Licensing Liberty—Puerto Rico’s New Economic Horizon

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In a transformative year, Puerto Rico has achieved unprecedented strides in economic liberty, surpassing two decades of prior progress. The August 3, 2025 enactment of Act 102-2025, which universally recognizes occupational and professional licenses issued across the United States, marks the second landmark policy victory for Puerto Rico Institute for Economic Liberty (ILE for Instituto de Libertad Económica para Puerto Rico).

Paired with Act 3-2025—which eliminates blanket licensing bans for individuals with criminal records—and Act 96-2025—which mandates a 30-day decision deadline for licensing boards—these reforms showcase evidence-based advocacy dismantling entrenched barriers and expanding opportunity. Regulations, after all, must protect consumers, not entrench monopolies or exclude the deserving.

Acts 3-2025, 96-2025, and 102-2025: Transformative Impacts

Act 3-2025 ends the automatic rejection of applicants with criminal records. In practice, this means that boards must evaluate cases individually based on relevance to professional duties. This reform restores dignity and opens pathways to meaningful work. Multiple state evaluations link easing licensing barriers to lower recidivism by increasing steady employment. Between 1997 and 2007, states with the heaviest licensing burdens saw recidivism rise ~9%, while those with the lightest burdens saw it fall ~2.5%.

In a similar vein, Act 102-2025 eliminates redundant bureaucratic hurdles for licensed professionals relocating to Puerto Rico. An active U.S. license and three years of experience now qualify professionals in fields from nursing to engineering, streamlining mobility. Consumer protections stay robust via ethics rules, disciplinary oversight, and concise Puerto Rico-specific modules that assess local competency without redundant academics.

Similar reforms have been promising at the national level. A multi-state working paper found that universal recognition increased the employment-to-population ratio (the share of working-age people with jobs) for licensed workers by ~0.98 percentage point. And those gains were co‑driven by higher participation and lower unemployment among licensed workers. Meanwhile, inbound migration of licensed workers rose by ~48% into states adopting universal recognition. In Arizona, for example, dynamic modeling projects universal recognition to add ~15,991 workers and at least $1.5B in GDP by 2030, with population +44,376.

If more were needed, the Obama White House/Treasury/CEA review concluded that licensing raises prices, restricts employment opportunities, and hinders interstate mobility, with limited evidence of quality gains in many occupations.

For Puerto Rico, these changes promise faster recruitment into critical sectors like healthcare and construction, boosting productivity in the post-PROMESA economy (the 2016 federal law establishing fiscal oversight for Puerto Rico’s debt crisis). A 2022 Puerto Rico study by ILE found that 34 local licenses exist in fewer than five U.S. jurisdictions, including 13 unique to the Island. This is evidence of atypically narrow licensing that universal recognition and fair‑chance reforms aim to counter.

Finally, Act 96-2025 completes the framework. It standardizes licensing procedures, mandates a 30-day decision timeline, and grants provisional licenses if deadlines lapse, allowing 30 additional days for final rulings. This ensures citizens are not penalized by bureaucratic delays, enabling employers to plan hires, hospitals to staff shifts, and contractors to schedule projects.

Together, Act 102 opens the door to external talent, Act 3 widens it for those seeking redemption, and Act 96 ensures it stays unblocked.

Reciprocity in Practice

As ILE Founder and CEO Jorge Rodríguez highlights, these reforms embed Puerto Rico in a nationwide reciprocity network: Today, 27 states recognize licenses issued in Puerto Rico for relocating professionals, and with Act 102-2025, “Puerto Rico [is] now the 28th jurisdiction to reciprocate, upholding every U.S. citizen’s constitutional right to mobility.”

Jorge points out the Island’s unique regulatory landscape, noting that Puerto Rico maintains 34 occupational licenses not required in 46 or more states, with 13 unique to the Island. To practice here, professionals must still “apply to the local board, meet all legal requirements—including mandatory association membership where applicable—and obtain a locally issued license. No one begins practicing immediately upon arrival.” If boards delay, “a 30-day processing clock triggers; failure to decide grants a provisional license, with 30 more days for a final ruling.” For the first time, as he emphasizes, “individual economic rights supersede bureaucratic inertia.”

Editor’s note: Counts per ILE; local boards retain full disciplinary jurisdiction. Puerto Rico’s regime includes 34 licenses found in five or fewer states (13 unique), underscoring the value of reciprocity.

From left to right: Jorge L. Rodríguez (ILE Founder & CEO ), Arturo V Bauermeister (ILE Legal Director, Founding Member of B&D LLC, and event moderator), and Hon. Thomas Rivera Schatz (President of the Puerto Rico Senate and a key driver of the acts) at the April 23, 2025 event, “Fighting Back: Puerto Rico’s Deregulation Efforts,” co-organized by ILE and the Puerto Rico Lawyers Chapter of the Federalist Society.

