Table of Contents
- Executive Summary: Key Trends Shaping Cuba’s CRE in 2025
- Market Overview: Current State of Commercial Real Estate
- Regulatory Landscape: Laws, Taxation, and Compliance (Sources: minjus.gob.cu, minfinanzas.gob.cu)
- Foreign Investment Rules and Restrictions (Sources: mincex.gob.cu, cubatrade.org)
- Economic Drivers: Tourism, Trade, and Infrastructure
- Prime Locations: Emerging Hotspots and Development Zones
- Key Statistics: Market Size, Vacancy Rates, and Rental Yields
- Challenges: Political, Legal, and Currency Risks
- Future Outlook: Projections for 2025–2030
- Strategic Recommendations for Investors and Developers
- Sources & References
https://youtube.com/watch?v=NSSYW9ZpKHs
Executive Summary: Key Trends Shaping Cuba’s CRE in 2025
Cuba’s commercial real estate (CRE) sector is undergoing cautious transformation amid ongoing economic reforms and shifting regulatory frameworks. As of 2025, the Cuban government continues to control most land and property, but incremental legal changes are opening select segments of the CRE market to new forms of ownership, investment, and operation. In recent years, Decree-Law No. 288 has allowed for limited private ownership and transfer of real estate, though primarily in the residential sector. Commercial property transactions—especially involving foreign investors—remain tightly regulated, with state entities retaining primary ownership and oversight Gaceta Oficial de la República de Cuba.
Foreign investment is permitted under the framework of Law No. 118/2014, which establishes joint ventures and lease arrangements as the primary vehicles for non-Cuban entities. Most large-scale commercial developments, including retail, office, and hospitality projects, are operated as joint ventures with state companies such as GAESA or CUBANACU. In 2024-2025, Cuba continues to prioritize tourism infrastructure, with hotel and mixed-use projects concentrated in Havana and key coastal regions. The government reports that over 70% of active foreign investment projects are in the tourism and hospitality sector Ministerio del Comercio Exterior y la Inversión Extranjera (MINCEX).
Compliance and permitting remain challenging for investors. All CRE transactions require approval from ministries such as Ministerio de la Construcción (MICONS) and Ministerio de Finanzas y Precios (MFP), with strict adherence to labor, environmental, and national security regulations. Legal due diligence is essential, particularly concerning property title, zoning, and the terms of joint venture agreements. While new regulations in 2023-2024 have clarified some procedural requirements, bureaucratic delays persist.
Official statistics on CRE transaction volumes are limited. However, government sources confirm more than 40 joint venture projects with foreign capital in 2024, predominantly in the hotel sector MINCEX. The retail and office segments remain underdeveloped, with growth constrained by currency shortages, sanctions, and limited domestic purchasing power.
Looking ahead, the outlook for Cuba’s CRE market in 2025–2027 is defined by gradual liberalization, continued state oversight, and selective foreign participation. Key trends include the expansion of mixed-use and hospitality projects, potential regulatory adjustments to attract capital, and ongoing challenges related to infrastructure, transparency, and international compliance standards. The sector’s trajectory will depend on government policy, external investment appetite, and macroeconomic stabilization efforts.
Market Overview: Current State of Commercial Real Estate
The commercial real estate (CRE) sector in Cuba remains unique due to the nation’s socialist framework and evolving economic reforms. As of 2025, private property ownership is still highly regulated, with the state retaining control over land and most commercial assets. Foreign investment is permitted primarily through joint ventures or special economic projects, notably within tourism, retail, and light industrial sectors.
Recent legislative changes, including the 2022 update to the Foreign Investment Law, have clarified processes for foreign participation in commercial real estate projects. The law allows foreign investors to lease land and construct facilities through joint ventures with state entities, but outright ownership of land remains prohibited. These partnerships are commonly structured under the oversight of the Ministerio de Relaciones Exteriores de la República de Cuba and must secure approval from the Ministerio del Comercio Exterior y la Inversión Extranjera (MINCEX).
