Real Estate Investment Alert - September 2026
Draft Amendment to the Consolidated Text of the General Regulations of Public Registries Is Published
On September 23, 2026, Resolution No. 00209-2026-SUNARP/SN of the National Superintendency of Public Registries was published, ordering the publication of the draft amendment to the Consolidated Text of the General Regulations of Public Registries. The proposal seeks to advance the transition toward the "Digital Registry," incorporating interoperability with public databases, electronic annotations, and the assisted use of artificial intelligence in the registrar's review, without replacing the registrar's function or liability.
The proposed amendments include, among others, the following:
- Registry public faith: the draft expressly provides that the determination of bona fide registry third-party status rests exclusively with the judicial or arbitral authority.
- Artificial intelligence: the use of automated systems and artificial intelligence is recognized as a supporting tool.
- Duplicate registration entries: amendments are proposed to the procedure for closing duplicate registration entries, including a rule under which, in the case of compatible registrations, the less recent entry may prevail where it contains the updated chain of title or subsequent subdivisions.
- Electronic annotations: a new ancillary and provisional registry mechanism is proposed to give notice of procedural incidents, administrative measures, or transitory legal situations associated with a registration entry. Such annotations would be intended to ensure enforceability against third parties, traceability of information and, as applicable, priority reservation.
- Judicial challenge of Registry Tribunal resolutions: consistent with the foregoing, it is proposed to replace the current continuation of the validity of the filing entry with an electronic appeal annotation
The deadline for submitting comments, contributions, or observations on the draft is fifteen (15) calendar days, counted from the day following its publication. Comments may be submitted through the document processing units of registry offices nationwide, SUNARP's virtual filing desk or to the following email addresses: hespinoza@sunarp.gob.pe y gabad@sunarp.gob.pe.