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Quick Hits
- Mexico’s Ministry of Labor and Social Welfare published guidance for renewing a license as a provider of specialized services in the Registry of Specialized Services Providers or Specialized Works.
- The REPSE license must be renewed every three years, and the renewal process must be completed within three months before the license expires.
- The Federal Labor Law generally prohibits companies from outsourcing work, but provides exceptions for providers of specialized services.
Actualization Requirements and Process
The government amended the Federal Labor Law (FLL) in 2021 to generally abolish outsourcing, but included certain carve-outs and exceptions for contractors and individuals who provide specialized services. In February 2023, the government published an amendment to the REPSE guidelines.
Under the FLL, outsourced work must:
- be specialized (not part of the core business of the client);
- be provided at the client’s premises under the supervision and/or control of the client;
- be memorialized via an agreement; and
- have an authorization by the government.
Contractors and individuals who wish to renew their licenses must use the REPSE online portal. Registrants must be up to date with their tax and social obligations with the Mexican Social Security Institute (IMSS), Mexican Revenue Service (SAT), and the National Institute of Workers’ Housing Fund (INFONAVIT). Registrants must also define precisely the specialized services that they will perform.
REPSE licenses must be renewed every three years, and the renewal process must take place within three months before a license expires. The renewal process can only be started on the dates established in advance. After the license period has expired, the platform will automatically disable the renewal module. Failure to follow the renewal requirements will result in the immediate cancelation of the registration.
According to the ministry’s most recent guidance, depending on the year and month of registration, REPSE registrants must complete the renewal process during the periods as shown in the table below.
| Year of registration | Month when the registration was granted | Period of registration renewal |
| 2021 | June | From March to May 2024 |
| July | From April to June 2024 | |
| August | From May to July 2024 | |
| September | From June to August 2024 | |
| October | From July to September 2024 | |
| November | From August to October 2024 | |
| December | From September to November 2024 | |
| 2022 | January | From October to December 2024 |
| February | From November 2024 to January 2025 | |
| March | From December 2024 to February 2025 | |
| April | From January to March 2025 | |
| May | From February to April 2025 | |
| June | From March to May 2025 | |
| July | From April to June 2025 | |
| August | From May to July 2025 | |
| September | From June to August 2025 | |
| October | From July to September 2025 | |
| November | From August to October 2025 | |
| December | From September to November 2025 | |
| 2023 | January | From October to December 2025 |
| February | From November 2025 to January 2025 | |
| March | From December 2025 to February 2026 | |
| April | From January to March 2026 | |
| May | From February to April 2026 | |
| June | From March to May 2026 | |
| July | From April to June 2026 | |
| August | From May to July 2026 | |
| September | From June to August 2026 | |
| October | From July to September 2026 | |
| November | From August to October 2026 | |
| December | From September to November 2026 |
Source: Ministry of Labor and Social Welfare (STPS)
Ogletree Deakins’ Mexico City office will continue to monitor developments and will provide updates on the Cross-Border blog as additional information becomes available.
Pietro Straulino-Rodríguez is the managing partner of the Mexico City office of Ogletree Deakins.
Natalia Merino Moreno is an associate in the Mexico City office of Ogletree Deakins.
María José Bladinieres is a law clerk in the Mexico City office of Ogletree Deakins.
