February 2026 | Client Alert
On August 1, 2025, Act No. 102‑2025, the Ley de Reconocimiento Universal de Licencias Ocupacionales y Licencias Profesionales en Puerto Rico (the “Act”), was approved, establishing a framework for the recognition in Puerto Rico of occupational and professional licenses issued by other U.S. jurisdictions. The Act expressly calls for the adoption of implementing regulations by the Puerto Rico Department of Health.
Consistent with this legislative mandate, in December 2025 the Puerto Rico Department of Health published a proposed Regulation for the Universal Recognition of Occupational and Professional Licenses in Puerto Rico (the “Regulation”). The Regulation sets forth uniform procedures under which local boards and licensing entities would evaluate and recognize licenses and governmental certifications issued in other states and U.S. jurisdictions.
Pursuant to the administrative rulemaking process, the Department of Health held a virtual public hearing on January 8, 2026, to receive comments from interested parties regarding the proposed Regulation. Written comments were also invited following the publication of the notice.
If adopted in its current form, the Regulation would require local health boards to issue a license by endorsement to applicants who hold a valid out‑of‑state license with a substantially similar scope of practice, have maintained licensure for at least one (1) year, and demonstrate at least three (3) consecutive years of recent practice. Applicants must satisfy comparable training or examination standards, be in good standing, have no disqualifying criminal or disciplinary history, and submit a sworn application with supporting documentation and the applicable $100 administrative fee. Notably, the proposed Regulation would apply exclusively to professions and occupations regulated by boards, divisions, or licensing entities within the jurisdiction of the Puerto Rico Department of Health and would not extend to licensing authorities housed in other government agencies.
Local boards would be required to act on applications within thirty (30) days. If a board fails to issue a determination within that period, the applicant would automatically receive a provisional license or governmental certification permitting practice in Puerto Rico pending final review. The Regulation also authorizes boards to convene virtually and to adopt streamlined procedures to meet these statutory deadlines.
The proposed Regulation would further allow for recognition based on work experience when the originating jurisdiction does not require licensure, provided the occupation or profession is substantially similar and the applicant demonstrates at least three (3) years of continuous prior experience. Applicants who hold a governmental certification from another state would be entitled to the immediate issuance of a provisional license upon filing a complete application.
Under the proposed Regulation, applications may be denied for failure to meet the regulatory requirements, lack of good standing, pending complaints or investigations, qualifying criminal convictions involving dishonesty or moral turpitude, or the submission of false or misleading information. Licensees would also be required to report adverse licensure actions taken in other jurisdictions.
During declared emergencies, the proposed Regulation would authorize the Secretary of Health to provisionally recognize out‑of‑state or foreign licenses, and the Governor may temporarily expand scopes of practice or authorize the provision of services through remote means. Applicants whose licenses or certifications are denied or revoked would retain the right to seek administrative reconsideration under applicable Department of Health procedures.
We continue to monitor developments regarding the final version and implementation of this Regulation.
For any questions regarding this matter, please contact any of the attorneys in our Health Law Practice Group or your primary O’Neill & Borges attorney.
Authors: Natalia P. Vilá Palacios & José J. Colón García
This O’Neill & Borges Client Alert is prepared for general information purposes only. It does not constitute legal advice or a legal opinion; nor does it establish an attorney-client relation with the recipient. For further information or to establish an attorney-client relation please contact us at info@oneillborges.com or your prime contact attorney at O&B.