Government fees: the Salario Mínimo Promedio fraction system

1. Key takeaways

Government fees for devices in Honduras are not fixed amounts but a fraction system: the base is the Salario Mínimo Promedio (average minimum wage), and fees are set as fractions of it by activity and by matter. For the premises licence (Acuerdo No. 003-2021, La Gaceta No. 35,552, 2021-03-23, item CUARTO), the precio base is accumulated by activity first: Acondicionar on-site 1/40, online 1/55; Almacenar/Importar/Distribuir on-site 1/35, online 1/45; Comercializar/Fabricar on-site 1/25, online 1/35; where several activities are operated, the base equals the sum of them all. New licences and renewals take 60 working days at a fee equal to the base (table 2); activity-related modifications take 20 working days priced under table 1 (point 3); other modifications take 20 working days (table 3, with a change of premises name at on-site 1/35, online 1/45); the expedited tiers are 40 days at 3/2×, 20 days at 2×, 10 days at 3× the base (table 4). Fees for registration matters are set by Acuerdo No. 012-2020 (La Gaceta No. 35,299, 2020-06-30), covering 11 classes of matters.

2. Legal basis

Two fee instruments govern the sector: Acuerdo No. 003-2021 for premises and transport licences, and Acuerdo No. 012-2020 for registration-type matters. The table below consolidates the provisions, deadlines and fee fractions.

3. Expert insights

Insight 1: a fraction system means government fees float automatically with the annual adjustment of the minimum wage. Since the base is the average minimum wage, every fee expressed as a fraction moves as soon as the wage is adjusted. This directly refutes the claim that Honduran government fees equal some fixed dollar figure; any quotation in a fixed foreign-currency amount lacks an official source. GRZAN confirms amounts exclusively through the payment notice issued by ARSA at the time, and treats everything else as a practical estimate only.

Insight 2: the online channel is genuinely cheaper, and the difference is computable. In the two fee sets of table 1, Importar is on-site 1/35 and online 1/45, and Comercializar is on-site 1/25 and online 1/35. Under multi-activity accumulation (point 1 of the explanatory notes), this difference scales with the number of activities, making the choice of channel a quantifiable cost decision.

Insight 3: for registration fees the official text shows the matters but not the amounts. Item PRIMERO of Acuerdo 012-2020 lists 11 classes of matters in detail, but the fee tables of items SEGUNDO to DÉCIMO are published as images in the official PDF, with no searchable text layer. Except for item SÉPTIMO (special authorisation for non-government bodies, 5 working days, 1/9), the remaining amounts cannot be verified from official text. This is the single point in this market that most demands honest labelling: no fabrication; the payment notice governs.

Insight 4: expediting has a price and is conditional on institutional intake capacity. Table 4 gives the three tiers of 40 days at 3/2×, 20 days at 2× and 10 days at 3×, and the text states at the same time that they depend on the institutional capacity to accept and on the applicant’s request. Expedited processing is not an option granted on demand, and its highest cost is 3 times the regular fee.

Insight 5: there is an update gap between the fee schedules and the new regulation. Acuerdo 0631-ARSA-2023 (published 2024-09-21) extended licence validity to 2/4/6 years, while the Vigencia column of table 2 of Acuerdo 003-2021 (published 2021-03-23) still states 2 years; registration, modification and exemption matters are neither covered by 003-2021 nor verifiable in amount under 012-2020. This staggered overlap in time and scope is a risk that must be managed explicitly in budgeting.

4. Practical recommendations

• Model the budget in fractions, not in amounts: take the current average minimum wage as the base, compute the base with the fractions of table 1, and then apply the matter coefficients.
• File everything through the online channel: fees are lower than on-site, and both the 60-working-day deadline of table 2 and the expedited tiers of table 4 apply equally.
• For registration-type matters, take every amount exclusively from the current payment notice issued by ARSA, and cite no fixed amount that has not been verified against official text.
• Use the free institutional correction: after filing, proactively check the data keyed in by ARSA and request correction before the decision notice, to avoid paying again to fix an error.
• Use expedited processing only where a genuine delivery milestone exists, and first confirm ARSA’s current intake capacity; the top tier costs 3 times the regular fee.
• Review once a year whether the fee instruments have been updated, focusing on whether the 4-year and 6-year fees of Acuerdo 003-2021 and the image-based fee tables of Acuerdo 012-2020 have been turned into searchable text in a new instrument.

5. Verification checklist

• □ The current average minimum wage base has been obtained and used for the fraction conversion
• □ The precio base calculated under table 1 has been accumulated over the activities actually applied for
• □ The online channel has been confirmed and the on-site versus online fee difference is in the budget
• □ Current payment notices from ARSA have been obtained for registration-type amounts
• □ Modification matters have been separated into activity-related and other, with fees taken accordingly
• □ Expedited needs and the costs of the 3/2×, 2× and 3× tiers have been assessed
• □ The update status of the fee instruments is on the annual review list

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support for the Honduran market. Our team manages Secretariat of Health (SESAL) registration applications, prepares Spanish-language dossiers, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com

Regulatory information verified as of October 29, 2026.