Commercial real estate development is concentrated in designated zones such as the Mariel Special Development Zone (ZED Mariel), established to attract foreign capital and modernize infrastructure. As of 2024, ZED Mariel has approved over 60 projects involving foreign partners, with investments exceeding $3 billion USD. Sectors represented in these projects include logistics, manufacturing, and hospitality, reflecting Cuba’s emphasis on export-oriented and tourism-driven growth (Zona Especial de Desarrollo Mariel).
Compliance requirements are strict. Investors must navigate detailed due diligence processes, including anti-money laundering checks, and demonstrate alignment with Cuba’s national development priorities. All leases, construction, and operational agreements undergo review by the Gaceta Oficial de la República de Cuba and relevant ministries. Commercial leases typically run for 25 years, with possible extensions, but all improvements and buildings revert to state ownership at lease-end unless otherwise negotiated.
Official statistics are limited, but the Oficina Nacional de Estadísticas e Información (ONEI) reports a modest rise in commercial floor space, especially in Havana and key tourist destinations, due to ongoing upgrades of hotel, retail, and logistics facilities. However, the sector faces challenges: currency instability, material shortages, and ongoing US sanctions continue to constrain growth and profitability.
Looking forward, the Cuban government’s 2025–2027 economic plan signals continued prioritization of joint ventures and targeted foreign investment in commercial real estate, particularly in tourism and logistics. However, the legal environment is expected to remain closely controlled, with gradual, incremental reforms rather than sweeping liberalization.
Regulatory Landscape: Laws, Taxation, and Compliance (Sources: minjus.gob.cu, minfinanzas.gob.cu)
The regulatory landscape governing commercial real estate in Cuba is characterized by a highly centralized legal and administrative framework, with all land and most properties remaining under state ownership. The Ministerio de Justicia (MINJUS) is the principal authority overseeing property law, registration, and the legal status of real estate transactions. Although the Cuban Constitution (2019) recognizes private property to a limited extent, the purchase, sale, and long-term lease of commercial real estate are tightly regulated, particularly for foreign entities.
Foreign investment in commercial real estate is permitted under specific conditions established by Law No. 118, the “Ley de la Inversión Extranjera,” which allows joint ventures and wholly foreign-owned companies to obtain long-term usufruct rights (typically up to 99 years) rather than outright ownership. Transactions must be approved by the MINJUS and relevant sectoral ministries. All agreements are subject to registration in the Registro de la Propiedad, and compliance with urban planning regulations issued by municipal authorities is mandatory.
Taxation on commercial real estate activities is governed by the Código Tributario, administered by the Ministerio de Finanzas y Precios (MFP). Foreign-invested entities are subject to a corporate income tax rate of 35%, with tax holidays and incentives available for investments deemed strategically important. Property-related taxes include an annual land tax (Impuesto sobre la Propiedad o Posesión de la Tierra) and, where applicable, taxes on rental income and capital gains. All tax declarations and payments must be made in accordance with the procedures set by the MFP, and strict penalties apply for non-compliance.
Recent legal reforms have focused on improving transparency and streamlining administrative procedures, including the digitalization of property registries and tax filings. Nevertheless, the process for obtaining permits, licenses, and approvals remains complex and often requires significant engagement with multiple government agencies. Compliance with anti-money laundering regulations and adherence to sector-specific investment rules—especially in tourism, retail, and logistics—are critical for both domestic and foreign participants.
Looking ahead to 2025 and beyond, further regulatory adjustments are anticipated as Cuba seeks to attract greater foreign capital while retaining state control over strategic assets. Monitoring legislative updates from MINJUS and the MFP will be essential for investors to navigate the evolving landscape of commercial real estate in the country.
Foreign Investment Rules and Restrictions (Sources: mincex.gob.cu, cubatrade.org)
Cuba’s approach to foreign investment in commercial real estate is shaped by a unique regulatory environment, strict state oversight, and evolving economic imperatives. As of 2025, foreign ownership of land remains prohibited; all land is state-owned, and foreign investors may only acquire real estate rights through long-term leaseholds—typically up to 99 years—under joint venture or association agreements with Cuban entities. This framework is outlined in the pivotal Law No. 118 on Foreign Investment (2014), which continues to regulate the sector, emphasizing state priorities and national interests.
