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 registrationMonth when the registration was grantedPeriod of registration renewal
2021JuneFrom March to May 2024
JulyFrom April to June 2024
AugustFrom May to July 2024
SeptemberFrom June to August 2024
OctoberFrom July to September 2024
NovemberFrom August to October 2024
DecemberFrom September to November 2024
2022JanuaryFrom October to December 2024
FebruaryFrom November 2024 to January 2025
MarchFrom December 2024 to February 2025
AprilFrom January to March 2025
MayFrom February to April 2025
JuneFrom March to May 2025
JulyFrom April to June 2025
AugustFrom May to July 2025
SeptemberFrom June to August 2025
OctoberFrom July to September 2025
NovemberFrom August to October 2025
DecemberFrom September to November 2025
2023JanuaryFrom October to December 2025
FebruaryFrom November 2025 to January 2025
MarchFrom December 2025 to February 2026
AprilFrom January to March 2026
MayFrom February to April 2026
JuneFrom March to May 2026
JulyFrom April to June 2026
AugustFrom May to July 2026
SeptemberFrom June to August 2026
OctoberFrom July to September 2026
NovemberFrom August to October 2026
DecemberFrom 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.

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