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On November 21th, 2025, the Ministry of Labor issued Ministerial Agreement MDT-2025-186, which amends Agreement MDT-2025-102, governing the prevention and management of discrimination, violence, and workplace harassment in the private sector.
Key Amendments:
- Exception for small employers:
Employers with 1 to 9 workers are no longer required to submit the Internal Protocol for the Prevention and Eradication of Discrimination, Violence, and Workplace Harassment (the “Protocol”). However, they must still comply with the Guidelines for the Prevention and Eradication of Discrimination, Violence, and Workplace Harassment to be issued by the Ministry of Labor.
- Control:
For employers with 10 or more employees, the Ministry of Labor will begin conducting random compliance audits on the implementation of the Protocol starting July 31, 2026.
- Stability for those who have already complied:
Companies that already have an approved Internal Protocol and/or Risk Program, or that are currently in the approval process, will not be required to modify it or submit a new one.
- New Internal Protocol approval procedure:
The Regional Director of Labor will approve the Protocol when if it meets with the core components: prevention, identification and detection of cases, care, and monitoring and evaluation. If deficiencies are identified, employers will have 10 business days to correct them before the application is dismissed. Once approved, employers will have 15 calendar days to download the Protocol and the corresponding resolution. After this period, the documents will be automatically deleted, with only the procedural record retained indefinitely.
- Registration:
All private sector employers with 10 or more employees must register their Protocol once on the Ministry of Labor´s designated digital platform.
The Protocol may be updated or amended whenever the employer deems it necessary.
For new employers, the registration deadline is July 31st of the year following their incorporation.
- Implementation and compliance monitoring:
Within 60 business days, the Ministry of Labor will issue an Implementation Guide for the Protocol and the Guidelines for the Prevention and Eradication of Discrimination, Violence, and Workplace Harassment, standardizing content and methodology for employers . The Ministry will also implement a digital module to support and monitor compliance with the reform.
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This publication contains information of general interest and does not constitute legal opinion on specific issues. Any analysis will require legal advice from the Firm.