REPSE in Mexico: what it is and what to verify before paying a specialized provider

A company that hires cleaning, maintenance, audit or technical support services in Mexico often learns late that the supplier needed a government registration. Without it, the payment may lose its tax effects and leave the buyer with labor exposure.

At Soulbit Academy we explain REPSE from the buyer's side, as of October 2026: what it is, when a specialized service triggers it, what changed with the June 2026 simplification and what to check before releasing a payment. For the broader question of contractors versus employees, our guide to contractors versus employees in LATAM complements this one.

REPSE in Mexico: what the registry is and what article 15 of the Federal Labor Law says

REPSE is the Registro de Prestadoras de Servicios Especializados u Obras Especializadas, the public registry of the Secretaría del Trabajo y Previsión Social (STPS) in which providers of subcontracted services must be listed. Its legal basis is article 15 of the Federal Labor Law, whose current text was last amended on May 14, 2026.

To obtain the registration, a provider must show that it is up to date on its tax and social security obligations. The registration is renewed every three years, and the STPS may deny or cancel it at any time if the provider stops meeting the requirements.

The registry must be public and available on an internet portal. Today that portal is repse.stps.gob.mx, and it is the source a buyer uses to check a supplier.

Prohibited personnel subcontracting and permitted specialized services since 2021

The reform published on April 23, 2021 prohibited the subcontracting of personnel and left only specialized services or works permitted. Article 12 defines the prohibited practice as one person supplying or placing its own workers at the disposal of another.

Article 13 sets the condition for what is allowed: the service or work cannot be part of the beneficiary's corporate purpose or main economic activity, and the contractor must be in the registry. Complementary services shared between companies of the same corporate group count as specialized under the same condition.

Table 1 summarizes how the law treats three arrangements that are often confused.

Arrangement	What it is	What the law says	What it means for the buyer
Personnel subcontracting	The provider places its own employees at your disposal to do your own activity	Prohibited (article 12, Federal Labor Law)	Registration does not make it lawful; labor and tax risk
Specialized service or work	The provider delivers a service or work outside its client's corporate purpose and main activity	Permitted with a written contract and a registered provider (articles 13 and 14)	Check the registry, the contract and the payment support documents
Employment agency or intermediary	Recruits, selects, trains, but does not put workers to work for you	Permitted; not treated as the employer (article 12)	The employer is whoever benefits from the work, not the agency

When does hiring a service require REPSE?

Hiring requires REPSE when the provider delivers a specialized service with its own employees and that service is not part of the buyer's corporate purpose or main economic activity. If the service is exactly what your company does, or if the provider only supplies people, registration does not solve the problem.

A hypothetical example: the Mexican subsidiary of a US software company hires a firm to audit its information security, using the firm's own staff. That is a specialized service outside the subsidiary's activity. If instead it brings in developers who work under its direction on its own product, that looks more like placing staff at its disposal. This is an illustration, not a legal classification.

Who must register and the STPS simplification published on June 9, 2026

Every individual or company that provides specialized subcontracted services must register in REPSE, whatever its size. The buyer does not register for hiring; its duty is to verify and document.

On June 9, 2026 the Official Gazette published the agreement establishing simplification actions for procedures before the STPS, effective June 10. According to the text, registration, update and cancellation are unified under a single procedure code, STPS-086-002.

The agreement sets a response time of 5 business days for providers with up to 10 workers and 15 business days for those with more. This article does not state which document requirements changed: check them in the text of the agreement published in the Official Gazette.

The simplification does not remove the obligation to hold the registration, does not widen the activities that can be subcontracted and does not change the tax requirements for deduction and credit. For a buyer, the practical effect is that a small provider should be able to register or renew faster, not that the control becomes lighter.

The registration lasts three years, and the window to request renewal should be checked on the STPS portal. An expired registration is no longer proof of compliance.

Joint liability of the buyer: what REPSE does not remove

A buyer that pays a specialized service provider is jointly liable to that provider's workers if the provider defaults on its labor obligations. Article 14 of the Federal Labor Law says so, and REPSE does not remove it.

Joint liability means a contractor's worker can claim against whoever benefited from the service, not only against the direct employer. The risk shrinks when the buyer documents that the provider was registered, that the service was truly specialized and that the provider kept up with its obligations.

