October 06, 2025
The Ministry of Labor, Employment, and Social Security (MTESS) has issued Resolution No. 915/2025. The rule amends MTESS Resolution No. 991/2024, which required employers to report the entry and exit of non-dependent personnel in the Employer-Employee Registry (REOP).
The obligation to register independent workers, outsourced personnel, and contractors who regularly provided services at the employer’s establishment is suspended. The reporting of entry is now voluntary. This status will remain until a new administrative act regulates the matter. Notably, the rule defines «regularity» as the provision of services for at least 16 hours per week or 64 hours per month for more than 60 days.
Furthermore, an incentive for voluntary reporting is introduced: exemption from the fee for the Labor Compliance Certificate. However, if an employer reports the entry of a non-dependent worker, reporting that person’s departure becomes mandatory. No fines will be applied for late reporting for this group as long as the entry registration remains voluntary. The resolution also extends the deadline for reporting the payment of the year-end bonus (aguinaldo) to the first 10 business days of each year.
Finally, we note that the suspension of the mandatory requirement introduces a voluntary registry that conditions a benefit on the creation of a precedent. The decision of whether to register non-dependent personnel becomes a calculation between an administrative benefit—the fee exemption—and the legal risk that such a record may be used as evidence in future disputes over the nature of the contractual relationship. The evaluation requires weighing the nature of the services provided against the new definition of «regularity» and the legal risk against the operational benefit.