October 6, 2025
Today, the Diario Oficial de la Federación (Official Gazette of the Federation) published the “AGREEMENT number ACDO.AS2.HCT.300925/288.P.DIR, issued by the Honorable Technical Council of the Mexican Social Security Institute (IMSS) during its ordinary session held on September 30, 2025, regarding the request for authorization to approve the amendment to Rule Five and the transitory provisions of the General Rules for obtaining the opinion on compliance with tax obligations in matters of social security.”
Pursuant to this Agreement, as of October 1, 2025, the procedure for obtaining the opinion on compliance with tax obligations related to social security shall be carried out exclusively through the IMSS Electronic Mailbox (Buzón IMSS), following the steps below:
I. Access the IMSS Electronic Mailbox through the Institute’s website at www.imss.gob.mx/buzonimss using the corresponding authentication method;
II. From the menu, select the option “Cobranza” (Collections);
III. Then select “32D Consultar Mi Opinión” (32D Consult My Opinion); and
IV. Click on the “Consultar Mi Opinión del Cumplimiento” (Consult My Compliance Opinion) icon to download the compliance opinion regarding tax obligations in matters of social security, which may be saved in “.PDF” format or printed.
In accordance with the Transitory Provisions of the General Rules for obtaining the opinion on compliance with tax obligations related to social security, such opinion shall be deemed valid for the periods established in the applicable regulations: fifteen business days or twenty business days in the case of consolidated procurement procedures, pursuant to the Law on Acquisitions, Leases, and Services of the Public Sector, or fifteen calendar days pursuant to the Law on Public Works and Related Services.
These periods correspond to those set forth in Article 32-D of the Federal Tax Code for the formalization of the corresponding contracts. For such purposes, the taxpayer must demonstrate to the contracting public entity that the social security compliance opinion was obtained within that period.
Furthermore, the positive compliance opinion is essential for companies registered in the Registry of Specialized Service or Specialized Works Providers (REPSE), administered by the Ministry of Labor and Social Welfare (STPS). This document certifies that the company is up to date in fulfilling its social security obligations—an essential requirement to maintain the validity of its registration and to legally provide specialized services.
Failure to hold a valid positive opinion may result in suspension or cancellation of the REPSE registration, as well as sanctions or joint liability for the contracting companies.
The attorneys from our Social Security and Labor Law departments remain at your disposal to advise you on compliance with this new obligation.
Sincerely,
Gil Zenteno
Jorge G. De Presno
David Puente Tostado
Gabriela Méndez
Jesús Carmona
Ana Sofia Lazcano