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Lex Mundi Latin America and the Caribbean: TMT and Cyber Guide

Uruguay

(Latin America) Firm Guyer & Regules

Contributors Diego Baldomir
Federico Pereyra Burghi

Updated 24 Nov 2025
1. What is the current state of the telecommunications market in your jurisdiction? Who are the main players in the market?

The main players in the Uruguayan telecommunications market are:

  • Antel (state-owned): provides mobile, fixed broadband, Pay TV, data services and landline services.
  • Movistar (recently purchased by Tigo): provides mobile and data services.
  • Claro: provides mobile and data services.
2. What is the market share for different services (mobile, broadband, Pay TV, etc.)? E.g. level of penetration for mobile services, fixed broadband, 4G, 5G, and fiber deployment.

According to the Regulatory Unit for Communication Services ("URSEC"), in 2024, Uruguay´s telecommunications market share was distributed as follows:

  • Mobile communications: 43.5%.
  • Fixed broadband: 33.1%
  • Pay TV (subscription TV): 17.1%.
  • Fixed-line telephony: 6.4%.

Key Operators: The Uruguayan telecommunications market is dominated by three major companies: Antel, Movistar (Tigo) (Millicom) and Claro (América Móvil). Antel is the largest operator in most areas of the telecommunications market, particularly in mobile, data and fiber infrastructure, while Movistar and Claro have solid positions in mobile and data services. The market shows a competitive structure, with Antel's leadership strengthened by its national deployment of fiber.

Telecoms overview: Mobile remains the largest revenue earner, at around UYU 28 billion in 2024, with several million active lines and Antel with around 62% of subscriptions. Fixed broadband services (included in data and Internet revenues, for a total of UYU 21.3 billion) continued to expand as Antel launched its extensive fiber-to-the-home network, reaching most urban households. Pay TV revenues reached about UYU 11 billion with around 441,000 subscribers, which continues to show a slow decline as users turn to OTT (over-the-top) streaming services. Fixed telephony continues to diminish in relevance within total sector revenue, generating about UYU 4.1 billion. Overall, Uruguay's telecommunications market remains stable, with overall strong penetration in broadband and mobile, the ongoing evolution of fiber, and the gradual shrinkage of traditional TV and voice services.

3. What are the most relevant trends and challenges in the ICT industry? Are there ongoing developments in areas such as 5G deployment, IoT, satellite services, infrastructure investment, or market consolidation?

The ICT industry in Uruguay is focusing on cloud, fiber, and 5G. Uruguay leads the region in FTTH penetration, allowing for faster fixed and mobile broadband, while Antel has spearheaded a rapid 5G rollout (aiming for about 500 sites). To increase capacity for cloud and AI workloads, Google and others are making significant investments in data centers. URSEC authorized LEO satellite services (Starlink and Amazon), expanding high-speed options for remote locations.

The growing use of AI, cloud, and IoT is increasing demand for data centers, managed services and upskilling.

Securing sustained capital expenditures for network fiber and densification, maintaining competition in light of Antel's market dominance, modernizing spectrum/LEO regulations, and addressing community and environmental concerns regarding large, hyperscale projects are the primary obstacles.

4. What are the main laws governing telecommunications in your jurisdiction? Which authority regulates the telecommunications sector?

The main laws governing telecommunications in Uruguay are Law No. 17,296, Articles 70 to 94-bis, which creates the Regulatory Unit for Communication Services ("URSEC"), the competent authority in charge of the telecommunications sector, and the Decree No. 115/003, as amended, which approved the current regulations on telecommunications licenses.

5. Describe the licensing requirements for the provision of the following services:

The license constitutes the administrative authorization issued by the Executive Power, or, where appropriate, by the URSEC, enabling its holder to provide telecommunications services to third parties or to the general public. 

Article 11 of Decree No. 115/003 establishes the requirements that any interested party must comply in order to obtain a license. The requirements applicable to all applicants include: submission of personal and corporate documentation; a sworn statement declaring awareness of and commitment to comply with all provisions of the regulatory framework governing telecommunications services; a sworn statement by which the applicant undertakes to implement security systems and procedures aimed at safeguarding the confidentiality of communications transmitted through its facilities and equipment, in accordance with the rules of good engineering practice. 

