For more than two decades, Dominican tourism clusters have built an increasingly close relationship with the government. They have participated in competitiveness programs, coordinated territorial projects, signed agreements with ministries, and received public funding
SANTO DOMINGO. The legal link between tourism clusters and the Dominican State does not originate from special legislation, but rather, in most documented cases, from a much broader concept: non-profit associations.
Law 122-05, which regulates them, establishes the general framework for these entities. The administrative procedure requires, among other documents, the bylaws, the articles of incorporation, the list of members, and documentation proving their membership.
That is why a tourism cluster can legally exist as a non-profit association without a law stating what a tourism cluster should be like.
An association, not a separate legal category
The Dominican cluster model was developed before there was specific legislation for these organizations:
- The Santo Domingo Tourism Cluster offers a documented example: its public activity, with successive directives since at least 2018, corresponds to an organization already consolidated by that time.
- In Puerto Plata, the destination itself identifies the Puerto Plata Destination Tourism Cluster as a consortium of institutions and companies that has been operating since 2003, through a public-private agreement.
- In La Romana-Bayahíbe, the Hotel Association dates back to 2000 and the process of articulation with other actors in the tourism value chain was already underway in 2004, according to a working document of the Inter-American Development Bank; the formally established organization, the La Romana-Bayahíbe Tourism Cluster, dates back to 2009, according to the Hotel Association itself.
The documents thus show a common characteristic and an important difference: clusters can be organized under the general regime of non-profit associations, but they do not necessarily have an identical legal structure or the same origin date for the articulation process and for the formal organization that represents it.
There is another way to receive public money
Legal incorporation does not automatically mean that an organization can receive state funding. The National Center for the Promotion and Development of Non-Profit Associations (CASFL) states that non-profit organizations interested in public funds must complete a process that includes legal incorporation, classification, sectoral accreditation, and registration in the National Accreditation Registry.
The CASFL defines this registry as a fundamental reference for the allocation of public funds or the contracting of non-profit organizations by the public sector, as well as for state endorsement of agreements and financing of cooperation agencies.
To evaluate each funding request, CASFL weighs, according to its own management report, the organization's legal, administrative and financial compliance, its governance, its transparency and accountability mechanisms, the technical feasibility of the project and, where appropriate, the quality of its previous accountability reports.
The SIGASFL platform itself allows for the registration of grant applications, accountability reports, activities and documentation, as well as tracking the processes of the associations.
This allows us to distinguish three moments that are often confused when discussing public funds: an organization can be incorporated; it can be authorized; and it can receive a budget allocation. These are different situations.
The allocation in the General State Budget does not in itself equate to the execution of the money.
What the Tourism Budget Shows
The records of the General Directorate of Budget allow us to see precisely a part of that circuit. In the approved 2025 budget, five non-profit associations linked to the Ministry of Tourism appear, for a total of RD$18.5 million:
- Monseñor Nouel Provincial Ecotourism Development Fund (RD$5 million)
- Sánchez Ramírez Province Ecotourism Development Council (RD$5 million)
- Ecotourism Cluster of Espaillat Province and Related Areas (RD$6.5 million)
- Happy Dolphins (RD$500,000)
- La Romana Bayahibe Tourism Cluster (RD$1.5 million).
The preliminary budget for 2026, prepared by CASFL in September 2025, added a sixth organization, the Puerto Plata Destination Tourism Cluster, with RD$12 million, and raised the total recommended for the sector to RD$30.5 million.
If that recommendation remained unchanged until the enactment of Law 99-25, of December 16, 2025, Puerto Plata would become, of the three organizations that have "cluster" in their name, the one that receives the highest allocation, above even Espaillat and La Romana-Bayahíbe combined.
That alone does not demonstrate a difference in performance between the destinations. The budget identifies allocated or recommended amounts; it does not constitute a comparative evaluation of results.
The State does not just transfer money
The relationship between clusters and public institutions is not limited to subsidies either.
In September 2025, the Ministry of Tourism, together with the La Romana-Bayahibe Hotel Association and the La Romana-Bayahibe Tourism Cluster, formalized the project that declared that destination as the first in the country with a focus on accessibility and tourism inclusion, with technical assistance from Open Doors Organization and Travegali.
In Samaná, the Ministry of Environment and Natural Resources chose the Samaná Tourism Cluster as the coordinating entity for the co-management of Salto del Limón, a natural attraction in which the ministry planned to invest RD$11 million.
In these cases, the cluster appears as part of a public-private partnership to implement a specific policy in the territory, not merely as a recipient of a budget transfer.
The new procurement system changes the context
Added to that relationship is now Law 47-25 on Public Procurement, enacted on July 28, 2025 and in force since January 28, 2026, which repealed Law 340-06 and established an updated regime for State procurement, with emphasis on efficiency, transparency and oversight.
This is relevant for organizations that, in addition to receiving grants, participate as implementers of projects, services or works financed with public resources.
The CASFL expressly states that registration in the National Registry of Authorization is a criterion for considering ASFLs suitable to be contracted by public bodies as executors of specific projects, services or works.
Therefore, not all public resources received by an organization necessarily have the same legal nature: a budget grant is not the same as payment for a contract. A cooperation agreement is not automatically a public contract, and a budget allocation, or even a recommendation for allocation, does not prove that the money has been disbursed or that the project has been carried out.
Traceability requires following each operation back to its corresponding document, accountability reveals what happened after the allocation, and the State now has tools to record a good part of that journey.
SIGASFL records funding requests and accountability reports. CASFL maintains the National Registry of Licensing and, according to its own management report for the first half of 2025, conducted 268 inspections of non-profit organizations nationwide and thirty compliance audits, finding inadmissible expenditures in some cases. DIGEPRES identifies budget allocations. ONAPI allows for the tracking of trade names.
The journalistic problem arises when these records are examined separately, since one record might state that an organization exists. Another might show that it received an award or an award recommendation. A third might document a co-management agreement or arrangement.
None of these data points, taken individually, answers how much money ultimately arrived, what activities it funded, and what results it produced. The question, therefore, is no longer simply how much money was allocated or recommended for the clusters, but rather what projects were funded, how much was disbursed, who implemented them, and what results were reported.
Until that traceability is rebuilt for each destination, the budgeted or recommended amounts allow us to know how much was put on paper, but not by themselves how much the territory changed.
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