Nearly one year after the amendments to Mexico’s Federal Labor Law concerning rest periods during the workday, popularly referred to as the “Chair Law”, came into effect, the compliance landscape for employers in Mexico has changed dramatically. If 2025 was the year of physical adjustments, when many companies mistakenly equated compliance with simply purchasing chairs, 2026 is shaping up to be the year of operational enforcement. And it is precisely at this stage that many workplaces across Mexico are revealing significant vulnerabilities.

In recent practice, we have observed that the enforcement criteria of Mexico’s Department of Labor have evolved. Labor inspectors are no longer limiting their review to a visual walkthrough to count the number of seats available on the floor. Instead, inspections now focus on verifying the actual and effective availability of seating for employees to use during rest periods within the workday, as required under Mexican labor regulations.

The core issue we are seeing is not necessarily the absence of chairs, but rather the tacit prohibition against using them. Many employers in Mexico still maintain formal rules, or unwritten “floor policies”, that discourage or even penalize employees for sitting, based on the outdated premise that “if you are sitting, you are not working.” This disconnect between having chairs on-site and allowing employees to use them has become one of the primary triggers for fines imposed by the Department of Labor during workplace inspections.

The employer’s Achilles’ heel lies in internal documentation. The reform was not merely logistical; it was regulatory. If a company has not conducted a supporting internal assessment and its Internal Work Regulations remain unchanged, failing to specify the timing, designated areas, and conditions for employee rest, there is a formal compliance gap, regardless of how ergonomic the chairs may be. Mexican labor authorities are demanding documentary consistency: the chair alone is not enough; internal policies must clearly reflect the new legal framework.

Additionally, there is a workplace safety component that is often overlooked. This is not about placing just any stool or seat on the production floor. If seating obstructs an emergency evacuation route, or if its design interferes with the safe operation of machinery, an inspection initially focused on “general working conditions” can quickly escalate into a review of occupational health and safety compliance under Mexican standards, where penalties are considerably more severe.

The recommendation for employers operating in Mexico is straightforward and pragmatic: conduct a comprehensive internal review, involve the legally mandated joint employer-employee committees, and formally update the Internal Work Regulations to align with actual workplace practices. Inspectors are interviewing employees directly to determine whether rest periods are genuinely permitted or merely theoretical, significantly increasing enforcement exposure.

Now is the time to act proactively to ensure that what began as an investment in furniture does not result in financial penalties stemming from preventable labor management deficiencies under Mexican law.