Furthermore, the regulation requires the submission of specific documentation depending on whether the applicant is a natural person or a legal entity, as detailed in Article 11 of Decree No. 115/003. 

The applicant must also satisfy a series of technical requirements, including the submission of a Technical Plan and schedule, as well as an investment plan covering the first two years of operation, and must specify the geographical area of coverage and service provision.

Article 9 of Decree No. 115/003 defines the license categories as well as the rights and entitlements vested in the respective licensees:

  • Class A: Authorizes the operation of a public telecommunications network and provision of telecommunication services technically and legally feasible according to existing legislation, except for pay television services. This license gives the right and the obligation to provide interconnection and to negotiate reciprocal compensation.
  • Class B: Authorizes provisions of telecommunication services using your own network or one owned by another provider.
    • Class B1: Allows for the provision of telecommunication services requiring access to resources of a Class A license holder.
    • Class B2: Allows for the provision of telecommunication services not requiring access to resources of a Class A license holder.
  • Class C: Exclusively authorizes the installation of links, means, and telecommunications systems for their provision or lease to telecommunications service licenses.
  • Class D: Authorizes the provision of subscription television services that require the use of wired or wireless transmission means for content distribution.
6. Are there any foreign ownership restrictions on telecom operators?

There are no general restrictions on foreign ownership of telecom operators in Uruguay. Nonetheless, the application process requires that foreign companies prove compliance with Articles 192 to 198 of Law No. 16.060 in order to obtain a license; for example, they must be registered in the Uruguayan general register of commerce and make all the relevant publications required by the regulation in force.

7. Are service prices regulated or freely determined?

Services prices in Uruguay are currently freely determined by providers.

8. Is regulatory approval required for license transfers or corporate control changes? What are the conditions or requirements?

Yes, Article 15 of Decree 115/003 requires that it is an obligation of licensees to obtain authorization of the Executive Power or URSEC to transfer a license or for any corporate control changes.

9. Are there universal service obligations? If so, what are the applicable rules?

There are no universal service obligations for private actors. At the moment URSEC has as one of its objectives the expansion and universalization of access to telecommunication services.

10. What are the interconnection and access obligations? Net neutrality - Are there obligations to block or filter internet content under specific conditions?

Any provider that seeks to use essential facilities shall be entitled to request interconnection, and the requested provider shall be obliged to grant it on technical and economic terms equivalent to those afforded to third parties and under an open network architecture with technical compatibility. The following facilities shall be made available, as applicable and where technically feasible: call termination, ILD call origination, signaling, ports, co-location (physical or virtual), access to telephony assistance services (emergency services, community services, directory information), transmission of the Calling Line Identification ("CLI"), and billing data with the customer’s authorization. Interconnection shall take place at the point closest possible to the requested provider’s customer, with agreed quality parameters and technical specifications. Prices shall be freely negotiated; failing agreement, URSEC may set them based on long-run average incremental costs ("LRIC"). The Interconnection Decree does not establish obligations to block or filter Internet content; however, in practice, blocks are implemented—for example, against illegal online gambling sites not authorized by the competent authority.

11. How is radio spectrum allocated and managed? What is the process for awarding high-demand mobile frequencies (e.g., auction, tender, on demand)? Is there a secondary market for spectrum (e.g., spectrum trading or leasing)?

Decree No. 114/003 approved the Regulation on the Administration and Control of the Radioelectric Spectrum, by which URSEC is established as the government body in charge of the administration and control of the radio spectrum, and the authority that must grant authorization for its use.

Interested parties can directly request URSEC for a specific spectrum. However, there is a certain spectrum that requires a competitive procedure with the previous authorization of the Uruguayan Executive Power.
There is no secondary market in Uruguay and changes in the spectrum title not approved by URSEC may lead to a cancellation of the authorization.

12. Are national, regional, or municipal authorizations required for installing telecom infrastructure? What are the rules regarding the use of support structures (e.g., towers, poles; sharing of infraestructure)?

The previously mentioned Decree No. 115/003 in Article 6 establishes that installation of telecom infrastructure requires no special authorizations other than those which correspond to using spaces of private or public domain and those relative to environmental, planning or urban security. Therefore, municipal authorizations may be required. Any radioelectric equipment must be homologated by URSEC prior to use.

