Updated on November 10, 2026.
Article 132, section XXXIV, of the Federal Labor Law (LFT) requires employers to electronically record each employee's work hours, including start and end times, and to provide this record to the authorities upon request. This provision was added by the decree published in the Official Gazette of the Federation (DOF) on May 1, 2026; the STPS (Ministry of Labor and Social Welfare) regulations specifying who is subject to this requirement will take effect on January 1, 2027.
What does article 132 section XXXIV say?
Article 132 of the Federal Labor Law lists the employer's obligations. The reform decree published in the Official Gazette of the Federation (DOF) on May 1, 2026, added section XXXIV (and, to Article 994, section IV Bis with the penalty). The full text of the section is as follows:
"XXXIV. Electronically record the working hours of each employee, including the start and end times; and provide it to the authority when required."
The Ministry of Labor and Social Welfare will issue general provisions that determine the scope of application and exception to the obligation established in the preceding paragraph.
The content of the electronic record will constitute full proof if it is established that it was agreed upon between the employee and the employer.
Three paragraphs, three functions: the first creates the obligation, the second tasks the STPS to define its scope, and the third gives the registration probative value, with one condition: that it is agreed with the worker.
Phrase by phrase: what it requires and what it doesn't say
The law is only what is in quotation marks. The two columns on the right are our interpretation of the text.
| Phrase from the law | What it requires | What it doesn't say |
|---|---|---|
| "Register electronically" | The record must be kept electronically; a paper list is not. | What technology to use: it doesn't mention apps, time clocks, fingerprint or GPS |
| "the working day of each worker" | One record per person, not a team count | Which positions or company sizes are excluded: that is reserved for the STPS. |
| "including start and end times" | The time that each day begins and the time that the workday ends | A format or a template; it also doesn't specify any fields other than start and end. |
| "provide it to the authorities when required" | To have it available and be able to hand it over when the authority requests it. | That it needs to be sent periodically |
| "general provisions […] scope and exception" | The STPS will say who it applies to and who is exempt. | What are those exceptions: as of November 10, 2026, none have been published |
| "It will be fully proven if it is established that it was agreed upon" | That the record agreed with the worker has full evidentiary value | A record without an agreement is useless: it's a weaker document, but the employer can still present it. |
Two key points are lost in the summaries. The law doesn't require biometrics or location tracking; it requires an electronic record with start and end times. And the conclusive evidentiary value doesn't come from the technology itself, but from the agreement with the employee, which must be verifiable.
Who is obligated
The section refers to "each worker," while the fine, in Article 994, Section IV Bis, refers to "the obligated employer." The STPS (Ministry of Labor and Social Welfare) will determine who this obligated employer is, specifying "the scope of application and exceptions." The law does not specify company sizes, business sectors, or regions.
As of the closing of this edition (November 10, 2026), the STPS (Ministry of Labor and Social Welfare) had not yet published these provisions. What it has said, in an interview, is how it plans to do so. Alejandro Salafranca Vázquez, head of the STPS's Decent Work Unit, told El Economista on May 28, 2026, that "the guidelines for electronic registration will be established over the next four years, prioritizing large and medium-sized companies first" and that "exceptions are still being evaluated."
It's a declaration, not a published rule. Therefore, it's not accurate to say that every employer will be required to register starting January 1, 2027, nor that a small business will be exempt. What can be said is that the obligation is already written into law, pending clarification of its scope by the Ministry of Labor and Social Welfare (STPS). And even if your business falls within a later phase, registration is beneficial to you starting today for a reason that doesn't depend on the STPS: the burden of proof in a labor lawsuit.
Since when
The entire decree, including section XXXIV, has been in effect since May 1, 2026. What comes into effect on January 1, 2027 are the STPS rules.
| Date | What's happening | Where is |
|---|---|---|
| May 1, 2026 | The full decree, including section XXXIV, enters into force | Transitional First |
| From May 1st to December 31st, 2026 | Period to "adjust work processes to the terms of this Decree" | Third Transitional Provision |
| January 1, 2027 | The general provisions of the STPS come into effect; on that same day the maximum working hours are reduced to 46 hours per week. | Transitional Provisions Fifth and Second |
Transitional Provision Five states verbatim: “The general provisions referred to in section XXXIV of article 132 of the Federal Labor Law shall enter into force on January 1, 2027.” The correct wording is this: the law already mandates registration; the STPS (Ministry of Labor and Social Welfare) rules that define who is required to register and with what exceptions apply from January 1, 2027. Starting to register in 2026 is exactly what the adjustment period allows. The complete overview of the reform is in the guide. electronic recording of working hours in Mexico.
What happens if it is not fulfilled?
There are two consequences and it's best not to mix them up.
