New Rules for E-Commerce and Digital Services in Costa Rica
Manrique Rojas, Senior Associate at ARIAS Costa Rica and expert in International Trade, presents this article on New Rules for E-Commerce and Digital Services in Costa Rica.
The way companies sell online, present their prices and promote their products will need to be adjusted to comply with new rules in Costa Rica. Merchants, platforms and other digital service providers will need to review their purchasing processes, terms and conditions, and advertising strategies to determine what changes are necessary.
On June 24, 2026, the Law on the Governance of Digital Services and E-Commerce, Law No. 10946, was published. The law establishes new obligations for companies that offer goods, services and content through electronic means, as well as for digital platforms and other intermediary service providers. It also regulates advertising and the information provided to consumers.
The law will enter into force on June 24, 2027. During this period, the Executive Branch must issue its implementing regulations, so it will be necessary to wait and review the provisions developed under them. Nevertheless, companies can begin reviewing their operations now to identify any adjustments that may be required.
The law is intended to regulate digital services and the exchange of goods, services and content through electronic means, including advertising and the information provided to consumers. Its objectives include the effective protection of consumers, the safeguarding of their rights in the digital environment and greater transparency for online platforms. Its scope covers individuals and legal entities, whether public or private, that provide these services or carry out e-commerce activities, as well as intermediary service providers.
Obligations for Online Sellers
The law regulates various aspects of the relationship with consumers, from the information presented before a purchase to the confirmation of the transaction and the advertising used to promote products or services.
The matters companies should review include the following:
i. Final price: Consumers must know the total cost of their purchase, including applicable charges, before confirming it.
ii. Transaction confirmation: Once the purchase is completed, consumers must receive a record containing the relevant information in a format they can retain. This process can be automated.
iii. Consumer reviews: If a company uses recommendation systems, it must provide a free and transparent mechanism to receive and publish both positive and negative reviews of the products or services purchased.
iv. Advertising and endorsements: Advertising must be identifiable as such, and endorsements must be truthful. In addition, any material connection that may affect the credibility of an endorsement must be disclosed.
These matters require particular attention, as the law classifies failure to comply with these obligations as a serious infringement.
Companies will also need to review their terms and conditions, product and service information, contracting processes and payment security measures. Although certain breaches in these areas are classified as minor, the law provides that the maximum penalty must be imposed when an infringement causes harm to health, safety or the environment that adversely affects consumers.
Digital Platforms and Intermediaries
Companies that operate online platforms or provide intermediary services will need to review additional obligations, depending on the nature of the services they offer.
Among other requirements, they must have mechanisms in place to receive notices regarding content and handle complaints, as well as respond promptly to orders issued by the competent authorities. They must also provide reasons for certain decisions related to content restrictions or account suspensions, where applicable.
Another relevant issue is the design of digital interfaces. The law penalizes practices that distort or limit users’ ability to make free and informed decisions. It also establishes transparency obligations relating to online advertising and recommendation systems.
Foreign Companies and Cross-Border Operations
The law may also apply to companies without a domicile or physical presence in Costa Rica when their digital services are consumed from within the country.
The law provides for certain exceptions applicable to foreign providers. For example, it exempts merchants established outside Costa Rica from the requirement to provide contract terms in Spanish. It also allows providers domiciled abroad to demonstrate compliance with payment security obligations through international certifications or standards.
In addition, electronic contracts entered into with consumers are deemed to have been concluded at the consumer’s domicile. This should be considered when reviewing contractual terms and their potential effects in the event of a dispute.
Advertising with Content Creators
Companies that work with content creators or brand ambassadors will also need to review how they manage these relationships.
The law requires clear and transparent disclosure of any material connection between a company and a person endorsing its products or services when that connection may affect the credibility consumers give to the endorsement.
This connection is not necessarily limited to monetary payments. It could also arise when a company provides free products or other benefits to a content creator.
In this regard, we recommend reviewing agreements with content creators and internal campaign guidelines to determine how these relationships will be disclosed and to ensure that the disclosure is visible to consumers.
How Can Companies Prepare?
As a first step, we recommend assessing the company’s digital operations to determine which obligations apply and what changes are necessary.
Based on that assessment, the company can prioritize the required adjustments, particularly those related to serious infringements, and begin reviewing its processes, contracts, terms and conditions, and digital policies. This work can move forward while the implementing regulations are issued and matters requiring further development are clarified.
At ARIAS, we can assist you in assessing your operations and preparing the adjustments needed for the law’s entry into force.