The use of these structures is regulated by the licenses described in our response to question 5 above.

13. What regulations apply to the deployment and sharing of passive telecom infrastructure?

The previously mentioned regulations in our response to question 12 also apply to this type of infrastructure.

14. Are regulatory authorizations required for the landing and operation of submarine cables?

Yes, interested parties must obtain prior authorization from the Executive Power. Decree 169/023 ordered the creation of the Interinstitutional Advisory Commission for the Review of Applications for the Laying, Operation, and Maintenance of Submarine Telecommunications Cables, which would have under its duties the technical study of applications to lay and operate submarine cables, but it has not been instituted yet.

15. What are the licensing requirements for satellite services (based on the type of constellation)?

To operate satellite services you need a class B license as described in answer to question 5 and thus is subject to the same requirements. Furthermore, satellites must obtain landing rights in order to be used for telecom services.

16. Are authorizations required for ground stations?

Depending on the type of ground stations, the authorization may be granted concurrently with the issuance of the license or be petitioned independently. The radioelectric equipment to be used must be previously homologated by URSEC.

17. Is direct-to-device satellite communication regulated?

In Uruguay, there is no specific regulation; however, as said before, satellites must obtain landing rights authorization from URSEC.

18. Are telecommunications devices subject to homologation or type approval?

Yes, any radioelectric equipment is subject to homologation by URSEC before being imported, and its use is authorized on the national territory.

19. What is the current state of the audiovisual market in your jurisdiction? Who are the main players? What is the market share of Pay TV, OTT platforms, and traditional broadcasting (radio and free-to-air TV)? What are the main regulatory or...

Key market players in Uruguay that provide Pay TV services include Montecable, TCC, Nuevo Siglo, DirecTV, Cablevision, Flow and Multiseñal.

There is no official data on the market share of OTT platforms and traditional broadcasting, but the data on Pay TV shows a steady decline in clients and a starting decline in revenues.

The main issue the industry is facing at the time is that OTT platforms are becoming increasingly widespread, as traditional services lose market share, but at the same time, OTT platforms lack the regulation that nowadays applies to traditional audiovisual mediums, such as taxes, content, licenses, regulations and the like.  

20. What are the main laws applicable to audiovisual communication services? Which authority regulates this sector?

The main law is Law No. 20.383, which regulates audiovisual services in Uruguay, and its regulatory decrees.

The authority in charge of regulating the telecommunication sector in Uruguay as a whole is URSEC.

21. What types of licenses are available? What is the procedure to apply for a license? What is the duration of audiovisual licenses?

For audiovisual communication services broadcasting content via radio, free-to-air television, and Pay TV, Law No. 20.383 establishes only one type of license needed to provide the service, although its content may vary depending on the application, for example, the license can authorize providing the service at the local, departmental or national level.

Providers that seek to utilize the radio spectrum to broadcast audiovisual content will need a license to distribute audiovisual content, a telecommunications license, and authorization to use a designated spectrum or frequency.

The procedure is a public competitive process that the Executive Power may initiate every five years, provided there are radioelectric channels available to use.

Licenses are granted for 15 years and can be renewed for 15 years indefinitely if the license holder applies for renewal before the last 12 months of the license and verifies certain legal requirements.

22. Is regulatory approval required for license or share transfers? What are the conditions or requirements?

Yes, approval is required for both license and share transfers. This approval is granted prior technical study by URSEC. The authorities will examine the same requisites that the law establishes to grant the license to determine the transfer approval.

23. Are there restrictions on foreign investment? Are there exceptions? Are there any incompatibilities or cross-ownership restrictions?

Uruguay maintains an open, national‑treatment regime for foreign investment with no economy‑wide caps, and in telecommunications, there are no foreign ownership limits in the licensing regulation; foreign‑owned operators may hold licenses subject to standard approvals for changes of control, spectrum administration, and the separate constraint of ANTEL’s exclusivity in national fixed telephony. The audiovisual sector is the exception; the 2024 statute imposes nationality and anti‑foreign‑control requirements on license holders, bans foreign control and linkage to foreign‑capital entities, and allows only a limited exception for pay‑TV stock companies whereby at least 51% of voting capital must be in qualifying Uruguayan hands and foreign shareholders cannot exercise control. 

