensions; 15 May 2026 for tax year 2025 without an extension	DDEC
Annual report, Act 60 decrees	IANE submitted to DDEC with donation proof and fee	Date set in decree; as of May 2026, 15 November of the following year; 16 November 2026 for tax year 2025	DDEC
Puerto Rico income tax return	File the planilla with Hacienda	Each year by the Hacienda deadline or extended deadline	Hacienda
Residential property	Own and live in a qualifying principal residence	Ongoing, after the purchase window in your decree	Deed and property records, kept on file

Building a Yearly Compliance Calendar That Actually Works

After a near miss in my second year, when I nearly mixed up which tax year a receipt belonged to, I built a routine. It has kept me calm ever since. Here is the sequence I recommend, which you should adapt to the dates in your decree:

1. January: Review your decree. Reread the conditions, confirm which law it was issued under, and write your IANE due date in your calendar with two reminders: one a couple of months before and one a few weeks before.
2. January through December: Track your days. Update your presence spreadsheet after every trip off the island. Save boarding passes and travel confirmations in a dedicated folder.
3. Early in the year: Plan your donation. Choose qualifying nonprofits, confirm they meet the requirements in your decree, and schedule the payment so you have time to collect acknowledgment letters.
4. Ahead of the Hacienda deadline: File your planilla. Work with your Puerto Rico CPA. If you extend, confirm how the extension affects your IANE date.
5. Ahead of your IANE deadline: Assemble the annual report. Gather the donation acknowledgments, bank proof, property records and anything else your decree requires.
6. By the date in your decree: Submit the IANE to DDEC and pay the filing fee. Save a copy of the submitted report and the confirmation.
7. Year-end: Do a closer connection check. Is your license from Puerto Rico? Are you registered to vote here? Are your doctors, banks and memberships local? Fix any gaps before the next year starts.

A Realistic Scenario: The Traveling Consultant

Consider Maria, a strategy consultant living in Guaynabo with an Act 60 decree. In one year she gets a large project that requires frequent trips to Chicago. By September her day count is closer to the line than she would like. Because she has tracked days monthly instead of guessing, she notices early and moves several client meetings to video calls. She finishes the year comfortably within the presence test.

Health coverage turned out to be part of her solution too. She travels often, so she carries international health insurance through Cigna Global alongside her local plan. She can see a doctor during a long work stretch on the mainland, while her primary care physician, dentist and specialists stay in San Juan, which keeps her medical life centered on the island for closer connection purposes. If you are sorting out coverage yourself, see Health Insurance in Puerto Rico: Plans, Costs and Options Explained (2026).

Maria then makes her donation in the spring, collects acknowledgment letters right away, and gives everything to her CPA in early autumn. Her decree was issued under Act 60, so her report is due 15 November of the following year. She files well ahead of that date. Nothing dramatic happens, and with compliance that is the outcome you want.

Common Pitfalls and How to Protect Your Decree

Not one of the annual obligations is hard by itself. The trouble comes from the combination of deadlines, documents and real life getting in the way.

Heavy Travel Years and Family Emergencies

Some years you cannot plan. A parent gets sick on the mainland, or a business opportunity requires months abroad. These are the years when compliance is at the most risk. Talk to your tax advisor as soon as you see a heavy travel year coming. Do not wait until December. The rules include some exceptions and nuances, but they need documentation and should be applied with professional guidance.

If your life is changing in a bigger way, such as a family member joining you on the island or you relocating part of your household, a mover comparison service like Sirelo can save you a lot of phone calls when shipping belongings between the mainland and San Juan. For a closer look at what happens when the day count goes wrong, see What Happens If I Spend Too Many Days Off-Island from Puerto Rico?.

Documentation Discipline and Professional Help

I tell every newcomer the same thing: assume you will one day need to prove everything. Keep these records for each tax year:

• Your day-count log and supporting travel records
• Donation acknowledgment letters and payment confirmations
• A copy of each submitted IANE and its confirmation
• Your filed planilla and any extension paperwork
• Your property deed and evidence that it is your principal residence
• Records supporting your closer connection, such as local licenses, voter registration, utility bills and medical records

Organize them by tax year, in both digital and physical form if you can. Remember that the donation proof for a given year goes into that year’s IANE. Keep each year’s packet separate so nothing gets assigned to the wrong year.

Finally, work with a Puerto Rico CPA and, when needed, an attorney who handles incentive decrees regularly. Requirements and fees change over time, and DDEC updates its guidance and filing systems. A good local professional will track those changes for you. They will also tell you about new obligations before they become a problem, which matters a great deal when your decree depends on getting the details right.

If you keep your decree in view, track your days honestly, make your donation early and file your IANE by the date your decree sets, Act 60 compliance becomes a routine part of island life.

Disclaimer

This article is for general informational purposes only and does not constitute professional advice. Laws, prices and regulations vary by location and change over time. Consult a qualified professional for guidance on your specific situation.