The norm, in detail
San Juan: 80/60 local mining procurement
Provincial Act 2827-M (San Juan, Official Gazette 16-Jul-2026)
in forcePROVINCIAL
RIGI and investment
What changed and who it applies to
What changed
Act 2827-M requires mining companies to file two plans as sworn statements: a 'Local Employment Development Plan' targeting 80% local workers —measured on the average annual payroll and counting both the miner's own employees and the indirect staff of its contractors (sec. 5)— and a 'Local Supplier Development Plan' targeting 60% of the total annual amount of purchases and contracts tied to the project, measured across the miner's direct purchases and its indirect ones through contractors (sec. 9). The supplier plan is updated every two years. It creates the RE.PRO.MIN, San Juan's Mining Suppliers Registry, under the Ministry of Mining: a single, official, public and freely searchable registry (sec. 11). The piece that turns the registry into the market's real gate: for the 60% count, 'only contracts with suppliers registered and holding a valid certificate in RE.PRO.MIN shall be computable' (sec. 9). The quota is not a hard floor: contracts for which no local offer is available on reasonable terms of quality, technical capacity, volume, timing or market price may be excluded from the calculation base, with a reasoned technical justification (sec. 9). verif · Jul 16, 2026 ↗
In force
In force since 07/16/2026: sec. 30 provides that 'this act enters into force upon its publication', and publication is dated 16-Jul-2026. The compliance windows run from that date (sec. 29): 60 calendar days for miners and contractors that ALREADY had an employment or supplier plan filed under an approved Environmental Impact Statement (DIA) to adapt it to secs. 5 to 10; 90 calendar days for those already operating without a plan; 90 days from obtaining the respective DIA for new projects or for those changing stage or phase; and 90 days to report voluntary community development projects under way. The Enforcement Authority may grant reasoned extensions. The implementing regulation is still pending. verif · Jul 16, 2026 ↗
Who it affects
Copper/gold/silver miners operating in San Juan at any stage (prospecting, exploration, construction, exploitation, closure and post-closure; sec. 249 of the Mining Code), their contractors and supplier SMEs. Requirements for a supplier to enter and stay in the RE.PRO.MIN, all of which must be met SIMULTANEOUSLY (sec. 12):(1) an operating establishment licensed in its own name, with a real domicile in the community of influence or in the rest of the province;(2) legal and tax domicile in that same jurisdiction;(3) at least ONE of two roots criteria: (a) ≥51% of the share capital —or of the votes that form the corporate will— held by persons with local legal and tax domicile, evidencing local ultimate beneficial owners where the partners are legal entities (sole-proprietor firms are exempt from this item), or (b) for industrial goods production or service provision, that the main establishment be its exclusive property and located in the province;(4) employing at least 80% local workers on the average annual payroll of contracts tied to San Juan mining projects;(5) keeping all of its vehicles registered in San Juan and paying the provincial vehicle registration tax on them. Seniority, in two tiers: 24 months to qualify as a local supplier of the community of influence, 12 months for the rest of the province. Construction firms must also be listed in the Provincial Registry of Builders with no less than 24 months of seniority (sec. 13). Local worker (secs. 7 and 8): real domicile recorded in the national ID and evidenced effective residence, with a minimum of 24 months of continuous residence immediately prior to hiring for the worker from the community of influence and 12 months for the provincial one. A five-tier ORDER OF PREFERENCE, the same for employment and for purchases (secs. 6 and 10): 1) department of direct influence, 2) indirect influence as recognised in the DIA, 3) rest of the province, 4) rest of Argentina, 5) abroad. Penalties (sec. 20): warning, formal notice, a fine of up to 200,000 tax units, suspension of certificate issuance, suspension of the registration from 30 days to 1 year, temporary disqualification and cancellation of the registration; the fine is halved if cured within 10 days. Incentive for the miner (sec. 25): a company that meets both thresholds simultaneously and sustains 80% employment and 60% purchases over an annual period —provided that, within those percentages, at least 30% of workers and 20% of suppliers come from the Community of Influence— obtains a tax credit certificate against provincial taxes, transferable in whole or in part and on a one-off basis to suppliers registered in RE.PRO.MIN. It requires legal and tax domicile in San Juan, or a commitment to relocate it within 12 months, on pain of forfeiture and repayment with interest. verif · Jul 16, 2026 ↗
The norm
Ley Provincial 2827-M of San Juan (entry LP-2827-M in the Provincial Legal Digest, mining subject area), passed by the San Juan Chamber of Deputies (single-chamber legislature) in its Sixth Ordinary Session of Jul 2, 2026 with 33 votes in favor and 2 against, and published on Jul 16, 2026. It runs to 32 articles. Its art. 31 repeals Ley 1208-M, the previous local procurement law. Initiative of the provincial Executive Branch (Governor Marcelo Orrego). verif · Jul 16, 2026 ↗
Our reading
It is now standing law and it has a number: Act 2827-M, in force since 16-Jul-2026. San Juan replicates the Salta moat over 24.9% of the RIGI portfolio this observatory measures and vets —USD 22,828 M out of USD 91,576 M across 28 projects— estim, and the piece that decides the business is not the quota but the registry: for the 60% count, *only* suppliers registered and holding a valid certificate in the RE.PRO.MIN are computable verif sec. 9. Provincial homologation stops being a competitive edge and becomes the condition of existence before the copper mega-miners (El Pachón, Los Azules, Vicuña). The nuance that softens the moat is narrower than it looked: the miner is not released from the 60% because a local supplier is uncompetitive — it may only take that purchase out of the calculation base, and it must justify this on technical grounds verif sec. 9. And the real barrier to entry for the San Juan SME is not the 51% of capital but the 24-month seniority in the department of influence verif secs. 12 and 13: whoever was not there does not make it in time for this wave. It remains a governor's policy, not part of the national programme — provincial protectionism in tension with Milei's opening. What has to be watched is no longer enactment but the implementing regulation and the effective opening of the RE.PRO.MIN: Act 1208-M, which this one repeals, was never applied, and the deadlines of sec. 29 fall due on 14-Sep and 14-Oct 2026 verif. thesis
Where it lands, province by province1
San Juan It is the entry key to the spending of the three copper mega-miners. For a purchase to count towards the 60% quota, the supplier must be registered and hold a valid certificate in the RE.PRO.MIN (sec. 9, consolidated text of the Digest): provincial homologation stops being a competitive edge and becomes a condition of existence before El Pachón, Los Azules and Vicuña. The real barrier for the San Juan SME is not the 51% of capital but the 24-month seniority in the department of influence (secs. 12 and 13): whoever was not there does not make it in time for this wave. And the nuance that softens the moat is narrower than the press reported: the miner is not released from the 60% because the local supplier is expensive — it may only take that purchase out of the calculation base, and it must justify this on technical grounds. favorable verif
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Ignacio Aredez· Chief analyst
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