On March 3, 2025, we reported on the amendments to the INFONAVIT Law and the Federal Labor Law, highlighting the impact that the changes to Article 29 of the INFONAVIT Law could have on companies and their employees. Initially, these modifications raised concerns in the business sector due to the obligation to cover mortgage loan amortizations for employees during periods of incapacity or absence, even when they do not receive a salary.

However, on March 13, 2025, INFONAVIT published a clarification that provides greater clarity and certainty regarding the implementation of this reform:

1. Deductions applied to workers during periods of incapacity or absences must be calculated proportionally, ensuring that the amount withheld matches that specified in the “notice of withholding discounts.”
2. These deductions may not exceed the salary actually paid to the worker or the limits established in Article 97 of the Federal Labor Law.
3. If the salary paid to the worker is insufficient to cover the full deduction, the employer is not obligated to cover the uncollected amount.

Although this criterion is not binding, it serves as a reliable guide to avoid potential errors in withholding discounts and reduces the risk of labor disputes. We recommend that companies focus on correctly implementing these provisions.

At Calderón Marín, we remain attentive to any further official updates that may arise, and we are available to assist you in the proper implementation of these measures and to mitigate any labor or social security risks. If you need additional guidance, please do not hesitate to contact us.