In light of the regulatory changes and compliance obligations that will impact employment relationships as of July 2026, we are pleased to present an overview of the key legal and operational developments that employers should consider. These include, in particular, the phased implementation of Law 2466 of 2025, the final stage of the statutory reduction of the maximum working week established under Law 2101 of 2021, and other complementary regulations relating to labor law and occupational health and safety.

Accordingly, employers should undertake a comprehensive review of their working time arrangements, payroll practices, internal work regulations, management systems, and employment-related procedures to ensure compliance with the applicable legal requirements and to mitigate potential risks arising from their implementation.

Set out below are the key developments to consider:

1. IMPLEMENTATION OF THE FORTY-TWO (42) HOUR MAXIMUM STATUTORY WORKING WEEK

As a result of the phased implementation established under Law 2101 of 2021, effective 15 July 2026 the statutory maximum working week has been reduced to forty-two (42) hours. This reduction must be implemented without affecting employees' salaries, statutory benefits, vested rights, or any other employment rights and protections.

With respect to the distribution of working hours, current legislation provides that the weekly working time may be agreed between the employer and the employee over five (5) or six (6) working days, provided that the applicable daily and weekly statutory limits, as well as mandatory rest periods, are observed.

Employers may maintain their existing work schedules and operational arrangements, provided that they comply with the new statutory limits and do not exceed the maximum weekly working hours established by law.

In this context, employers should review their current working time arrangements, including shift schedules, flexible working arrangements, attendance monitoring mechanisms, and the parameters used to calculate overtime, statutory premium payments, and the ordinary hourly rate, which serves as the basis for calculating overtime and statutory surcharges.

2. ELIMINATION OF MANDATORY FAMILY DAY AND WEEKLY EMPLOYEE WELFARE ACTIVITIES

Recent amendments to Colombian labor legislation have also modified certain employer obligations relating to employee welfare activities.

First, the mandatory Family Day is no longer a legal obligation for employers. Following the entry into force of Law 2466 of 2025, the semi-annual Family Day changed from a mandatory obligation to a voluntary initiative that employers and Family Compensation Funds may continue to promote and facilitate. This amendment has been effective since 25 June 2025.

Likewise, the obligation established under Law 50 of 1990 requiring employers to allocate two (2) hours per week to recreational, cultural, sports, or training activities has been permanently eliminated as of 15 July 2026, upon completion of the phased implementation of the forty-two (42) hour maximum statutory working week.

Nevertheless, employers should bear in mind that the elimination of these statutory obligations does not necessarily allow them to discontinue these benefits automatically. Where such benefits have been incorporated into employment agreements, internal work regulations, collective bargaining agreements, collective pacts, internal policies, or constitute contractual or extra-statutory benefits granted by the employer, any modification or elimination should be carefully assessed.

Accordingly, we recommend that employers review the legal basis of each benefit before making any changes, in order to avoid potential claims relating to vested rights or previously recognized employment conditions.

3. SURCHARGE FOR WORK ON MANDATORY REST DAYS INCREASE

As part of the phased implementation of Law 2466 of 2025, effective 1 July 2026 the statutory premium for work performed on mandatory weekly rest days and public holidays increased from eighty per cent (80%) to ninety per cent (90%).

The law also provides for a further increase, raising the premium to one hundred per cent (100%) as of 1 July 2027.

In light of this amendment, employers should review the configuration of their payroll systems and verify that the applicable premium rates have been properly updated to ensure compliance with current legislation. Likewise, employers should review their shift arrangements and compensatory rest mechanisms, particularly when operations are conducted on a continuous basis or when employees are required to work on statutory rest days or public holidays.

Failure to implement these changes correctly may result in payroll discrepancies, salary adjustments, and potential employment claims.

4. REVIEW OF NIGHT WORK PREMIUMS AND UPDATE OF THE ORDINARY HOURLY RATE

Although the amendment relating to night work became effective on 25 December 2025, it is worth recalling that Law 2466 of 2025 redefined daytime and nighttime working hours.

Under the amended legislation, night work is defined as work performed between 7:00 p.m. and 6:00 a.m. the following day, while daytime work corresponds to the period between 6:00 a.m. and 7:00 p.m. The statutory night work premium remains thirty-five per cent (35%) of the employee's ordinary hourly rate.

However, with the entry into force of the 42-hour maximum statutory working week on July 15, 2026, employers should once again review the parameters used to determine the ordinary hourly rate, as this constitutes the basis for calculating overtime payments and statutory premiums.