Recent years have seen further clarification and incremental opening regarding the scope of foreign participation. Notably, commercial real estate investment is concentrated in tourism (hotels, resorts, marinas), mixed-use developments, and special economic zones such as the Mariel Special Development Zone. Here, foreign investors can lease land and develop commercial property within specified guidelines, contingent upon approval by the Council of Ministers and sectoral authorities. All proposals undergo rigorous due diligence, including assessments of financial capacity, technology transfer, and projected socio-economic impact, in accordance with the processes stipulated by the Ministry of Foreign Trade and Investment (MINCEX).
Compliance requirements are strict. Investors must operate through a Cuban legal entity (typically a joint venture company or international economic association contract), and all transactions—including profit repatriation, taxation, and dispute resolution—are governed by Cuban law and subject to government audit. Routine reporting and transparency obligations are enforced by sectoral regulators and the Ministry of Foreign Trade and Investment (MINCEX). The Cuban government retains authority to terminate agreements unilaterally in cases of national interest, or if compliance standards are not met.
Statistically, the volume of active foreign commercial real estate ventures remains modest compared to regional peers, reflecting both opportunity and constraint. As of 2024, foreign investment is heavily weighted towards tourism and infrastructure, with over $3 billion committed in approved projects, much of it in hotel and resort complexes within designated development zones (Cuba Trade Economic Council). However, non-tourism commercial property remains rare, primarily due to legal limitations and bureaucratic complexity.
Looking to 2025 and beyond, incremental liberalization is anticipated, especially in sectors aligned with government priorities such as renewable energy, logistics, and high-value tourism. However, profound changes—such as permitting outright foreign land ownership or a broader commercial real estate market—remain unlikely without major legal reforms. Investors are advised to closely monitor regulatory updates from MINCEX and to maintain rigorous compliance processes, as Cuba continues to balance economic modernization with state control.
Economic Drivers: Tourism, Trade, and Infrastructure
Cuba’s commercial real estate sector in 2025 is fundamentally shaped by the interplay of tourism, trade, and infrastructure modernization. The Cuban government, which maintains central control over land and most property, has implemented gradual reforms since the 2010s to attract foreign capital, especially in sectors like hospitality, logistics, and retail. The Mariel Special Development Zone (ZED Mariel), a flagship project west of Havana, continues to anchor much of Cuba’s foreign direct investment (FDI), offering tax incentives and allowing foreign companies to lease land for up to 99 years for commercial use—a notable exception to Cuba’s general prohibition on private land ownership (ZED Mariel).
Tourism, a cornerstone of the Cuban economy, is a primary driver of commercial real estate activity. According to the Ministerio de Turismo de Cuba, international arrivals in 2023 rebounded to 2.4 million visitors, with projections for 2025 aiming to surpass pre-pandemic levels as global travel stabilizes. This sustained demand has accelerated the development and renovation of hotels, resorts, and ancillary commercial spaces, often through joint ventures between Cuban state entities and international hospitality operators. Notably, the legal framework requires that foreign investment agreements in tourism be channeled through the Ministry of Foreign Trade and Investment, with compliance oversight by both MINCEX and the Cámara de Comercio de la República de Cuba.
Trade and logistics infrastructure are also focal points for commercial real estate growth. The modernization of ports, logistics hubs, and industrial parks—chiefly within the Mariel zone—reflects Cuba’s push to position itself as a gateway for regional trade in the Caribbean and Latin America. As of 2024, over 60 investment projects operated in ZED Mariel, representing more than $3 billion in committed capital (ZED Mariel). These projects include warehousing, manufacturing, and distribution facilities, all subject to compliance with Cuban environmental, labor, and anti-money laundering regulations enforced by the Ministerio de Justicia.