Before the authority: the fine. Article 994, section IV Bis: “From 250 to 5,000 Units of Measurement and Updating (UMA), for any employer who fails to comply with the provisions of section XXXIV of article 132 of this Law.” With the 2026 UMA (1,117.31 pesos daily, INEGI press release 1/26), this ranges from 29,327.50 pesos to 586,550.00 pesos. The UMA changes every February 1st; the 2027 pesos will be released in January. Details in fines for not recording working hours.
When a worker makes a claim: the burden of proof. Article 784 of the Federal Labor Law (LFT) places the burden of proof on the employer to demonstrate, among other things, absences (section III) and the "ordinary and overtime work hours, when the latter does not exceed nine hours per week" (section VIII). Article 804 requires the employer to keep and present the "attendance records, when kept at the workplace," and Article 805 establishes the consequence of failing to present them: "the presumption that the facts stated by the plaintiff in their complaint are true," unless proven otherwise. This does not depend on the Ministry of Labor and Social Welfare (STPS) or on an inspection.
How to fulfill each obligation and how to demonstrate it
The law states what to register, not how. This table translates each obligation into what, in practice, must be able to be shown; it is our interpretation, not the legal text.
| Obligation (text of the law) | How is this demonstrated? | What to check in your system |
|---|---|---|
| Register "electronically" | A system that saves every record with a timestamp and leaves a trace of any changes | It shouldn't depend on a sheet of paper that anyone can edit without leaving a trace. |
| "of each working person" | One record per person, with a means of identifying who is making the call. | Phone number confirmed with your own code or PIN; no group lists |
| "start and end times" | Check-in and check-out times for each day, with a reliable time | Let the time come from a server and the cell phone clock be stored separately. |
| "provide it to the authorities when required" | Full export by period and by worker, at any time | That exporting should not cost anything and should not depend on the supplier |
| "It will be fully proven if it is established that it was agreed upon" | Employee acceptance saved (text, date, device) and their agreement or disagreement with each correction | That the original never be modified and the corrections remain separate, on account |
| Maintain attendance records (Article 804) | Complete history "during the last year and one year after the employment relationship ends" | The termination of an employee's employment should not erase their record. |
The row that is most neglected is the agreement row. "Agreed between the employee and employer" is verified by each employee's acceptance at the beginning and by their consent in each subsequent change.
How Aurora Check-in solves it
Aurora Check-in is Aurora Inbox's free electronic time and attendance service for employers in Mexico: the employee clocks in and out from their cell phone, without installing anything, and the employer keeps evidence with the server time that cannot be edited or deleted.
Each clock-in saves the server time, device, and location at that moment; the cell phone time is saved separately and never used for calculations. The employee confirms their phone number with a code and accepts the clock-in before starting; this acceptance is saved along with the text version, code, date, and device. The original is never modified: a correction is a new record with a reason, which the employee accepts or disputes from their cell phone, and the dispute is recorded in the reports. CSV exports and monthly reports per employee are free, and records are kept for at least one year after termination. No biometrics required, no minimum number of employees.
How it works, step by step, is on the page of Aurora Check-in.
Frequently Asked Questions
Is Article 132, Section XXXIV already in effect?
Yes. The decree that added it came into effect on May 1, 2026 (First Transitional Provision). What comes into effect on January 1, 2027, are the provisions of the Ministry of Labor and Social Welfare (STPS) that will determine to whom it applies and with what exceptions (Fifth Transitional Provision); as of November 10, 2026, these have not yet been published.
What patterns does it require?
The law applies to "the employer obligated" according to the provisions of the STPS (Ministry of Labor and Social Welfare); it does not specify company sizes or business sectors. The STPS stated in an interview (May 28, 2026) that adoption will be gradual, starting with large and medium-sized companies, and that exceptions are still being evaluated. Until the regulations are published, no one can definitively say when each business will be required to implement them.
Does it require a time clock or a fingerprint system?
No. The text says "electronically" and doesn't mention any technology. A record from the worker's cell phone, with server time and confirmed phone number, covers what the non-biometric section requires.
What does it mean that the record "will constitute full proof"?
If it is proven that the record was agreed upon between the employee and the employer, its contents have full evidentiary value in court. In practice, this requires being able to demonstrate the agreement: the employee's acceptance at the outset and their agreement with each correction.
Sources
- Official Gazette of the Federation, Decree reforming, adding to, and repealing various provisions of the Federal Labor Law regarding the reduction of working hoursMay 1, 2026.
- Chamber of Deputies, Federal Labor Law, current text, last reform published in the DOF on May 14, 2026 (articles 784, 804 and 805).
- INEGI, Press release 1/26, UMA values effective from 1 February 2026January 8, 2026.
- The Economist, "STPS anticipates gradual implementation of electronic recording of working hours"May 28, 2026.
This article provides general information and is not legal advice. For specific cases, consult an employment lawyer.
