He should qualify for a work permit as he's already a full international. We may still send him out on loan though to get more experience. However he's more experienced in senior football than Jeremy Sarmiento who forced himself into the first team picture in his first season, so we may see Enciso kept for the first part of the season, training with the first team squad while playing some games for the U23's and seeing how he gets on before a further decision is made in January. There is certainly a proven pathway into the first team squad for a new young signing now though.
When I did the math in January he was a few points off:
Lets see... he played 397 out of 1080 minutes in Copa Sudamericana. That is 36% if I remember how to calculate percents. This means... 0 points as it is a band 2 competition. He also played too little in Copa Libertadores. So 0 minutes from playing time in those competitions.
However, his club went to the semi finals in the Copa Sudamericana and he was in the matchday squads, so thats 6 points. Unfortunately they failed to go to the Copa Libertadores group stages so 0 points from that. Their quarter-finals in the same tournament in 2020 wont count because it is not within the 12 month limit.
All in all 6 points from the SA continental competitions.
Moving over to domestic competitions. The Paraguayan league is unfortunately a band 6 league. This is where I cant be bothered to do the exact maths and I also dont know if Clausura and Apertura counts as different competitions and doubles the point. Assuming not, he probably just goes over the 80% game time limit and gets 1 point from this, but it could be as much as 3.
Libertad won the Apertura season ending in December, meaning as a club from a band 6 club he Enciso gets another 1 point.
Furthermore he also gets another 2 points for playing in a band 6 club at all. His 3 appearances for low ranked Paraguay is also 0 pts.
TLDR: So if I'm counting correctly, and he gets no additional points for being part of Paraguys Copa America squad (it seems not but I could be wrong), he gets between 10-12 points out of the necessary 15. No work permit.
In order to get his work permit, it is unlikely that he could stay in Paraguay. He would need to be loaned out to a decent league and get decent amount of game time.
Not going to do the counting again but not quite sure he reaches the 15 pts just yet.