The Comptroller General of the Republic issued Resolution No. 3 of 2026, dated January 26, 2026, registered (tomada de razón) on February 5, 2026, and in force since June 1, 2026. The resolution amends Resolution No. 36 of 2024, which sets rules on exemption from the registration (toma de razón) procedure. The changes update the economic thresholds that determine when a contract, transfer, or public concession must undergo prior legality control, and introduce an express obligation to publish or notify the act together with the respective official letter when the CGR registers it with qualifications and/or instructions.
If your company contracts with the State, receives transfers from public bodies, operates under an energy, telecommunications, ports, or aquaculture concession, or holds capital in companies linked to CORFO or the Public Enterprises System (SEP), these rules affect you directly.
What changed
Resolution No. 36 of 2024 set the catalog of administrative acts that State bodies must submit to the CGR's registration (toma de razón) before executing them — the prior legality control that operates as a condition of effectiveness of those acts. The amendment operates on four fronts.
The first incorporates two new outcome categories into the control process. From this reform, the CGR may "abstain" when the act submitted is not subject to registration and/or recording, or "return" it when the body does not attach the necessary background, annexes, or documentation for the legality control. To this is added a publicity obligation: when the CGR registers an act "with qualifications and/or instructions," the issuing body must publish or notify the act accompanied by the respective official letter.
The second front creates an exemption for contracts under a standard design. When a contract adopts a format already approved by the CGR — whether in registered administrative terms or in templates the Comptroller previously validated — the instrument is exempt from the procedure. The limit is precise: the award act remains subject to registration. The streamlining applies to the contract as a document, not to the process that selected you as a supplier.
The third front updates the economic thresholds. For acquisition or supply of movable goods and/or provision of services by direct deal, exceptional direct contracting with publicity, private tender, or purchase by quotation, the threshold is above 8,000 UTM — and their renewals are subject for an amount equal to or above that threshold. For public works by direct deal or private proposal, the threshold is above 10,000 UTM; by public tender, above 25,000 UTM. Advisory and consultancy services linked to works are subject above 5,000 UTM if by direct deal or private proposal, and above 12,000 UTM if by public tender. Transfers of resources with or without an agreement are subject when they exceed 8,000 UTM, with narrow exceptions for the "To Address Emergency Situations" allocation of the Undersecretariat of the Interior and certain programs of the Ministry of Education.
The fourth front incorporates new categories into the catalog. Acts that approve or contain rules, instructions, guides, or general-application guidelines —and their amendments— issued by the National Monuments Council, the Ministries of Health, Education, Housing, and Environment, the Environmental Assessment Service (SEA), and the General Water Directorate (DGA) now enter registration. Also subject are the agreements of CORFO, the SEP Committee, or public enterprises created by law that authorize variations in the State's participation in the capital or board of companies.
What it may mean for your company
The most immediate effect is in the thresholds. If you sell goods or services to the public sector through direct deal or private tender and the contract exceeds 8,000 UTM, that contract will have to undergo registration before being executed — including its renewals. For works and consultancies, the threshold varies by contracting route: direct deal triggers control before public tender does.
The exemption for contracts under a standard format can reduce times in the process. But there is another angle worth understanding: the exemption covers the contractual instrument, not the award act. Your company may receive the contract faster, but the resolution that selected you as supplier remains subject to prior control. The bottleneck does not disappear; it moves.
The obligation to publish acts registered with instructions changes the transparency map for State suppliers. Previously, a contractor had no direct access to the instructions the CGR gave the body when registering the contract. With the amendment, those instructions must accompany the act when it is published or notified. If the contract was registered with conditions, your company will know what they are — and can verify whether the body complied with them during execution.
The entry of CORFO and SEP agreements into the catalog of subject acts has a corporate scope. Any capital or board variation involving the State through CORFO or SEP will have to undergo prior control before being executed. If your shareholding structure includes the State as a partner, that control becomes a new link in the chain of corporate decisions.
The temporal rule is express: the resolution enters into force on June 1, 2026, and administrative acts issued from that date must comply with its provisions. For processes started before that date, the practical key will be the issue date of the corresponding administrative act.
Do you know which acts in your portfolio will be subject to registration from June 1, 2026, and which can avail of the standard-format exemption? Schedule a review to anticipate the real timelines of your contracts.
What you can do
If your company contracts with the State or has ties to entities involving CORFO or SEP participation, three concrete actions:
- Map the administrative acts associated with your current and future portfolio. Identify awards, contract approvals, renewals, transfers, concessions, or corporate modifications that may be issued from June 1, 2026, and contrast them with the thresholds of 5,000, 8,000, 10,000, 12,000, or 25,000 UTM, depending on the nature of the act and the contracting route. The key is not only the contract, but the administrative act that approves, awards, or renews it.
- Verify whether the contract conforms to an already validated standard format. Before assuming the contract will have to undergo registration, check with the contracting body whether the instrument conforms to a standard format contained in registered administrative terms or to a format previously approved by the CGR. If so, the contract may be exempt from the procedure; but the award act will remain subject to prior control.
- Review the registration official letter when there are qualifications or instructions. If the act was registered with qualifications and/or instructions, the body must publish or notify it together with the respective official letter. Incorporating that review into contract monitoring makes it possible to understand the conditions under which the CGR registered the act, anticipate adjustments in execution, and leave early record if the body does not adequately reflect those instructions.
If any of these points raises questions —the thresholds, the standard-format exemption, or the monitoring of the official letters— a 30-minute diagnostic session is enough to size up your gaps. Schedule here.
If you need to assess the impact of these changes on your portfolio of public contracts, on your tender processes, or on your corporate structure with State participation, schedule a diagnostic meeting with our team.
This content is informational and does not constitute legal advice.