What the Government Program means for private entrepreneurs

However, the document lacks a fundamental precision: it does not detail the concrete “hows” for the implementation of these measures. Nor does it establish specific schedules beyond some annual goals, leaving open the question of the practical mechanisms that will be used to materialize these provisions.

What we have, then, is essentially a systematized compilation of the lines of work that the government has been announcing, now presented under a plan structure with result indicators. This organization allows, for the first time, a clearer overall vision of the direction that economic policy intends to take.

Depending on its effective implementation—and the evolution of the national and international context—this program could shape the scenario for the private business sector in the medium term. Our analysis identifies the components that deserve strategic follow-up, understanding that their concrete impact will depend on multiple factors that are yet to be defined.

New exchange and currency policy: potential openings in a framework of control

The program establishes recovering the convertibility of the national currency as a “strategic task,” but makes a significant acknowledgment: conditions for a unified exchange scheme do not exist in the short term.

This admission is crucial, as it indicates that the fundamental exchange distortion—the coexistence of multiple exchange rates—will persist as a structural characteristic of the economy in the immediate horizon.

Facing this reality, the program proposes a “new mechanism for the management, control, and allocation of foreign currency” that would include “closed self-financing schemes” for exporters and a “partial dollarization” within limits yet to be defined.

For private companies, the proposed self-financing schemes could represent a way to access a portion of the foreign currency they generate with greater predictability. However, the “partial dollarization” generates more questions than certainties.

The document does not clarify whether this process will significantly include the national private sector, in which sectors it will be applied, or how equitable access to foreign currency will be guaranteed in a scenario of limited supply.

The latent risk is the consolidation of a fragmented and restricted access system, where the participation of MSMEs in this dollarization is marginal or subject to discretion.

Therefore, AUGE’s recommendation is to maintain a cautious expectation without assuming, for the moment, that this new mechanism will structurally solve the current bottlenecks.

Promotion of exports: announced incentives must overcome structural barriers and legal limitations

The program identifies the increase and diversification of external income as a fundamental pillar, with a particular focus on professional services, technology, and the knowledge sector, proposing “differentiated incentives” of a fiscal, regulatory, and salary nature. However, this approach sharply contradicts a regulatory reality: most high value-added professional services are included in the list of activities prohibited for the private sector.

This fundamental contradiction means that, without a prior review of said prohibitive framework, the potential contribution of the private sector in this area will be marginal. The situation is aggravated when considering that the private sector’s exporting capacity has historically been very limited, concentrating mainly on items such as software (where it is permitted) and charcoal, with an insignificant share of total national exports.

The substantial expansion of this participation requires, in addition to eliminating existing prohibitions, resolving structural challenges that the program does not sufficiently address: the definitive resolution of exchange problems that allow exporters predictable access to foreign currency; the building of confidence through a stable regulatory framework; and the liberation of diverse sources of financing for export projects.

Productive linkages: transition from leasing to strategic integration models

The program explicitly promotes the creation of productive linkages between the state and non-state sectors, representing an effort to overcome the predominant model so far – fundamentally based on the leasing of premises and idle capacities – to advance towards more advanced and mature forms of integration.

This evolution reflects the government’s position as the principal holder of the country’s productive assets and its interest in utilizing them more strategically. While this could be interpreted as a strengthening of the state’s position in the relationship, it simultaneously opens significant opportunities for the private sector: access to infrastructure, installed capacities, and markets that, although requiring rehabilitation, represent a considerable advantage compared to starting from scratch.

The key will be the implementation of the “Instruction that establishes contractual relations” between economic actors. If this instruction manages to create an agile framework, it could catalyze productive collaborations. However, if it reproduces the bureaucratic rigidity characteristic of inter-state relations, it will reproduce the same obstacles that have historically limited these linkages.

Necessary transformation with implementation challenges

The program establishes the modernization of the payment system, banking access (bancarización), and the transformation of banking services as priority objectives, with specific goals to increase online payments, the use of digital gateways, and the institutional redesign of the banking system.

This transformation is essential to improve the efficiency, security, and traceability of commercial transactions. The document specifically states the need to “advance in the transformation of banking management” and “present the proposal for the institutional redesign of the banking system,” recognizing the need to adjust it to the current requirements of the economy.

However, implementation faces significant challenges that the document does not fully address: limited technological infrastructure, irregular connectivity in many areas of the country, and the need for training for both entrepreneurs and consumers.

The program mentions confronting the non-acceptance of digital payments and the creation of new financial products, but does not detail the concrete incentives that will facilitate this transition for small and medium-sized enterprises, nor the actual scope of the promised banking transformation.

Monetary Regulation Bonds (LRM): monetary policy instrument with limited appeal for the private sector

The program includes among its actions the implementation of Monetary Regulation Bonds (LRM), financial instruments that are essentially debt securities issued by the Central Bank of Cuba (BCC).