Looking ahead, the outlook for commercial real estate in Cuba through 2025 and beyond hinges on continued regulatory reforms, the pace of U.S. sanctions relief, and the resilience of the tourism sector. While investor due diligence remains complex due to Cuba’s unique legal landscape and compliance requirements, the country’s ongoing infrastructure investments and the gradual liberalization of select sectors point to a cautiously optimistic trajectory for commercial property development.
Prime Locations: Emerging Hotspots and Development Zones
Cuba’s commercial real estate sector is undergoing significant transformation, driven by regulatory reforms and targeted development initiatives in prime locations. While the Cuban government maintains a centrally planned economy, recent updates to property and foreign investment laws are gradually enabling new commercial ventures, particularly in designated development zones and tourism corridors.
The most prominent hotspot is the Mariel Special Development Zone (ZED Mariel), located west of Havana. Established under Decree Law No. 313, ZED Mariel offers tax incentives, streamlined customs procedures, and guarantees for foreign investors. As of 2024, the zone attracted over 60 investment projects totaling more than $3 billion, with commercial real estate developments including logistics centers, light manufacturing, biotechnology parks, and warehousing. The Cuban government has prioritized ZED Mariel for expanded infrastructure and international partnerships through 2025 and beyond, aiming to create a regional hub for trade and industry (ZED Mariel).
Tourism corridors remain vital to commercial property activity. Havana’s historic center—a UNESCO World Heritage site—continues to see restoration and adaptive reuse of colonial-era buildings for hotels, restaurants, and retail. In Varadero and Cayo Santa María, resort and mixed-use developments are planned or underway, often via joint ventures with foreign hotel groups. The Ministry of Tourism’s investment portfolio for 2024–2025 highlights over 100 projects, including new hotels, marinas, and leisure complexes. These zones benefit from preferential legal regimes for foreign investment, including long-term land use rights and profit repatriation guarantees (Law No. 118).
- Havana: Focus on luxury hospitality, office renovations, and retail expansion, especially in Old Havana and the Malecón waterfront.
- Mariel: Industrial parks, logistics hubs, and biotechnology facilities, leveraging proximity to the deepwater port.
- Varadero & Keys: Resort complexes, commercial centers, and entertainment venues tied to government tourism strategies.
Compliance remains rigorous: all transactions require approval from the Ministry of Foreign Trade and Investment (MINCEX), and foreign investors must partner with Cuban entities or joint ventures. Commercial leases and land use rights are typically granted for up to 99 years, but outright sale of land remains prohibited (Law No. 118).
Looking ahead to 2025 and the next few years, the outlook is cautiously optimistic. Authorities are expected to further streamline approval processes and expand incentives in strategic locations. However, compliance with U.S. sanctions, local regulations, and complex approval pathways will continue to shape the pace and scope of commercial real estate development (Ministry of Justice).
Key Statistics: Market Size, Vacancy Rates, and Rental Yields
The Cuban commercial real estate sector remains unique in the regional context due to its state-dominated ownership structure and ongoing regulatory reforms. While comprehensive market data is limited by the centralized nature of Cuba’s economy, several key statistics and trends can be discerned from official sources and recent legislative changes.
- Market Size: The vast majority of commercial real estate in Cuba — including retail, office, and industrial properties — is owned and managed by the state through entities such as Ministry of Tourism and Grupo de Administración Empresarial S.A. (GAESA). Foreign investment remains concentrated in the tourism and hospitality sectors, where joint ventures with state companies are permitted under Law No. 118 on Foreign Investment. As of 2024, over 110 joint ventures and mixed companies operated in Cuba, primarily in tourism and associated commercial real estate. The hotel segment, a major driver of commercial development, accounted for over 80,000 rooms by late 2023, with ongoing expansion projects led by foreign partners (Ministry of Tourism).
- Vacancy Rates: Precise vacancy statistics are not regularly published by Cuban authorities. However, the National Office of Statistics and Information (ONEI) annually reports hotel occupancy rates, which serve as a proxy for certain commercial asset classes. In 2023, the national hotel occupancy rate was 36.8%, reflecting ongoing challenges from reduced international tourism and economic constraints. Office and retail space vacancy rates are inferred to be higher in less tourist-oriented provinces, as economic activity remains subdued outside of Havana and key resort areas.