The Audiovisual Law (No.20.383) also establishes hard concentration caps and explicit incompatibilities across licenses, with binding regulatory review and cure periods, while simultaneously permitting convergence by allowing cable operators to seek internet‑access licenses. Foreign investors can therefore deploy 100% ownership in telecoms but must structure for domestic control in audiovisual diffusion.

24. Are there limits to the number of licenses that can be held?

According to Article 16 of Law No. 20,383, which regulates the activity of audiovisual content distribution services by broadcasting or subscription, a private natural or legal person, or an economic group, may not hold, in whole or in part, more than five licenses in the metropolitan area and six in the rest of the country to provide services, regardless of whether in any of the amplitude modulation (AM) and frequency modulation (FM) broadcasting bands, and a single free-to-air television license. If the same natural or legal person or economic group holds, in whole or in part, licenses both in the metropolitan area and in the rest of the country, the total number of licenses held may not exceed six.

In the case of cable subscription television, there shall be a cap of eight licenses.

Partial ownership of a license is understood to mean the case in which a person is not the sole holder thereof but shares it with one or more other natural persons or legal entities, or owns shares or units representing more than ten percent (10%) of the voting capital of a company that holds a license. It shall also be considered that a private natural or legal person is the holder, in whole or in part, of the license to provide open broadcasting services when acts related to such ownership are carried out through a representative, agent, delegate, or any intermediary. 

25. Are audiovisual signals, production companies, and advertising agencies subject to registration?

Law No. 20.383 mandates the creation of a public registry to be created and managed by URSEC, which will hold information about the license holders.

26. Are there obligations to include national or local content; and, original vs. acquired content?

Yes, for television services provided in Montevideo and its metropolitan area, national content, or content created with national cooperation must be a minimum of 60% of all content, without considering any advertising. Services provided elsewhere must broadcast a minimum of 30% of the aforementioned content, as established in Decree No. 31/025.

For radio services provided in Montevideo and its metropolitan area, music of national origins or campaigns made to promote national authors must comprise a 30% of the total broadcast. Services provided elsewhere are required to broadcast a minimum of 20% instead.

There is no regulation on original vs. acquired content.

27. Are there any requirements for specific contents (e.g., news, fiction, children’s programming?

Law 20,383 and its regulations require, among other things, a protection-of-minors watershed from 06:00 to 22:00 with suitable content, minimum daily airtime for open broadcast TV, mandatory participation in official national broadcasts, accessibility measures (subtitling, sign language, and audio description; in Montevideo, real-time translation of newscasts), an obligation to retain recordings for 3 months, and, for subscription TV, inclusion of at least one local/national own channel and parental controls for adult channels. OTT internet services fall outside the scope of the law.

28. Are there minimum quotas for national content?

As stated in our response to question 26, there are minimum quotas for national content.

29. Are Pay TV operators required to carry certain free-to-air channels? What is the scope of this obligation?

They are not required to carry free-to-air channels, but they are required to air official broadcast chains if the Executive Power resolves it to be necessary.

30. Are there requirements regarding domestic or foreign advertising production?

There are no requirements of this kind regarding advertisements.

31. Are there prohibitions on certain products or audiences (e.g., children)?

Yes, there are restrictions on advertising, especially those aimed at children, which must comply with several requirements to protect their rights, e.g., protection-of-minors watershed from 06:00 to 22:00. Alcohol and gambling advertising cannot be aimed at children, and tobacco advertising is prohibited.

Regarding pharmaceutical advertising, it must comply with legal requirements and cannot be advertised if it is not available for the general public, whereas prescription-only medicines cannot be promoted unless authorized by the competent authority in accordance with applicable law.

32. Is there a registry for advertisers or reciprocity obligations?

There is no general registration for advertisers in Uruguay. No obligations of reciprocity exist under the applicable legal framework.

33. Are audiovisual services subject to special taxes or levies?

No special taxes exist for audiovisual services.

34. Are OTT platforms regulated? To what extent? Are there obligations for OTTs to register locally or appoint a legal representative? Are screen quotas applied to OTT and on-demand services? Are there tax obligations applicable to streaming platforms?

The service provided by OTT platforms is not yet regulated in Uruguay. Law No. 20,383 expressly states that it does not apply to audiovisual content distributed using the internet.

