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Special Report OC-26-09, Verification of compliance with Act 18 of 1975 by government entities in fiscal year 2023-24.

October 7, 2025
Portada del Informe Especial OC-26-09, Verificación sobre el cumplimiento de la Ley 18 de 1975, por parte de las entidades gubernamentales, en el año fiscal 2023-24.

Special report reveals repetitive non-compliance by entities in the processes of registering and submitting contracts to the Office of the Comptroller

The Office of the Comptroller of Puerto Rico (OCPR) published the result of a verification of compliance with Act No. 18 of October 30, 1975, Regulation 33 and the circular letters that the Office issues in this regard. The work had as its objective to verify compliance with the processes related to the submission and registration of contracts and their amendments in the OCPR Contract Registry application.

The results reveal that 96% of the entities evaluated completed the registration process. However, 4% of the entities did not complete the registration of 23 contracts, for which they are classified as registration created (although not completed). This percentage is divided into 15 contracts for the amount of $65.4 million to be received and 8 contracts for the amount of $35,600 to be paid.

This repetitive situation undermines the purpose of Act 18 of 1975, affects transparency and limits access to public information. The Report recommends to the Office of Government Ethics that it carry out the processes it deems pertinent regarding this result.

The Report, of four results, notes that 43% of the government entities evaluated did not respond to the objections to the contracts within the established time of 30 days. In the Registry application, 1,525 contracts totaling $191.2 million to be paid and $5.2 million to be received were identified with objections pending resolution for up to 18 months.

This fact causes the Office not to have the contracts correctly as the law provides and
that they are not accessible to citizens as public documents within the time required by law and regulation. A similar situation had been commented on in Special Report OC-25-30 of October 8, 2024.

We identified that 59% of the principal officials of 278 entities certified under oath incorrect information about the total of contracts granted during fiscal year 2024. The verification disclosed discrepancies of up to 418 contracts too few in the application and up to 328 contracts too many in the annual certification.

This situation may cause disbursements to be made contrary to what is established in Act 18 of 1975 and to the jurisprudence that establishes that no service or consideration that is the object of a contract may be demanded nor any disbursement of public funds made until it has been registered and submitted to the OCPR.

As of June 30, 2025, 26% of the entities had not complied with submitting the 2024 Annual Certification to the OCPR, and 12% submitted it up to three months late, contrary to what the current regulation provides.

The Report recommends to the principal officials of the entities that they ensure compliance with the current law and regulation regarding addressing the objections within 30 days and that the liaison officers complete the registration processes. In addition, they must submit to the OCPR the annual certifications within the established time with the correct information about the number of contracts and amendments of the entity.

The Office also recommends to the entities that they review the certifications submitted and ensure that those contracts that were never registered are registered immediately.

This Special Report covers the period from July 1, 2023 to June 30, 2024.

The Special Report OC-26-09 can be obtained on our website: www.ocpr.gov.pr.

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