How Universal Recognition Operates

Who qualifies (at a glance): Active U.S. license; 3+ years experience; Disclosure of past discipline; Completion of PR-specific modules/ethics; Board application on file.

• Apply: Submit a reciprocity application to the Puerto Rico licensing board.
• Qualify: Hold an active U.S. license with three years of experience and disclose any disciplinary history.
• Comply: Complete Puerto Rico‑specific requirements (ethics training, local‑law modules, and—where applicable—association membership).
• Guardrails: Boards keep full disciplinary authority; provisional licenses can be revoked for cause. Consumer protections remain stringent.
• Timeline: Boards must decide within 30 days; if they do not, a provisional license issues with 30 additional days for a final decision.

Debunking Myths

• Myth: Act 102-2025 favors mainland real-estate brokers.
  • Fact: It benefits all professionals, with safeguards ensuring quality and fraud prevention. Boards retain oversight, requiring local-law modules without duplicative credentials.
• Myth: Only brokers will relocate; nurses and tradespeople won’t for lower wages.
  • Fact: Universal recognition elsewhere has drawn diverse professionals, driven by family ties, quality of life, and cost-of-living advantages. Many Puerto Ricans seek to return, previously hindered by red tape.
• Myth: More academic credits ensure better outcomes.
  • Fact: Targeted training outperforms redundant academics. Universal recognition prioritizes relevant competencies, aligning with best practices.
• Myth: New entrants harm local professionals.
  • Fact: Competition expands services, moderates prices, and stimulates markets. And this benefits consumers and professionals alike.

Economic Justice and Academic Foundation

These reforms reflect ILE’s core tenet: Regulation should serve consumers, not exclude the capable or protect monopolies. Act 3 empowers those with past convictions. Act 102 attracts skilled professionals. And Act 96 ensures timely access. Collectively, this fosters equality and reduces unemployment. As the 2015 White House/Treasury/CEA review notes, licensing raises prices, restricts employment, and impedes mobility in many fields.

Beyond economics, these acts foster social equity. Act 3 restores dignity to formerly incarcerated individuals. I believe not only in reducing recidivism and strengthening families, but in redemption. Act 102, for its part, encourages the return of the Puerto Rican diaspora, revitalizing communities with skills and cultural ties. In a post-Maria, post-PROMESA era, this builds resilience, e.g., faster healthcare staffing improves public health outcomes for all.

It bears noting that these reforms originate from ILE’s report, Unleashing Potential: The Burdens of Occupational Licensing and How It Can Be Reformed in Puerto Rico, produced with the University of Puerto Rico, the Institute for Justice, and West Virginia University’s Knee Regulatory Research Center. Data-driven analysis, not ideology, shaped these policies.

Kudos to my friend and ILE Policy Research Director, Dr. Angel Carrion-Tavarez, for his incalculable contribution to putting the Island —statistically speaking—on the map.

Implementation: From Law to Impact

Legislation is the foundation. But execution is the edifice. To ensure success, stakeholders must:

• Publish quarterly dashboards tracking board performance, including processing times and Act 96 compliance.
• Release anonymized application data for public and academic scrutiny.
• Report median decision times, 30-day compliance rates, provisional licenses issued, and consumer-protection actions.
  • Modeled gains like Arizona’s +15,991 jobs and +$1.5B GDP are only realized in Puerto Rico if boards meet the 30‑day clock and issue provisional licenses when they do not.
• Clarify via executive action: hybrid professions, out‑of‑state discipline, and jurisdictional standards.
  • Potential pushback from local boards—as a recent Cato Institute commentary warned—could hinder progress.
  • Fiscal constraints may also strain board resources, risking delays in processing the expected influx of applications under Act 102-2025. So, addressing these challenges through targeted funding or streamlined support will be critical to sustaining momentum.

A Crucial Mission Realized

These victories affirm ILE’s approach: meticulous research and principled persuasion. Economic liberty has moved from white-paper theory to Puerto Rican statute twice in one year, with a third statute providing the operational backbone. While tailored to Puerto Rico's unique challenges—like its 13 Island-exclusive licenses—these reforms echo successful U.S. mainland models, offering lessons for all jurisdictions.

These victories ignite prosperity’s cycle. Share your Act 102 experiences below to hold boards accountable. Real data drives change.

This article was written originally under the Substack name The Bauermeister Brief. Feel free to subscribe for free to receive new posts and support his work.