The same article 14 requires the arrangement to be set out in a written contract. That contract must state the purpose of the services or works and the approximate number of workers who will take part. A generic contract with no concrete purpose weakens the buyer in a dispute.

For companies that already run payment controls, REPSE is one more control at vendor onboarding. Our guide to internal controls for payment approval offers a base for deciding who verifies and who authorizes.

What to verify for REPSE before paying a specialized services provider

Before each payment to a specialized services provider, the buyer should confirm three things: that the registration is valid, that the contract meets article 14 and that the tax and social security support documents exist. The income tax and VAT articles cited below place the check at the time of payment, not only at signing.

Table 2 organizes the checklist for procurement and treasury teams.

What to verify	Where to check	Legal basis	What to file
Valid entry in the registry	STPS portal, by supplier name or RFC	Article 15 Federal Labor Law; income tax law article 27, section V	Screenshot or certificate with the date of the check
Service outside your corporate purpose and main activity	Your articles of incorporation and the service description	Article 13 Federal Labor Law	Procurement note explaining why it is specialized
Written contract with purpose and approximate number of workers	Signed contract	Article 14 Federal Labor Law	Contract and annexes; it helps to include the registration number
Proof of salary payments, withholdings, IMSS and INFONAVIT	Documents the provider must deliver	Income tax law article 27, section V	Payroll CFDIs and payment receipts for each period
VAT return and acknowledgment for the payment period	Document the provider must deliver	VAT law article 5, section II	Copy of the return and acknowledgment, by the last day of the following month
Invoice (CFDI) with VAT shown separately	Your accounting system and the tax authority	VAT law article 5, section II	CFDI and, where relevant, the payment complement

The Income Tax Law conditions the deduction in article 27, section V: the buyer must check the registration at the time of payment and obtain copies of salary receipts, proof of tax withholdings paid, IMSS contributions and INFONAVIT contributions. The provider is obliged to deliver them.

The VAT Law requires, in article 5, section II, a copy of the VAT return and its acknowledgment for the month of payment. If the buyer does not collect them in time, it must file an amended return reducing the VAT credit taken for that service.

The versions consulted are those published by the Chamber of Deputies as of October 2026; ask your tax adviser to confirm that nothing has changed.

What happens to the payment if the provider does not deliver the support documents?

If the provider does not deliver them, the buyer risks the expense deduction and the related VAT credit. Write monthly delivery of the documents into the contract and hold approval of the next payment until they arrive.

To close the accounting file, the explainer on the Mexican CFDI invoice for foreign companies shows how the invoice is documented, and the guide to payroll for remote workers in Mexico with CFDI covers a company's own staff. Those situations should not be confused with a specialized service.

Foreign company with a Mexican subsidiary: what to review before the first payment

A foreign company with a subsidiary or operations in Mexico should review REPSE when it buys services whose provider employs its own workers on Mexican territory. The tax effect falls on whoever hires and deducts in Mexico.

Three questions structure the review. The first is who signs the contract: the Mexican entity or the parent abroad. The second is who delivers the service and where its workers are. The third is what the service is relative to the corporate purpose and main activity of the recipient.

A foreign supplier with no workers in Mexico that delivers a remote service raises a different question, about withholding and treaties, which is separate from REPSE. Your local tax adviser should analyze that. This article does not decide whether a specific operation falls under the regime.

Before onboarding a new Mexican supplier, apply the same logic you use for suppliers elsewhere: identity, representatives, beneficial owner. Our explainer on what KYB is describes what is verified about a company, and the guide to Mexico's anti-money laundering law and vulnerable activities shows another documentation duty common in Mexico.

What Soulbit V1 delivers on REPSE, and what it does not

Soulbit V1 does not verify any provider's REPSE registration and does not decide whether a service is specialized. That check, the contract and the tax support documents remain the responsibility of your team and your adviser.

What Soulbit V1 does today is apply KYB to the companies that operate on the platform, apply AML controls and transaction monitoring, operate with institutional custody and pay overseas suppliers in USDC and USDT stablecoins. Each payment leaves a traceability record your team can file with the supplier dossier.

What Soulbit V1 does not deliver: it does not query the STPS registry, does not review contracts or IMSS and INFONAVIT receipts, does not integrate with your ERP, does not issue or validate CFDI and has no local bank rail in Mexico. Its only local bank rail is in Colombia. A payment made in stablecoins replaces none of the controls in this guide.