REPSE: registration, renewal and oversight of contracted services

Industrial facilities. Illustrative image of specialised services.

Key points

Compare the contracted service, the registered activity and the work that will actually be performed.
Distinguish the application, registration notice, information updates and renewal; check the applicable requirements and validity period.
Link active contracts with their expiry dates, responsible personnel and evidence of performance.

Identifying the activity and applicable registration

The Federal Labour Law permits the subcontracting of specialised services or works that fall outside the recipient's corporate purpose and predominant economic activity, subject to the contractor's registration under Article 15. This rule requires analysis of the specific activity; a supplier's commercial description does not, by itself, determine its classification. [1]

For the contracting business, a useful review compares the requested service, the registered activity and the work that will actually be performed. It is worth defining who checks that alignment before contracting and how it will be reviewed if the scope expands, the workplace changes or the service arrangement is modified.

Registration and procedural simplification in 2026

The agreement published on 9 June 2026 introduced simplification measures and different documentation requirements for REPSE applications by individuals or legal entities with up to ten workers and those with more than ten. A checklist prepared before that agreement should therefore not be used as a universal reference without checking that it is current. [3]

From an application-management perspective, it is useful to identify the procedure requested, the current corporate information and the supporting documents to be submitted. A person responsible for follow-up can retain acknowledgements, respond to requests and communicate the outcome to those administering contracts. Internal controls should distinguish submission of an application from the registration notice.

Renewal and monitoring validity

The Federal Labour Law requires renewal every three years. The agreement of 21 February 2024 regulates the three-month window preceding expiry, according to the applicable timetable. The specific date should be checked against the notice and relevant procedure; updating information is not equivalent to renewing registration. [1] [2] [4]

As a business control, a calendar can link expiry dates, active contracts and responsible personnel. An advance review helps identify documentary discrepancies and seek timely clarification from the provider. It also avoids procurement and operations relying on different copies of the notice or a validity period that nobody has checked.

Written contracts and evidence of performance

Article 14 requires a written contract stating the service or works and the approximate number of participating workers. It also provides for joint and several liability of the contracting party where the contractor fails to fulfil its employment obligations, in relation to the workers used for that contract. [1]

Contract administration can bring together scope, deliverables, supervisory responsibilities, authorised changes and evidence of acceptance. Reviewing these elements alongside registration validity helps explain what was contracted and what was received. The file is more useful when procurement, operations and legal teams can consult the same documentation throughout the relationship.