Cuba: technology regulation at a glance

Framework: Banco Central de Cuba (BCC) Resolution 215/2021 (amended 2024); Resolution 4/2026 (Gaceta Oficial Extraordinaria No. 46, March 23, 2026)

Cuba formally recognizes and regulates virtual assets under BCC Resolution 215/2021, effective September 15, 2021, which empowers the Central Bank to license VASPs and specify permissible tokens. All crypto activity by businesses requires prior BCC authorization evaluated on 'socioeconomic interest'; peer-to-peer use by individuals is not prohibited but carries civil and criminal risk if unlicensed intermediaries are used. The most recent instrument, Resolution 4/2026, selectively authorized nine private SMEs and one mixed-ownership company to use virtual assets for international payments through BCC-licensed intermediaries.

Framework: Strategy for the Development of Artificial Intelligence (Estrategia para el Desarrollo de la Inteligencia Artificial), adopted May 2024 by the Council of Ministers, led by the Ministry of Communications (MINCOM)

Cuba has no enacted AI-specific legislation; its primary AI instrument is a national strategic policy document approved by the Council of Ministers in May 2024 as part of the broader Digital Transformation Policy. The strategy sets six thematic axes, including an ethics and legal framework axis, but binding sectoral AI rules and a comprehensive AI law remain absent. The adjacent Law 149/2022 on Personal Data Protection (in force February 2023) is the closest statutory instrument with relevance to AI data governance.

Framework: Ley No. 149/2022 'De Protección de Datos Personales' (Law on the Protection of Personal Data), supervised by the Ministry of Communications

Cuba enacted its first comprehensive personal data protection law, Ley No. 149/2022, on 25 August 2022; it entered into force on 21 February 2023. The law is grounded in Articles 40, 48, and 97 of Cuba's 2019 Constitution, which enshrine human dignity and the right to personal and family privacy. It regulates the collection and processing of personal data by both public and private entities and establishes individual data rights and administrative penalties for non-compliance.

Framework: Banco Central de Cuba (BCC), Resolution 215/2021 (virtual asset service providers), Decree-Law 113/2025 (foreign currency transactions), Resolution 134/2025 (first VASP license); state-operated platforms Transfermóvil and EnZona under BCC oversight

Cuba's digital payments landscape is almost entirely state-controlled, with the Banco Central de Cuba acting as the sole financial regulator. A formal licensing regime exists for virtual asset service providers (established 2021-2022, first license issued 2025), while domestic electronic payments are channelled through two government-backed platforms, Transfermóvil and EnZona. There is no independent payment-institution or e-money framework, no open banking, and no BNPL regulation; Decree-Law 113/2025 adds foreign-currency transaction rules but does not open the market to private fintech operators.

Framework: Cuba's immigration system is governed by DIMEC (Dirección de Identificación, Migración, Extranjería y Ciudadanía) under the Ministry of Interior (MININT). The legislative framework is being overhauled by Laws 171 (Migration), 172 (Citizenship), and 173 (Foreigners), approved by the National Assembly on 19 July 2024, published in Official Gazette No. 39 of 5 May 2026, and entering into force approximately November 2026.

Cuba has no dedicated digital nomad or remote-work visa. Foreign nationals wishing to reside long-term may pursue temporary residence through employment with a Cuban entity, study, family reunification, or a 'financially independent' (non-lucrative) category that permits living on foreign-sourced income without local employment. The sweeping immigration reform enacted in Laws 171-173 (2024, entering force ~November 2026) restructures residency categories but does not introduce a remote-work or digital-nomad pathway; practical barriers including severely restricted internet access and a centrally-planned economy make Cuba one of the world's least hospitable environments for remote workers.

Framework: Decree Law 35 on Telecommunications/ICT (2021); Law 162/2023 on Social Communication (in force October 2024); Decree 370; ETECSA state monopoly on connectivity

Cuba operates a heavily state-controlled internet infrastructure where a single state-run provider (ETECSA) monopolises connectivity and is legally required to block users publishing content deemed contrary to socialist order or public morality. The 2021 Decree Law 35 and the 2024 Social Communication Law together criminalise online dissent, mandate content censorship without judicial oversight, and provide for government-accredited 'social communication inspectors' who monitor cyberspace. Freedom House rated Cuba 21/100 ('Not Free') in its Freedom on the Net 2025 report, one of the lowest scores globally.

Framework: Decreto 360/2019 (ICT Security and Defense of National Cyberspace); Decreto-Ley 35/2021 (Telecommunications, ICT and Radio-Electric Spectrum); Resolution 105/2021 (National Action Model for Cybersecurity Incident Response); overseen by MINCOM and OSRI (Oficina de Seguridad para las Redes Informáticas)

Cuba's cybersecurity regime is built on a state-centric, sector-focused architecture anchored in Decreto 360/2019 and Decreto-Ley 35/2021, which together regulate ICT security, national cyberspace defence, and critical infrastructure protection. The Ministry of Communications (MINCOM) and its subordinate Office of Computer Network Security (OSRI) serve as primary authorities, with mandatory incident-reporting obligations for legal persons. No comprehensive horizontal law comparable to NIS2 is in force; the framework prioritises national security and state information control alongside technical cybersecurity obligations.

Framework: Law 118 on Foreign Investment (2014); Decree-Law 46/2021 on MIPYMEs (private SMEs) as amended by Decree-Law 88/2024 and Decree 107/2024

Cuba maintains a heavily state-directed economy in which foreign investment is channelled through narrowly defined, government-approved modalities, primarily joint ventures with Cuban state entities or wholly foreign-owned enterprises in designated sectors, both requiring Council of Ministers (or delegated body) approval. Non-Cuban foreigners wishing to participate in the domestic private MIPYME (small/medium enterprise) sector must hold permanent legal residency in Cuba. A March 2026 reform for the first time permits Cubans residing abroad to invest in private domestic businesses, but non-Cuban foreign nationals continue to face a restrictive, bureaucratic environment with no general right to form a company.