- Rental Yields: Official data on commercial rental yields is not disclosed, as most assets are not transacted on an open market. For foreign investors in joint ventures, returns are realized through profit-sharing agreements rather than traditional rental yields. According to Law No. 118, profit repatriation is permitted subject to compliance, but tax and administrative costs remain significant factors affecting net yields.
- Outlook: The market outlook for 2025 and beyond depends heavily on regulatory reforms and the pace of foreign investment approvals. The government’s 2023–2027 economic plan emphasizes further opening in select sectors, but material changes to property rights for non-state actors are not anticipated in the near term (National Assembly of People's Power). Commercial activity is expected to remain concentrated in tourism-linked developments, with gradual expansion conditional on external economic conditions and evolving compliance requirements.
Challenges: Political, Legal, and Currency Risks
Cuba’s commercial real estate sector faces significant challenges rooted in the country’s political, legal, and currency environments. These factors create a complex landscape for both domestic and foreign investors, shaping the sector’s progress through 2025 and the foreseeable future.
Political and Regulatory Environment: The Cuban government retains tight control over property ownership and land use. While reforms since 2011 have permitted limited private enterprise and foreign investment, all land remains state-owned, with property rights conveyed through long-term leases or usufruct arrangements. Foreign investment in commercial real estate must be conducted via joint ventures with state entities, and every project requires approval from the Ministerio del Comercio Exterior y la Inversión Extranjera (MINCEX). The approval process is lengthy and subject to shifting political priorities, often delaying or deterring investment.
Legal Framework and Compliance Risks: Cuba’s legal system, based on civil law with strong socialist characteristics, lacks transparent, codified rules for commercial real estate transactions. Investors face legal uncertainty over contract enforcement, dispute resolution, and repatriation of profits. The 2014 Foreign Investment Law (Law No. 118) provides some guarantees for foreign investors, such as protection from expropriation and tax incentives, but it also reserves broad discretionary powers for the state. Any expropriation claims are generally handled through Cuban courts, with no recourse to international arbitration unless explicitly stipulated in the investment agreement. Compliance with anti-money laundering and anti-corruption rules, overseen by the Banco Central de Cuba, is mandatory but implementation standards may differ from international norms.
Currency and Financial Risks: The dual currency system was officially ended in 2021, but currency instability remains a substantial risk. Transactions in the commercial real estate sector are typically denominated in Cuban Pesos (CUP), which are subject to inflation and volatile exchange rates. Foreign investors may face challenges in converting earnings to hard currency and repatriating profits due to strict currency controls. The ongoing economic embargo and restricted access to international banking channels add further complications to cross-border financial operations and increase compliance burdens.
Key Statistics and Outlook: According to the Banco Central de Cuba, annual foreign direct investment flows remain well below government targets, with real estate projects accounting for a modest proportion of approved investments. Despite ongoing efforts to attract capital, the uncertainty in legal protections, political discretion, and persistent currency risks are expected to continue constraining large-scale commercial real estate development through 2025 and beyond.
Future Outlook: Projections for 2025–2030
The future outlook for commercial real estate in Cuba between 2025 and 2030 will be shaped by continuing regulatory reforms, evolving foreign investment policies, and the country’s ongoing economic transformation. Although Cuba’s commercial real estate sector is still tightly regulated, recent years have seen incremental legal changes aimed at attracting foreign capital and modernizing key infrastructure.
One pivotal development is the sustained implementation of Law No. 118 on Foreign Investment, which provides a framework for joint ventures and wholly foreign-owned enterprises, especially within Special Development Zones such as Mariel. This legislation has enabled select foreign investors to participate in the development of office parks, hotels, and logistics centers, albeit under strict government oversight. The Ministry of Foreign Trade and Foreign Investment continues to update its portfolio of investment opportunities, with commercial properties in tourism, retail, and logistics ranked as national priorities for the coming years.
