Cuba has not adopted national legislation based on or influenced by the United Nations Commission on International Trade Law (UNCITRAL) Model Law on Electronic Signatures.

Under Arts. 1.1, 2, 6 and 8–10 and the Annex to Resolution No. 166/2024, non-state economic operators must export goods and services through designated authorised exporting entities. The operator submits the export request to an authorised intermediary, which approves the foreign customer, prepares the offer, concludes the transaction, and agrees the export price.
For merchandise exports, Arts. 1–3, 9–17 and 25–29 of Resolution No. 38/2023 provide that exporting entities must be registered in the National Registry of Exporters and Importers and hold the relevant foreign-trade powers and an approved export nomenclature. Under Resolution No. 38/2023, those powers are granted by the Ministry of Foreign Trade and Foreign Investment (MINCEX) to state enterprises and wholly Cuban-owned commercial companies. Goods falling outside an entity’s approved nomenclature may be exported only under a prior occasional export permit. Non-state operators, therefore, cannot export directly and must rely on a designated intermediary that also holds the necessary registration, foreign-trade powers and product coverage.

According to the Ministry of Communications, a process is implemented that requires a homologation certificate issued after control in testing laboratories in Cuba for ICT goods. Although there is no legal framework establishing the procedures for testing, control and certification of these goods, the Ministry requires companies to pass certain tests to obtain a homologation certificate for each product or service of telecommunication and computer equipment. There are two accredited laboratories in Cuba. The first one performs tropicalisation tests. The second one handles the testing of equipment connected to telecommunications networks that use the spectrum. Through this certification process, the Ministry of Communications regulates and controls the technical and operating specifications of the systems, equipment, and devices to be used in telecommunications and computer networks in order to guarantee the interconnection between public networks, as well as the interoperability of services.

Art. 19 (e) of Resolution No. 179/08 requires that Internet access service providers must ensure that software with cryptographic systems or encrypted file transfer is not used.

Art. 21.8 of Resolution No. 99/2019 stipulates that applicants for an operating licence for private data networks must provide information concerning the cryptographic protocols and algorithms used to protect communications, which must have been authorised by the competent authority. Art. 27.l further requires holders to obtain approval for the use of any supported application or service that employs cryptographic methods for protecting transmitted information, with holder referring to the person authorised by the Ministry of Communications to provide private data transmission services through a private telecommunications network. Art. 2 defines a private data network as a telecommunications network whose infrastructure is installed within a single locality or across multiple geographically distinct localities interconnected by telecommunications links for the purpose of meeting the data service needs of its holder.

Although Law 118 on foreign investment does not restrict investments in the online commerce sector, the state company CIMEX, with its company Tuenvio.cu, is the only platform that offers online purchases in Cuba.

Art. 12 of Decree-Law No. 22/2020 establishes a quantitative limitation on non-commercial imports by providing that the total value of the goods contained in each consignment may not exceed USD 200.

In June 2020, Cimex Corporation notified all users of the "tuenvio.cu" e-commerce platform via email about new regulations for online purchases. According to these updated regulations, users of the Tuenvio.cu platform, which facilitates e-commerce in Cuba, is limited to one purchase per day for food and toiletries combos. These restrictions were outlined in Cimex's online shopping guide, which is available on the Tuenvio.cu platform, ensuring customers were aware of the daily purchase limits.

There are no formal licensing requirements in Cuba in the electronic commerce sector. However, Cuba has only one online trading platform called Tuenvio.cu, which is managed by the state-owned company CIMEX. This, indirectly, represents a restriction that excludes foreign companies that want to seek licenses to manage an electronic commerce platform.

According to Art. 8 of Decree-Law 370, the Ministry of Communications issues licenses to providers of services related to the computerisation of Cuba so that they can project, install, maintain and market computer programs and applications according to the conditions set forth in the law.

Resolution No. 127/2019 establishes the regulations governing the organisation, operation, and issuance of operating licences for providers of public internet hosting services in the national territory. Art. 5 provides that the licence is granted by the "Unidad Presupuestada Técnica de Control del Espectro Radioeléctrico del Ministerio de Comunicaciones" (UPTCER).

Cuba has not joined any agreement with binding commitments to open transfers of data across borders.

According to Resolution No. 125/2019, the country requires computer programs and applications to be registered before commercialisation. This is managed through a registration system that covers domestically developed and imported products, as well as the natural and legal persons responsible for their development or commercialisation.
Under Arts. 2, 3 and 5, registration must be completed through the Technical Budgetary Unit for Radio Spectrum Management of the Ministry of Communications (UPTCER) before the product is placed on the market.
Registration remains valid for five years and must be renewed within 45 days preceding its expiry. Under Art. 10, failure to renew results in cancellation of the registration and prohibits further commercialisation of the program or application. Art. 11 confirms that the same obligations apply to foreign developers and commercialisers.

Law No. 149/2022 on Personal Data Protection establishes a comprehensive framework for the regulation of personal data in Cuba. While the Law does not create a dedicated data protection authority, it assigns responsibility for ensuring compliance to the Ministry of Justice (MINJUS).

Under operative paragraphs Second, Fifth and Seventh of Resolution No. 144/2021, entities authorised to export or import goods, services or both must register in the National Registry of Exporters and Importers within 30 working days of the legal instrument granting such authority. The authorising certificate records the entity’s authorised activity and, where applicable, the nomenclature of products it is authorised to export, import or both. The Registry is expressly classified as a central registry of permits and licences.
In addition, foreign exporters seeking to supply the Cuban market must reportedly register as authorised suppliers with the relevant Cuban purchasing agency before that agency may formally request or accept quotations from them. It is reported that this separate supplier-registration procedure is time-consuming and bureaucratic, normally taking three to four months and requiring company documents to be translated into Spanish, authenticated by a Cuban embassy and, in some cases, legalised or notarised in Cuba or the exporter’s home country. Although registration itself is free, exporters incur translation and authentication costs, and the registration expires after two years without business activity, requiring the procedure to begin again.