By Lisa Knepper, Darwyyn Deyo, Ph.D., Kyle Sweetland, Jason Tiezzi, Alec Mena
This edition of License to Work is the first to capture licensing requirements for the Commonwealth of Puerto Rico, thanks to data collected by researchers at the University of Puerto Rico. To keep our rankings comparable between the second and third editions, we have not included Puerto Rico in them. However, here we summarize Puerto Rico’s licensing requirements and show how its licensing burdens for License to Work’s sample of occupations compare to those of the 50 states and the District of Columbia.
Puerto Rico requires a license to work in 49 of the 102 occupations in our sample, five fewer than the average state. It is the only U.S. jurisdiction not to license water well drillers, pest control applicators or vegetation pesticide applicators. It is one of only two that does not license public preschool teachers and one of five that does not license head coaches for public high school sports. The 49 License to Work occupations the Commonwealth does license are far from the only occupations it regulates, however. Like the 50 states and the District, Puerto Rico licenses many occupations that are not part of our sample. Not counting “sporting occupation licenses” (such as boxing, wrestling and horseracing), Puerto Rico licenses a total of at least 129 occupations according to the University of Puerto Rico researchers.1
On average, the 49 licenses require 144 days of education and experience, about one exam, and $228 in fees. While the Commonwealth’s average exam and fee requirements are close to the other jurisdictions’ averages, its average education and experience requirements are substantially lower than the 350 days required by the 50 states and D.C., as shown in Figure 12. Indeed, these average requirements are some of the lowest across the jurisdictions we study.
Figure 12: How Puerto Rico Compares
To put them in perspective, if we included Puerto Rico in our rankings, its licenses would be on the lower end of the burden ranking, as the 46th most burdensome in the nation, between Louisiana’s and Alabama’s. Taking both the number of occupations it licenses and its average burdens into account, Puerto Rico would rank between Michigan and Pennsylvania as 31st on combined rank, as shown in Table 10. Table 11 ranks the 49 occupations Puerto Rico licenses according to how burdensomely the Commonwealth licenses them.
Table 10: Puerto Rico’s Burden and Combined Rankings
Puerto Rico and Select States Ranked by Average Burdens for Licensed Occupations, 2022.
Puerto Rico and Select States Ranked by Number of Licenses and Average Burdens, 2022.
Table 11: Licensing in Puerto Rico
While Puerto Rico’s average burdens compare favorably with those of other jurisdictions, many of its licenses do not. Most notably, among Puerto Rico’s 49 licenses, the most burdensome is that for pharmacy technician, and its requirements exceed those of all other jurisdictions. Aspirants must earn an associate degree and complete a 1,000-hour supervised internship, for a total of 905 days lost to education and experience. These burdens look especially steep considering that 15 of the 44 states that license the occupation do not require any education or experience.
Unlike most other jurisdictions, Puerto Rico also requires aspiring dental assistants and dispensing opticians to earn an associate degree, contributing to their ranks as the 3rd and 4th most burdensome licenses among the 49 examined here. Dental assistants are licensed by only eight states, and Puerto Rico’s is the only license to require an associate degree. By contrast, four states require no education or experience at all, including Washington, which recently eliminated all required training. As for dispensing opticians, most states do not license them, and of those that do, two do not require any education or experience.
Puerto Rico’s sixth most burdensome occupation is interior designer, licensed by only three other jurisdictions. Aspiring interior designers must earn 24 credits in general subjects and another 60 in specialized study, amounting to 588 days lost to education and experience. Though less burdensome than other interior design licenses—Louisiana, Nevada and the District of Columbia each require six years of education or experience—Puerto Rico’s requirements still appear needlessly onerous given that 48 states do not license interior designers, including Florida, which recently eliminated its license.
Other licensing burdens that stand out as uncommonly steep include those for electrical helpers and travel guides. Only three states license electrical helpers and none require education or experience, but Puerto Rico mandates 500 hours of accredited vocational education, amounting to 117 days lost, the result of legislation enacted in 2016.2 Of the 37 states that license travel guides, the majority do not require any education or experience, yet Puerto Rico requires 803 days, including specialized coursework and two years of experience, giving it the second most burdensome licensing requirements in the Commonwealth.
Some of Puerto Rico’s requirements also far outstrip national minimums. For example, the Commonwealth requires 1,000 hours of education, amounting to 233 days lost, for manicurists, while Alaska recently reduced its requirement to just 12 hours. Similarly, aspiring skin care specialists must also undergo 1,000 hours of education in Puerto Rico, while Florida requires only 220 hours. Puerto Rico’s training requirements for entry-level emergency medical technicians, 400 hours of accredited coursework, amounting to about three months, are triple the requirements of most states.
Other requirements appear too burdensome in light of the risks they pose to the public. Most notably, Puerto Rico requires almost eight months (233 days) of training for cosmetologists compared to three months for EMTs (which itself is far higher than average). And because makeup artists and shampooers must be fully licensed cosmetologists, workers in these occupations, too, need more than twice as much training as EMTs.
Finally, not only does Puerto Rico license occupations other jurisdictions do not—sometimes quite onerously—but it also imposes several licenses recently eliminated elsewhere, such as makeup artists, shampooers, residential painting contractors, taxi drivers, travel agencies and weighers, as well as interior designers.
Despite Puerto Rico’s low average burdens overall, comparisons to other jurisdictions show there is likely room for reform. To rein in licensing burdens, Puerto Rico can follow the steps outlined in How to Reform Licensing. In so doing, it will make the Commonwealth a freer, fairer place to live, work and do business.
1. A. J. Ruiz-Torres (personal communication, Aug. 2, 2022).
2. 2016 P.R. Law No. 161; Documentos requeridos: Perito electricista; ayudante de perito electricista. (n.d.). Gobierno de Puerto Rico, Departmento de Estado. https://pr.pcshq.com/?page=otherprofessions,PR-peritoselectricistas
This section was originally published by the Institute for Justice.