Compliance remains a central consideration. Foreign participation is generally limited to joint ventures with Cuban state entities and subject to approval by the Chamber of Commerce of the Republic of Cuba. The government has also heightened its focus on anti-money laundering and transparency standards, consistent with Cuba’s engagement with regional compliance frameworks. Legal due diligence and robust risk management are thus essential for any new entrants or expanding entities.
Statistically, the commercial real estate market is expected to show modest growth from a low baseline. According to the National Office of Statistics and Information, foreign direct investment in real estate has represented a small but growing segment, with a particular concentration in the tourism sector—hotels and mixed-use developments. The government’s 2025–2030 development agenda projects an increase in hotel capacity, modern retail spaces, and logistics facilities, with a target of over 12,000 new hotel rooms and a significant expansion of retail square footage in urban centers by 2030.
- Accelerated investment is projected in the Mariel Special Development Zone, which serves as a commercial and logistical hub.
- Hotel chains and foreign hospitality investors are expected to expand their footprint, contingent on continued regulatory liberalization.
- Retail and mixed-use developments will gradually increase, driven by the government’s intent to diversify sources of hard currency and stimulate urban revitalization.
Overall, the period from 2025 to 2030 will likely witness gradual but significant changes in Cuba’s commercial real estate landscape, contingent on policy continuity, improved compliance infrastructure, and the sustained appeal of select sectors to international investors.
Strategic Recommendations for Investors and Developers
The commercial real estate landscape in Cuba is undergoing gradual transformation as the government continues to implement economic reforms and selectively opens the market to foreign investment. For investors and developers considering entry or expansion in 2025 and beyond, a cautious and well-informed approach is critical. Below are strategic recommendations based on recent legal changes, compliance requirements, and market developments.
- Understand the Legal Framework: Foreign investment in Cuban commercial real estate remains highly regulated. The principal law governing foreign investment is Law No. 118 (Ley de la Inversión Extranjera), which permits foreign participation primarily through joint ventures or international economic associations, notably in sectors prioritized by the state such as tourism, logistics, and renewable energy. Foreign direct ownership of land is generally not allowed; instead, investors typically enter into long-term lease agreements or joint venture arrangements with Cuban entities. It is advisable to closely review the latest provisions and decrees published by the Gaceta Oficial de la República de Cuba and consult with the Ministerio de Justicia for up-to-date legislative guidance.
- Align with Government Priorities: The Cuban government’s 2024–2028 national development plan prioritizes foreign investment in hospitality, port infrastructure, and logistics hubs. Investors should target projects in special development zones such as the Zona Especial de Desarrollo Mariel (ZED Mariel), which offers tax incentives, import duty exemptions, and more streamlined approval processes, as detailed on the Zona Especial de Desarrollo Mariel official site.
- Compliance and Due Diligence: All investment proposals must undergo rigorous approval by the Ministerio del Comercio Exterior e Inversión Extranjera (MINCEX). Investors should prepare for extensive due diligence, including anti-money laundering checks and demonstrating technological or managerial value-add. Ongoing compliance with local labor laws, environmental regulations, and reporting standards is strictly enforced.
- Monitor Currency and Financial Risks: Cuba’s dual currency system was unified in 2021, but currency volatility and limited convertibility of the Cuban peso (CUP) persist. Financial planning should account for potential delays in profit repatriation and the impact of U.S. sanctions, which continue to complicate cross-border transactions and access to international banking.
- Market Outlook and Entry Timing: The commercial real estate sector is expected to see moderate growth through 2027, propelled by renewed tourism and logistics investments, but hindered by infrastructure deficits and ongoing external constraints. Early engagement with Cuban partners and authorities, and flexibility to adjust to evolving regulatory conditions, will enhance long-term prospects.
Careful navigation of Cuba’s regulatory environment, partnership with state entities, and alignment with national priorities are essential for successful investment in Cuban commercial real estate through 2025 and beyond.
