Registration of Shareholders
Starting on January 1st, 2019, it is required for corporations to report with the Revenue Service (Ministerio de Hacienda) a list of shareholders who have more than 15% of the shares of the company. The report must be provided between March 1st and December 31st 2019 according to the following schedule.
It seems the registration requirement has been postponed until September of 2019
https://www.hacienda.go.cr/noticias/14992-registro-de-accionistas-iniciara-en-setiembre
Indeed
https://news.outlierlegal.com/blog/2019/02/25/the-registration-of-shareholders-has-been-delayed/