Accordingly, employers are encouraged to conduct a comprehensive review of their payroll systems and compensation practices to verify the proper calculation of overtime, night work premiums, and premiums for work performed on mandatory rest days, thereby ensuring compliance with the applicable legal framework and preventing potential payroll discrepancies.

5. UPDATE OF INTERNAL WORK REGULATIONS AND DISCIPLINARY PROCEDURES

In light of the amendments introduced by Law 2466 of 2025, employers are required to update their Internal Work Regulations to incorporate the new rules governing disciplinary proceedings and the minimum due process guarantees applicable to disciplinary actions.

Under the Labour Reform, employers were required to complete this update within twelve (12) months following the entry into force of the law. That deadline expired on June 25, 2026. Employers must also ensure that the updated Internal Work Regulations are made permanently available to employees through the company's physical and/or electronic communication channels.

In addition, Law 2466 of 2025 strengthens employees' due process rights by establishing that, at a minimum, disciplinary proceedings must include the following stages:

1. Formal notification of the commencement of the disciplinary process.
2. A clear description of the facts under investigation and the potential consequences arising from them.
3. Disclosure of the evidence supporting the disciplinary action, ensuring the employee's right to challenge such evidence and exercise their defense
4. A reasonable opportunity for the employee to present their defense, within a period of no less than five (5) business days following notification of the commencement of the disciplinary proceedings.
5. Adoption of a reasoned decision based on principles of proportionality and reasonableness.
6. The possibility of appealing the decision, where applicable under the relevant legal framework.

In light of these developments, employers should verify that their Internal Work Regulations, disciplinary procedures, and internal practices are fully aligned with the new legal requirements. Disciplinary measures imposed without observing the minimum due process guarantees may expose employers to labor disputes and challenges regarding the validity of the sanctions imposed.

6. REGISTRATION OF TELEWORKERS THROUGH THE TELEWORKER REGISTRATION SYSTEM (SISTEL)

The Ministry of Labor has launched the Teleworker Registration System (SISTEL), an institutional platform designed to register, monitor, and update information relating to employees engaged under teleworking arrangements.

Accordingly, employers implementing any form of teleworking are required to register the relevant information concerning their teleworkers in SISTEL and to keep such information up to date whenever there are changes to the reported conditions, including changes in position, work location, teleworking modality, or employment status.

The implementation of SISTEL introduces a new monitoring and traceability mechanism through which the labor authorities may oversee remote working arrangements. Employers are therefore encouraged to verify that the information recorded in the system accurately reflects the current terms and conditions of their employment relationships.

Accordingly, we recommend conducting an internal review of all employees working under teleworking arrangements, the conditions currently reported, and the supporting documentation maintained by the company, in order to ensure consistency between the information registered in SISTEL and the company's records, and to mitigate potential risks during labor inspections.

7. ANNUAL REPORTING OF THE OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT SYSTEM (SG-SST)

By July 31, 2026, employers and contracting entities must submit, through the Ministry of Labor’s online platform (sgrl.mintrabajo.gov.co), the self-assessment of the Minimum Standards applicable to the Occupational Health and Safety Management System (SG-SST) for the 2025 reporting period, together with the corresponding improvement plan derived from such assessment, in accordance with Article 26 of Resolution 0312 of 2019 and Ministry of Labor Circular No. 027 of 2026.

Accordingly, employers should verify that the information submitted accurately reflects the company's actual occupational health and safety practices and is supported by appropriate documentation, thereby ensuring compliance with current legal requirements and facilitating any inspections or requests from the labor authorities.

8. PUBLICATION AND REPORTING OF INFORMATION RELATING TO WORKPLACE SEXUAL HARASSMENT

Pursuant to Law 2365 of 2024, employers are required to publish, on a semi-annual basis, information regarding the number of workplace sexual harassment complaints processed and the sanctions imposed in connection with such cases.

This information must be disclosed through the company's available physical and/or electronic communication channels and submitted to the Integrated Gender-Based Violence Information System (SIVIGE) within ten (10) days following the end of each reporting period.

At present, however, the SIVIGE platform has not yet become operational. Consequently, until the official reporting mechanism is available, the Ministry of Labor has established an alternative reporting procedure, whereby the required reporting form must be submitted via email to solucionesdocumental@mintrabajo.gov.co.

