Panama Accounting Records 2025-2026: the annual compliance obligation 80% of foreign-owned corporations miss

On May 19, 2026 at 9 a.m., my sister received an email from Kraemer & Kraemer, our law firm in Panama City. Three attachments: an Accounting Records Form, a Financial Statement Form, and a Corporate Dormancy and No Asset Declaration. Quiet deadline, forms in English and Spanish. None of these names appear in the 200-page guide we had built before incorporating our Panama corporation.

What we discovered while filling them out: Panama has a separate annual accounting obligation, distinct from the Renta income tax return, filed with your Resident Agent — not the DGI tax authority — and applicable to every Panama corporation, including fully dormant ones. Missing it triggers administrative fines up to USD 5,000, with forced dissolution on repeat offenses.

This article documents the full obligation, with the direct experience of our own 2025 filing through Kraemer & Kraemer. It’s the information we wish we had before incorporating.

The 30-second version

• Accounting Records (registros contables) are an annual filing required by Law 52 of 2016, strengthened by Law 254 of 2021.
• Applies to every Panama corporation, whether active or dormant.
• Filed with your Resident Agent (your law firm), not with the DGI tax authority.
• Three possible forms depending on status: Dormancy Declaration (no activity), Accounting Records Form + Financial Statement Form (active corporation).
• Typical deadline: before July 31 of the year following the fiscal year (exact calendar set by your Resident Agent).
• Penalties: fines of USD 1,000 to 5,000, suspension of Resident Agent service, forced dissolution for repeat offenses.
• Cost is typically included in standard Resident Agent fees (USD 350-650/year at Kraemer & Kraemer).

1. Why this obligation exists (and why most foreign founders find out too late)

To understand why this filing is so under-documented for English-speaking expats, you have to go back to the post-Panama Papers context (2016). Under OECD and EU pressure, Panama had to tighten its fiscal transparency framework to come off the blacklists.

Law 52 of October 27, 2016 introduced the obligation for every Panama corporation to maintain accounting records, including companies with no local activity. This was a break from the historic Panamanian regime where a Sociedad Anónima could remain fully opaque as long as it didn’t generate local operations.

Law 254 of November 11, 2021 strengthened the framework. It added the requirement to file records annually with the Resident Agent, expanded penalties, and created a simplified declaration for dormant corporations — the Corporate Dormancy and No Asset Declaration.

Why most foreign founders miss this? Because most English-speaking guides (International Living, Live and Invest Overseas) predate 2021 and still describe Panama under its old “easy offshore” regime. And because Panama law firms — the only ones who get the annual reminder — have no commercial incentive to publish this information openly: it’s part of their paid value-add.

2. Accounting Records vs Renta DGI — don’t confuse the two

The most common error — and one that initially confused us too — is to think Accounting Records and the Renta income tax return are the same thing. They are two parallel and independent obligations.

Critical point: the numbers in your Financial Statement Form (Accounting Records) must match the figures in your Renta DGI return. Any discrepancy is a red flag in an audit. Prepare both in sequence with your contador: Renta in March, Financial Statement in April-May with the exact same numbers.

3. Case 1 — your corporation is dormant (the simplest path)

If your Panama corporation had no economic activity during the fiscal year — no revenue, no sales, no contracts, and ideally no movement on a bank account — it qualifies for the simplified dormancy regime.

Then you only sign one form: the Corporate Dormancy and No Asset Declaration. This is a sworn declaration certifying that the company had no economic activity and no assets during the fiscal year in question. No financial statements to produce, no detailed balance sheet. The signature commits the signatory’s responsibility in case of false declaration.

Our exact case in May 2026: LAS FUNDADORAS HERMANAS S.A. stayed dormant in 2025 (the corporation was set up late 2025, Inside Panama generated no revenue during the fiscal year). So we filed a Dormancy Declaration for 2025. Starting in 2026, the status flips to “active” with the first AdSense or affiliate revenue — which changes the entire filing regime.

Watch the “zero asset” criterion: an open bank account with even a small balance can be enough to reclassify the company as active in the administration’s eyes. If your corporation holds a Tower Bank account with USD 500 in it, get the dormant qualification confirmed in writing by your contador before signing the Dormancy Declaration.

4. Case 2 — your corporation is active (two forms to produce)

As soon as there’s activity — AdSense revenue, affiliate commissions, Gumroad sales, consulting, signed contracts, an operational bank account with movements — the corporation is considered active and two separate documents become mandatory.

4.1 Accounting Records Form (Formulario de Registros Contables)

This first form does not contain the accounting figures themselves. It attests to the existence and physical location of the records: where your books, invoices, Tower Bank statements, and client contracts are stored. The form also asks who your contador is and their CCPAP number (Colegio de Contadores Públicos Autorizados de Panamá).

The idea: if the administration wants to audit, it needs to know where to look. Mandatory retention is 5 years minimum. Cloud storage is accepted, but the form must indicate the server or platform used.

