October 2026
On August 5, 2026, Colombia’s Ministry of Finance issued Decree 1044 of 2026, which amends the rules for registering international investments with the Central Bank (Banco de la República). It is good news for subsidiaries and branches of foreign companies in Colombia, but it is not an amnesty.
What changed
Until now, changes in the investment holder, its purpose or the receiving company, as well as cancellations, had to be registered within six months. Late registration was an FX infraction that could trigger investigations and fines of up to 200% of the amount involved.
The new decree removes that deadline. These registrations can now be filed at any time, as long as the investment was actually made. According to the recitals cited by INCP, 90% of the FX infractions known to the Superintendence of Companies in 2025 were precisely late registrations.
Law firms such as Holland & Knight also note that the decree applies the principle of favorability, which may benefit ongoing proceedings over late filings.
What did not change
- The duty to register remains. The deadline is gone, not the obligation to register changes and cancellations.
- Tax obligations are unchanged. For example, the income tax return due on a change of ownership of a foreign investment. The tax authority (DIAN) may request proof of the Central Bank registration.
What to do before year-end
- Reconcile the registry with your books. Compare what is registered with the Central Bank against the capital and movements in your financial statements.
- Catch up on pending items. Shareholder changes, capital increases, reductions or group reorganizations that were never registered.
- Review open proceedings. If there is an investigation for late registration, assess with your adviser whether favorability applies.
- Document it for headquarters and the shareholders’ meeting. An up-to-date registry makes dividend payments, capital repatriation and an eventual liquidation easier.
How we help
As resident legal representatives for subsidiaries and branches of foreign companies, JyM Contadores keeps your company’s corporate, tax and FX compliance up to date, including investment registration, and reports directly to headquarters.
Want to know how this applies to your company? Get in touch and we will tell you what is worth reviewing in your case before year-end.
Sources: Decree 1044 of 2026 (Ministry of Finance); INCP (August 12, 2026); Holland & Knight (August 14, 2026). This article is for information only and is not advice on your specific case.
