Converting a condominium into a condohotel: what Act 11-2026 requires

It is the route the law opened for a building that is today an ordinary condominium — Horizontal Property Regime — to become a condohotel. It is not one person’s errand: Article 9.-103 puts it in the hands of all the owners, and it then has to be authorised by the Permit Management Office or the municipality.

Owners of buildings held under the Horizontal Property Regime. The article speaks of “all the owners”, and approval follows the Consejo de Titulares decision-making procedure per the Master Deed and the Condominium Act.

• That the property be held under the Horizontal Property Regime, and that it be all the owners who convert it.Verified against the official source
• That the conversion be approved through the Consejo de Titulares decision-making procedure, per the Horizontal Property Regime’s Master Deed and the Puerto Rico Condominium Act or any successor act.Verified against the official source
• That a deed of conversion and dedication to the Condohotel regime be granted.Verified against the official source
• That the conversion and dedication be authorised by the Permit Management Office or its successor, or by the municipality where the property is located where the municipality has that authority delegated.Verified against the official source

• The deed of conversion and dedication to the Condohotel regime. The law publishes no document list beyond that, and expressly exempts the conversion from Article 4.-109’s requirements, including that plans accompany the Master Deed as complementary documents, except as needed to evidence changes in areas.

1. 1

   Step 1: It takes all the owners

   The article opens with those words: “All the owners of buildings held under the Horizontal Property Regime may convert it to the Condohotel regime.” It is the requirement that decides whether conversion is even possible in your building, and it is worth looking at before anything else.

2. 2

   Step 2: Approval follows the Consejo de Titulares rules

   The conversion shall be approved through the Consejo de Titulares decision-making procedure as established in the Horizontal Property Regime’s Master Deed and the Puerto Rico Condominium Act or any successor act. That is: Act 11-2026 invents no new voting procedure, it defers to the one already governing your condominium. We did not read the Condominium Act, so we do not describe that procedure here.

3. 3

   Step 3: Consent can be given in writing, without a meeting

   The new Article 9.-104 allows that, unless the Master Deed or the law says otherwise, any action requiring the owners’ vote or consent may be taken without a meeting, without prior notice and without a vote, if the written consent is signed by the Administrator and the required number of owners, and delivered to the Administrator or their Agent. It works by hand, by certified mail with return receipt, by private delivery service with signed receipt, or by electronic means if the Administrator acknowledges receipt by that same means. Electronic signature works, under Act 148-2006.

4. 4

   Step 4: Consents have an expiry

   Every written consent carries each owner’s signing date, and the proposed action is not valid unless signed by the required owners and delivered within the term set in the Master Deed or, failing that, within ninety (90) calendar days from receipt of the first signed consent. If the action is approved by fewer than all owners, notice of the approval is sent to them.

5. 5

   Step 5: Then it goes to OGPe or the municipality

   The conversion and dedication shall be authorised by the Permit Management Office or its successor, or, where the municipality has that authority delegated, by the municipality where the property is located. The owners’ decision does not suffice on its own.

6. 6

   Step 6: What the law saves you along the way

   The article lists four reliefs: the conversion is exempt from Article 4.-109’s requirements, including that plans accompany the Master Deed as complementary documents for filing at the Property Registry, except as needed to evidence changes in areas; the deed requires no new appraisal of the property; no value need be assigned, so it is treated as a public instrument without value; and it does not require regrouping or merging the filial properties into the matriz property, but is done by amendment to the regime’s initial registration.

Authorisation is sought from the Permit Management Office or its successor, or from the municipality where the property is located when it has that authority delegated. The deed of conversion and dedication is granted before a notary and recorded at the Property Registry.

• Believing a majority is enough: Article 9.-103 speaks of all the owners.
• Thinking the owners’ decision settles it: the conversion still has to be authorised by OGPe or the municipality with delegated authority.
• Signing a consent without watching the date: consents lapse per the Master Deed’s term or, failing that, ninety calendar days from the first one signed.
• Assuming a new appraisal or full plans are needed: the article expressly exempts both, save for evidencing changes in areas.
• Taking this guide as a summary of all of Act 11-2026: it covers the conversion and the written consent, not the whole regime.

These are the government pages this guide is based on.

• Oficina de Gerencia de Permisos (OGPe)

  OGPe

  bvirtualogp.pr.gov