Supreme Decree No. 5690 creates a registry while acknowledging, in the same text, that it is not yet operational. Its four articles establish the National Registry of Real Estate Service Providers—RENAPSI—identify who must appear in it and require its contents to be public and free of charge. They do not define what constitutes a real estate service, when a provider must register, which documents will be required or what follows from a failure to register. Those matters are left to a Ministerial Resolution that the Ministry of Sustainable Production, Environment and Water must approve within 30 business days of publication.
That distinction marks the limit of what can presently be said about the measure. Supreme Decree No. 5690 does not yet regulate real estate activity; it makes its providers identifiable. Its practical value will depend on rules that have not yet been issued and that, under the decree’s final provision, must be implemented without additional resources from the National Treasury.
What the decree does resolve
Article 2 covers companies providing real estate services nationwide as well as individuals who carry out such activities independently without being incorporated as companies. The second category is especially significant: companies already appear in the commercial registry, while many informal intermediaries operate outside that framework.
Supreme Decree No. 5690 does not yet regulate real estate activity; it makes its providers identifiable.
Article 3 contains the decree’s principal operational safeguard. RENAPSI information must be available through official digital platforms with public and free access. A registry that prospective clients cannot consult before committing to a transaction would offer limited protection; the decree avoids that basic flaw.
Article 4 preserves the administrative complaint channels available under Law No. 453 of 4 December 2013, the General Law on the Rights of Users and Consumers. The practical consequences of non-compliance will nevertheless depend on the specific administrative and sanctioning rules applicable to each case.
What remains to be defined
The regulations must translate this general framework into enforceable obligations. Among other matters, they will need to specify the real estate services within scope, registration deadlines and requirements, supporting documentation, procedures for updating or cancelling an entry, and the administrative consequences of non-compliance.
They must also determine how the platform will be implemented and administered, which authority will verify the information submitted and how RENAPSI will interact with the commercial registry and the existing consumer-protection system.
Practical implications
- Companies and independent providers should begin identifying which of their activities may fall within the registry and organise their corporate, commercial and contractual documentation.
- Users should understand RENAPSI as an identification and transparency tool, not as a substitute for reviewing title, authority, contracts or the legal due diligence required for a transaction.
- Concrete compliance obligations can only be assessed once the Ministerial Resolution is issued and the registry becomes operational.
Supreme Decree No. 5690 creates RENAPSI’s legal framework. Its capacity to improve transparency and protection will depend on the quality of the regulations, an accessible technical implementation and clear rules for providers and users.
