Last 13 July 2017, Ruling ACDO.SA2.HCT.280617/148.P.DIR was published in the Federal Official Gazette, setting forth the rules applicable to employers and other liable parties engaged in the construction activity, either permanently or sporadically, to register construction works, its stages and incidents.
Pursuant to these rules, IMSS agreed to simplify the registration of construction works. Employers or liable parties shall get registered in the IMSS website and access to the virtual desktop with its Advanced Electronic Signature (FIEL, per its Spanish initials) and password. This system is known as "Integral Registration Service of Construction Works" (Servicio Integral de Registro de Obras de Construcción - SIROC).
Remember that currently there are 6 forms to submit information related to construction works to the IMSS, which are detailed below:
- SATIC 01 – Initial notice of construction work registration
- SATIC 02 – Notice of outsourcing filed by subcontractors
- SATIC 03 – Construction work incidents (suspension, resumption, completion)
- SATIC 04 – Outsourcing cancellation notice
- SATIC 05 – Monthly list of the workers at the construction site
- SATIC 06 – Notice of outsourcing filed by owner or main contractor
All the notices mentioned above are simplified in one notice that shall be filed by the owner or main contractor of the construction work and another by the subcontractor, thereby eliminating administrative burden for both parties.
As to the monthly list of the workers who are employed at the construction site, the obligation to submit this notice will be deemed complied with any time the employers or liable parties link the employee to the work that is assigned at the moment of calculating the social security contributions through the Single Self-determination System (Sistema Único de Autodeterminación - SUA) and their payment. In order to do so, as of July 13, 2017, a new version of the SUA will be available, that will allow the proper identification of workers.
As of 14 July 2017, employers or liable parties may choose to use the SIROC system to submit notices of construction, their stages and incidents, and it will be mandatory as of 1 September 2017.
Please bear in mind that the construction works that were registered in the previous system (through SATICS), shall continue registered under that system until submitting the notice of work completion through the SATIC-03 form.
At Baker McKenzie we have a specialized team in construction matters and we will be pleased to assist you with the compliance of obligations with the IMSS.