Frequently asked questions about REPSE
Short answers, each with its legal source. For the detail on each topic, the full guides are linked at the end.
Who must register with REPSE?
Any individual or legal entity that provides specialized services or performs specialized works with its own staff placed at the disposal of a third party, provided those services are not part of the corporate purpose or the predominant economic activity of the party receiving them. The legal basis is article 15 of the Federal Labor Law (Ley Federal del Trabajo, LFT).
How often is a REPSE registration renewed?
Every three years. The renewal application is filed in the three calendar months before the month in which the registration expires (REPSE Acuerdo of the STPS, article décimo sexto). The amendment published in the Official Gazette (Diario Oficial de la Federación, DOF) on February 21, 2024 also assigns a calendar based on the month of registration and automatically disables the renewal module once the window has run out, so letting it pass leads to the registration being cancelled.
What is the fine for operating without REPSE?
From 2,000 to 50,000 times the UMA (Unidad de Medida y Actualización, the Mexican reference unit used for fines) under article 1004-C of the Federal Labor Law. With the 2026 UMA (MXN 117.31), that is a range of MXN 234,620 to MXN 5,865,500. The same penalty applies to anyone who benefits from subcontracting in breach of the law, which means the client as well.
Can the client deduct payments to a provider without REPSE?
No. Article 15-D of the Federal Tax Code (Código Fiscal de la Federación, CFF) denies the deduction and the VAT (IVA) credit for subcontracting payments that do not meet the requirements, and article 27, section V of the Income Tax Law (Ley del Impuesto sobre la Renta, LISR) requires the client to verify the contractor's registration when making each payment.
What are the ICSOE and the SISUB, and when are they filed?
They are the informational returns filed every four months by the provider of specialized services: the ICSOE with the Mexican Social Security Institute, IMSS (article 15 A of the Social Security Law, Ley del Seguro Social), and the SISUB with Infonavit, the workers' housing fund (article 29 Bis of the Infonavit Law, Ley del Infonavit). The law sets January 17, May 17 and September 17 for both, for the four months just ended. If that day is not a working day, the ICSOE moves to the next working day (IMSS guidelines, section 5.5); for the SISUB there is no written rule, and our recommendation is to file it on the preceding working day.
Where do I check whether a provider has a current REPSE registration?
In the public registry of the Ministry of Labor (Secretaría del Trabajo y Previsión Social, STPS) at repse.stps.gob.mx, a Spanish-language portal. The lookup is free and needs no account: you search by REPSE registration number (folio), Mexican tax ID (RFC) or registered legal name, and the result shows the folio, the state, the registration notice (aviso de registro), the validity period and the registered activities.
Which documents should the client ask its provider for with each payment?
Article 27, section V of the LISR requires the client, when paying, to verify that the provider holds a REPSE registration, and to obtain from the provider copies of the payroll CFDI (electronic payroll invoices) for the workers who provided the service, of the bank receipt for the payment of the income tax (ISR) withheld, and of the proof of payment of IMSS contributions and Infonavit contributions. The law does not require filing a copy of the registration; a registry lookup dated at the payment and the provider's registration notice are the practical way to document the verification. To claim the VAT credit, the VAT Law (Ley del Impuesto al Valor Agregado, LIVA, article 5o., section II) also requires a copy of the provider's VAT return and of the acknowledgement of its payment, delivered no later than the last day of the month following the payment.
Does joint and several liability extend to the client?
Yes. If the provider fails to meet its social security obligations, the party that contracted its services is jointly and severally liable with respect to the workers used, under article 15 A of the Social Security Law and article 29 Bis of the Infonavit Law.
Why does the STPS inspect one company and not another?
Inspections are not drawn at random. Under the STPS inspection protocol on subcontracting (September 2025), the authority combines information from the IMSS, the Tax Administration Service (Servicio de Administración Tributaria, SAT) and Infonavit as risk factors to schedule them, and the main signal is inconsistency between what was declared to each authority: what is registered in REPSE compared with what is reported in the ICSOE, the SISUB and to the SAT. Subcontracting inspections are also currently carried out without prior notice, and they reach both the provider and the company that hires it.
Can a REPSE registration be cancelled before the three years are up?
Yes. The STPS can deny a registration or its renewal if the company is not up to date with the SAT, the IMSS or Infonavit, or submits false information, and it can cancel a registration already granted at any time, for example for debts under final assessments (créditos firmes) owed to those authorities or for no longer meeting the requirements on which the registration was based. That is why the registration's validity is checked at every payment, not just once.