Quick Hits

• The amendment to Mexico’s INFONAVIT law includes new obligations for employers related to deductions allowed under INFONAVIT per the loans granted by said authority.
• Evidence of compliance with the new obligations must be presented before September 17, 2025.

New Obligations for Employers

Per the amendment, employers must adjust their systems and processes to determine, make, and enter deductions from the salaries of employees who are granted INFONAVIT loans.

• Employers will be obligated to apply deductions even when employees do not receive their salary due to absenteeism or disability.
• Employers are required to apply deductions even when employees are not receiving their salary for any reason other than those mentioned above (any agreed suspension of the employment relation).
• Agreements to offset payments between an employee and the employee’s employer are prohibited.
• Employers will be jointly liable for an employee’s loan credit, regardless of whether the employee generates salary/income (any type of compensation).
• Employers must continue to pay the loan if an employee ceases to generate income.

Failure to comply with these obligations could result in audits or the determination of several tax credits for nonpayment of credits granted by INFONAVIT.

Compliance Period

The amendment to the INFONAVIT law establishes that employers must be given a reasonable period to comply with the new obligations. Therefore, on May 5, 2025, a resolution was published in the Official Gazette of the Federation granting employers with the period they will have to comply with their new obligations.

Employers must make adjustments to their systems and processes to determine, make, and enter deductions from the salaries of employees who are granted loans within the fourth bimester of 2025 (this bimester corresponds to the months of July and August). However, evidence of compliance must be presented before September 17, 2025.