Hiring a company with REPSE does not automatically make any supply of personnel lawful. Personnel subcontracting is prohibited and only specialized services or works are allowed that are not part of the corporate purpose or the predominant economic activity of the beneficiary, in addition to shared services within a group under the legal assumptions. In 2026, the control must cover real specialization, valid registration, contract, assigned workers, tax and social security obligations, as well as the provider's three-year renewal.
Specialization is analyzed by service and client
Articles 12 to 15 of the Federal Labor Law require reviewing what is being hired, who directs the personnel and how the service relates to the beneficiary. REPSE must cover exactly the activity performed, but the registration number does not replace the analysis of the client's corporate purpose and predominant activity. The written contract must state the object of the service or work and the approximate number of people who will participate. In the operation, it is advisable to prevent the beneficiary from assuming powers proper to the employer. If the contractor fails to meet labor obligations with respect to the personnel used, the beneficiary may face joint and several liability under legal terms.
Validity, renewal and due diligence
The registration is renewed every three years and the application must be filed during the three months prior to expiration, in accordance with the STPS calendar and rules. An update of data does not replace the renewal. Before the start and during the contract, the beneficiary should verify the public registry, authorized activities, validity date and correspondence between personnel, centers and invoiced scope. It is also reasonable to request periodic evidence of wages, contributions and related tax obligations, within privacy limits. The file must keep dated consultations and alerts; a screenshot obtained at signing does not prove that the registration remained valid throughout the entire service.
Reports and four-month traceability
Registered providers report contracts to the IMSS through ICSOE and to Infonavit through SISUB every four months. The ordinary deadlines are the first seventeen days of May, September and January, with adjustments when the due date is a non-business day; in May 2026 the IMSS itself reported the applicable operating period. The reported data must match the contract, REPSE registration number and assigned personnel. On the client's side, the review must not be limited to receiving an acknowledgment: it is advisable to cross-check service, period, workers and receipts. This summary is general and does not replace the labor, tax and social security review of each structure.
Key points
- REPSE does not authorize services that form part of the client's corporate purpose or predominant activity.
- The contract must describe the specialized service and the approximate number of participating people.
- Renewal is every three years and is requested in the three months prior to expiration.
- ICSOE and SISUB require four-month reports consistent with contracts and personnel.
What to review
- Compare each service with the beneficiary's corporate purpose and predominant activity.
- Verify in the registry the validity and authorized activity before hiring and during performance.
- Reconcile contract, personnel, invoices, contributions, ICSOE and SISUB by four-month period.