Simplification of procedures with the Ministry of Labour and Social Security (STPS) – Register of Specialised Service Providers (REPSE)

The specific changes set out in the new Agreement are:

Consolidation of procedures

• Applications for registration, updates and cancellation with the REPSE are consolidated into a single procedure.
• Procedures have been grouped together to simplify the list of procedures relating to employment agencies.

Reduction in response times

The maximum time limits for the authority to reach a decision have been drastically reduced:

• For the REPSE, this has been reduced from 20 to 5 working days for employers with up to 10 employees, and to 15 days for employers with more than 10 employees.
• Procedures such as the closure or change of address of employment agencies are now resolved immediately.

Removal of requirements and documents

The requirement to submit applicant details and proof of address for numerous procedures has been abolished.

• For the REPSE in companies with up to 10 employees, the requirement to submit a power of attorney, payslips, IMSS employer records and SUA identification cards has been removed.

Update to forms

Eight new annexes (forms AC-3 to AC-9 and an online form for the REPSE) have been published to bring them into line with the new requirements.

BENEFITS OF THE CHANGES

Reduced administrative costs and greater efficiency 

By removing the requirement for simple copies, documents issued by the same authority and notarised deeds for certain procedures, employers save time and money. Immediate decisions or those taken within very short timeframes (such as 1 to 5 days) allow companies to operate more quickly.

Incentive for micro and small businesses 

The simplification measures benefit individuals and legal entities with up to 10 employees, exempting them from submitting the most burdensome documentation (payroll records, SUA contributions, IMSS contributions), which facilitates their formalisation and registration with the REPSE.

Maintenance of legal certainty 

Despite the simplification of procedures, the core principles of the subcontracting reform remain in place. Companies contracting specialised services continue to bear joint and several liability towards workers, and tax approvals are maintained to prevent fraud.

DRAWBACKS AND LIMITATIONS

Unequal benefits (size-related condition): 

The REPSE’s simplified documentation requirements do not apply to companies with more than 10 employees. These organisations remain obliged to submit identification documents, powers of attorney, payslips, IMSS records and SUA payments, with the sole exception of proof of address. Their processing time is also longer (15 days compared to 5 days for micro-enterprises).

Pending applications under previous rules: 

There is a temporary disadvantage for those who submitted their applications before the publication of this Agreement, as their applications will be processed in accordance with the regulations, timeframes and requirements in force at the time of submission, without benefiting from the new simplification.

Significant responsibility despite ease of registration: 

Although it is now easier and quicker to register (especially for micro-enterprises), companies receiving specialised services remain strictly liable for any labour, tax or social security non-compliance on the part of the subcontractor. The ease of the procedure does not exempt companies from the severe penalties provided for by law in the event of fraudulent registration.