Technically, they function as follows: the BCC sells them to commercial banks and other economic actors, thereby withdrawing Cuban pesos (CUP) from circulation, with the commitment to repurchase them at a determined future date.

Their declared objective is to “contribute to the reduction of inflation by gradually sterilizing part of the excess money in circulation.” While the document proposes to “expand the use of Monetary Regulation Bonds to the business sector,” they present serious limitations as an investment alternative for private companies.

The main drawback is that they are denominated in CUP and are issued in a context of high inflation and persistent loss of value of the national currency, which erodes their real return and questions their attractiveness as a store of value. Furthermore, the program does not specify interest rates, terms, secondary liquidity conditions, or transmission mechanisms for these bonds that could make them minimally competitive against other alternatives for productive investment.

For private companies, these bonds represent more of a monetary policy mechanism to try to contain inflation than a genuine investment opportunity, especially considering the priority of reinvesting profits in productive activities that generate foreign currency or tangible value in such a complex economic environment.

Modernization of the fiscal system: toward greater formalization with the VAT horizon

The program deploys an integral fiscal modernization strategy aimed at greater collection and control, implying a scenario of increasing formalization for the private sector.

The most concrete and immediately implementable element is the establishment of mandatory electronic invoicing for 2026, a measure that will demand technological and process adaptation from all companies. Simultaneously, the document mandates “studies and proposals for the implementation of the Value Added Tax (VAT),” signaling the clear direction of future tax reform toward an indirect, broad-based tax. While a “simplification of taxes” is mentioned, the main emphasis lies on strengthening fiscal control mechanisms and reducing evasion, including the automatic collection of debts from bank accounts.

For private companies, this set of measures represents a double-edged sword: on the one hand, it demands an investment in compliance and adaptation to new obligations, increasing the administrative burden in the short term; on the other hand, a more modern and predictable tax system could benefit formalized companies that operate with transparency.

AUGE Strategic Recommendations: Navigating a New Economic Scenario?

Given the framework established by the 2025 Government Program, whose concrete implementation measures and real effectiveness are yet to be defined, private companies require a strategic approach that combines meticulous preparation with operational flexibility. The following recommendations aim to guide business adaptation in this transition scenario:

1. 1. Regarding the New Exchange Mechanism:

• Maintain cautious expectations regarding the real scope of “partial dollarization.
• Wait for the publication of specific legal norms before making investment decisions based on this mechanism

2. Regarding Export Incentives:

• Document and structure the company’s export capabilities.
• Maintain prudent expectations until observing the publication of concrete operational mechanisms.
• Do not make significant investments without first seeing progress in dismantling structural barriers.

3. Regarding Productive Linkages:

• Develop clear and professionalized value proposals for potential state partners.
• Include contractual clauses in negotiations that specify payment terms and dispute resolution mechanisms.
• Maintain a realistic evaluation of operational and liquidity risks.
• Strategically evaluate integration opportunities considering the advantage of accessing existing infrastructure.

4. Regarding Payment Modernization and Banking Services:

• Begin a gradual process of adapting to digital payment solutions.
• Evaluate available solutions and implement them in a phased manner.
• Maintain operational flexibility to function in environments with potential technological interruptions.
• Monitor the evolution of the banking system’s financial service offering.

5. Regarding Monetary Regulation Bonds – LRM:

• Analyze with extreme caution any participation in this market.
• Prioritize investments in productive capacity and operational resilience.
• Consider LRM primarily as a monetary policy instrument, not as an investment opportunity.

6. Regarding Fiscal Modernization::

• Immediately initiate a diagnosis of accounting processes and information systems.
• Prepare for the transition to mandatory electronic invoicing in 2026
• Closely monitor the development of the debate on the implementation of VAT.
• Maintain transparent and up-to-date accounting in view of the strengthening of fiscal controls.

Cross-Cutting Recommendations:

• Establish a continuous monitoring system for the publication of norms and resolutions.
• Develop budgets and operational plans by scenarios.
• Maintain flexible organizational structures that allow adaptation to regulatory changes.
• Participate in sectoral dialogue spaces to understand expectations and real timelines.
• Prioritize the professionalization of internal processes and accounting transparency.

Towards strategic management in times of transformation

The analysis of the 2025 Government Program confirms what many entrepreneurs already suspected: we are facing a scenario of transformations, where the rules of the game are being redefined, but the concrete mechanisms for implementation remain in a fog. This planned ambiguity represents both a risk and an opportunity for the private business sector.

What the program does not say, but implies, is equally important:

• The need for professionalized management becomes critical
• Accounting and operational transparency is no longer optional
• Strategic adaptability becomes a competitive advantage
• Negotiation capacity defines access to opportunities
• • The long-term vision differentiates entrepreneurs from merchants

At AUGE, we understand that navigating this environment requires more than reaction: it demands strategic anticipation, meticulous preparation, and disciplined execution. We don’t just help you understand the change, we help you lead it.