4.2 Financial Statement Form (Estado Financiero)

The second form contains the figures: a synthetic summary of the financial statements for the fiscal year. Total assets, total liabilities, equity, revenue, expenses, net result. Typically a single page, not a detailed balance sheet — but the numbers must match the Renta filed with the DGI.

For Inside Panama in its first active year (projected 2026), this will cover: AdSense + affiliate + consulting + Gumroad sales revenue on one side, hosting + SaaS tools + professional fees expenses on the other, with the net result matching the Renta DGI.

5. Who can sign? The junta directiva legal point

Every Accounting Records form carries a key clause: “duly authorized by the Board of Directors to complete this Financial Statement for and on behalf of the entity.” The signatory must be duly authorized by the board.

Standard case: the form is signed by a member of the junta directiva (president, secretary, or treasurer). No question.

Special case — our situation: my sister and I are co-shareholders of LAS FUNDADORAS HERMANAS S.A., but neither of us appears as a director. Nominee directors are provided by the firm (a common practice for Panama corporations incorporated by foreigners still in the process of obtaining their Friendly Nations Visa).

So my sister sent a written clarification request to the firm on May 18, 2026:

“I notice the declaration states that the signatory must be ‘duly authorized by the Board of Directors to complete this Financial Statement for and on behalf of the entity’. My sister and I are co-shareholders of the company, but we do not appear as directors. Could you confirm whether I am authorized to complete and sign this document, or if it must be signed by the corresponding directors?”

Nicole Hepburn, Compliance Assistant at Kraemer & Kraemer, replied in less than 24 hours:

“Correct, this means that the board of directors grants you the power to sign, so the document may be signed by you.”

Concrete translation: a non-director shareholder can validly sign the Accounting Records if the board of directors delegates that power. This is often the case when the firm acts as nominee director — they implicitly delegate the accounting signature to the actual shareholders.

Our recommendation: never sign on that basis without explicit written confirmation from the Resident Agent. An email counts as evidence in case of later audit. Keep the exchange for 5 years minimum (the legal retention period for accounting records).

6. Concrete deadlines and penalties

The exact calendar varies from one Resident Agent to another. Our 2025 filing through Kraemer & Kraemer followed this sequence:

Penalties for non-compliance, under the combined Law 52 of 2016 + Law 254 of 2021:

• Administrative fines of USD 1,000 to 5,000 depending on delay and recurrence.
• Resident Agents are legally required to flag non-compliant companies — they can suspend service, which makes the corporation non-operational (cannot sign contracts, bank account eventually closed).
• On repeated default across multiple fiscal years: forced dissolution ordered by the regulatory authority.
• On the bank account side (Tower Bank or equivalent): risk of administrative freeze if the bank receives a default notification from the Resident Agent.

7. What it really costs, and how to organize yourself

Good news: at most serious firms, the Accounting Records filing is included in annual Resident Agent fees. But that assumes two things: that you have an up-to-date Resident Agent contract, and that the fees explicitly cover this service.

Realistic annual budget for a Panama corporation in 2026 (numbers updated after our experience):

Mandatory question to ask your Resident Agent when signing the contract: “Do your annual fees cover the preparation and filing of the Accounting Records? If yes, for both regimes (dormant and active)? If not, what is the additional cost?”

Some lower-end firms invoice the Accounting Records separately (USD 300-500/year), which changes the budget equation and creates unpleasant surprises in year two.

8. What to remember

Accounting Records are the most under-documented compliance obligation under post-2021 Panama law for foreign founders. Three things to remember:

1. It’s a separate annual obligation from the Renta DGI, filed with your Resident Agent.
2. It applies to every Panama corporation, active and dormant alike — with a simplified regime for dormant entities.
3. A non-director shareholder can sign if the board of directors authorizes it — always get the confirmation in writing.

The right reflex to set up right now: an automated reminder 60 days before the deadline announced by your Resident Agent, scheduled in your productivity tool of reference (Notion, Google Calendar, Make.com). This forgotten obligation is one of the three most common causes of forced dissolution for foreign-owned Panama corporations.

Get the full Panama compliance memo

This article is a deep-dive on one obligation. The complete Inside Panama Memo n°2 — Le contador panaméen covers the full landscape: how to find and brief your contador, the CCPAP system, tasa única deadlines, audit-proof bookkeeping, and the 90 % of compliance pitfalls foreign founders miss.

👉 Get the memo — $24

Or join the Inside Panama newsletter for weekly field updates from Panama City.

📧 Subscribe

Related reading

• La SA dormante visa pays amis — Memo n°4 (FR)
• Visa pays amis pas-à-pas — Memo n°5 (FR)
• Encaisser sans banque pro — Memo n°1 (FR)
• Quitter la France fiscalement — Memo n°6 (FR)

Published May 20, 2026 by the founders of Inside Panama, brand of LAS FUNDADORAS HERMANAS S.A. (RUC 155776412-2-2025).