Streaming platforms do have tax obligations for services provided in Uruguay; this was established by Law 19.535, which mandated that revenue derived from broadcasting audiovisual services to consumers who are physically in Uruguay constitutes Uruguayan-source and is subject to local taxation (IRAE/IRNR and VAT).

35. Is there any main regulatory framework governing artificial intelligence in your jurisdiction? Are there sector-specific regulations for the use of AI (e.g., in finance, health, education)? Which authorities oversee AI-related matters? Are there...

There is no regulatory framework governing artificial intelligence in Uruguay.

The Agency for Electronic Government and Information and Knowledge Society ("AGESIC") was recently entrusted by recent Law No. 20212 with designing and implementing the National Data Strategy and reviewing the Artificial Intelligence Strategy, but it has no regulatory powers.

There are several projects regarding AI being discussed in commissions of the Legislative Branch.

36. Please describe if there is any mandatory requirement to provided AI-based services under your jurisdictiction's regulations. Are any AI technologies considered high-risk or prohibited? What best practices are recommended or adopted in your jurisd...

Uruguay has no specific regulatory framework for AI in the private sector. Instead, general laws on contracts, torts, IP, consumer protection, and data privacy may apply case by case. Current recommendations focus mainly on public sector use, and there is no dedicated AI authority.

37. Are general regulations applicable to artificial intelligence? In such case, mention the most relevant legislation.

As noted, Uruguay has no specific AI law, so different Uruguayan laws may apply according to the situations that can arise. For example, intellectual property, user data, commercial, civil laws, consumer protection and data privacy could all come into play in relation to artificial intelligence in Uruguay.

38. What is the current legal framework for cybersecurity? Is there a national cybersecurity strategy or action plan in force? Are there any relevant bills or ongoing public consultations?

Uruguay has a National Cybersecurity Strategy (Estrategia Nacional de Ciberseguridad 2024–2030) with a legal framework in progress combining: (i) a cybercrime law approved in 2024 (Law No. 20.327); (ii) the establishment of a national incident register and governance issues in Law No. 20.212 which is managed by AGESIC; and (iii) the existing personal-data protection regime (Law No. 18.331 + Regulations) that includes breach notifications. Multiple drafts are pending, and some implementing decrees were issued in 2025.

39. Are there minimum cybersecurity requirements for companies or service providers (e.g. sectors such as telecom, energy, health, or finance)?

There is no universal private-sector cybersecurity law that applies to all companies.

40. Are there any relevant jurisdictional cases related to cybersecurity incidents where private or public entities were sanctioned because of an infringement?

There are no relevant jurisdictional cases related to cybersecurity incidents in Uruguay.

41. Are there mandatory incident response plans or reporting obligations?

Article 80, Law 20.212 and Decree 66/025 created the National Register of Cybersecurity Incidents ("RENIC") and required that public and specific private entities provide information on incidents to national authorities under the national incident management arrangements, which are AGESIC and the National Cybersecurity Incident Response Center ("CERTuy").

42. How do companies coordinate with authorities in the event of a cyberattack?

Companies can file an incident report to CERTuy via its website, and the authority will address the incident.

43. Are there specific provisions for the criminalization of cyber-related offenses?

Yes, Law No. 20.327 of 2024 criminalized for the first time in Uruguay cyber-related offenses. The new law addresses telematic harassment, aggravated telematic harassment, computer fraud, aggravated computer fraud, computer damage, and aggravated computer damage, among others.

44. Is your jurisdiction subject or adhered to any international cooperation agreements or treaties with other countries and/or international bodies? Does your jurisdiction participate in global cybersecurity initiatives?

Uruguay is part of several international cooperation frameworks on data protection and cybersecurity. Uruguay has ratified Convention 108 for the Protection of Individuals with regard to Automatic Processing of Personal Data and the Additional Protocol to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data regarding supervisory authorities and transborder data flows. Also participates in OAS initiatives, which promote cybersecurity capacity building and incident response cooperation across the Americas.

Lex Mundi Latin America and the Caribbean: TMT and Cyber Guide

Uruguay

(Latin America) Firm Guyer & Regules

Contributors Diego Baldomir Federico Pereyra Burghi

Updated 24 Nov 2025