Accordingly, in order to comply with this obligation, employers are encouraged to:

• Accordingly, in order to comply with this obligation, employers are encouraged to:
• Submit the completed form to the Ministry of Labor through the designated reporting channel and retain evidence of its submission.
• Publish the required information internally through the company's available physical and/or electronic communication channels, while maintaining evidence of such publication.

It is important that all published and reported information be properly anonymized, ensuring that no data is disclosed that could directly or indirectly identify the individuals involved in the reported cases. This is essential to safeguard privacy, confidentiality, and the due process rights of all parties concerned.

Finally, employers should retain all supporting documentation evidencing compliance with these obligations, including the completed reporting form, proof of submission to the Ministry of Labor, and evidence of internal publication, in anticipation of any future inspections or requests from the competent authorities.

9. NEW NATIONAL PUBLIC HOLIDAY AND PAID MANDATORY REST DAY IN COLOMBIA

Law 2578 of 2026 established the Day of Our Lady of the Rosary of Chiquinquirá, observed annually on July 9, as a national public holiday and a paid mandatory rest day throughout Colombia.

Accordingly, employees in both the public and private sectors are entitled to paid leave in connection with this national holiday.

However, the law provides that the date on which the paid rest day is observed is governed by Law 51 of 1983 (the Emiliani Law), pursuant to which transferable public holidays that do not fall on a Monday are moved to the following Monday. Likewise, where the commemorative date falls on a Sunday, the corresponding paid rest day will also be observed on the following Monday.

As July 9, 2026 fell on a Thursday, the corresponding paid public holiday was observed on Monday, July 13, 2026.

10. AMENDMENTS TO THE LABOR OUTSOURCING FRAMEWORK

Through Decree 0581 of 5 June 2026, the Colombian Government amended Decree 1072 of 2015 to strengthen the Ministry of Labor’s inspection, monitoring, and enforcement powers in relation to unlawful labor outsourcing and illegal labor intermediation.

Among its principal amendments, the Decree: (i) defines the concepts of unlawful labor outsourcing, illegal labor intermediation, and permanent business activities; (ii) establishes a rebuttable presumption of the existence of an employment relationship where permanent activities are performed through third-party arrangements; (iii) introduces a series of indicators that may be considered by the labor authorities when determining whether unlawful outsourcing practices exist; (iv) further restricts the use of temporary employment agencies to the specific circumstances expressly permitted by law; and (v) strengthens the applicable corrective and enforcement measures.

From an enforcement perspective, the Ministry of Labor may now order corrective measures including the formalization of employment relationships, the regularization of social security contributions, the suspension or termination of irregular civil or commercial service agreements, and the implementation of compliance plans.

Employers should also note that companies involved in unlawful outsourcing arrangements may be subject to successive fines of up to five thousand (5,000) monthly statutory minimum wages (SMLMV), without prejudice to other enforcement measures, including the suspension of business activities or, where applicable, the revocation of the operating authorization granted to temporary employment agencies.

11. MINISTRY OF LABOR GUIDELINES ON DISCIPLINARY DUE PROCESS

Through Circular No. 048 of 2026, the Ministry of Labor issued guidelines regarding the application of Article 7 of Law 2466 of 2025, governing disciplinary due process in the private sector.

Although ministerial circulars do not create new legal obligations, they reflect the interpretative criteria adopted by the labor authorities and should therefore be taken into account by employers.

Among its key clarifications, the Circular reiterates that employers must observe the minimum stages of disciplinary proceedings introduced by the Labor Reform, including: written notification of the facts under investigation, disclosure of the supporting evidence, a period of no less than five (5) business days for the employee to prepare a defense, the opportunity to appeal the decision, and compliance with the principle of promptness.

The Circular further clarifies that warnings or written memoranda do not require the formal disciplinary procedure where they merely constitute management or supervisory measures rather than disciplinary sanctions. However, where an employer's Internal Work Regulations classify such measures as disciplinary sanctions, or where repeated warnings may give rise to disciplinary consequences, the applicable disciplinary procedure must be followed.

Finally, the Circular reiterates that dismissal for just cause does not, as a general rule, constitute a disciplinary sanction and therefore does not require a prior disciplinary proceeding. Nevertheless, the Ministry considers that such proceedings should be conducted where the dismissal is disciplinary in nature or where a legal provision expressly requires a prior procedure. In all cases, employers must ensure that employees are afforded the right to be heard and that the dismissal process complies with the principles established by the Constitutional Court.

12. GUIDELINES FOR OBTAINING AUTHORIZATION TO DISMISS EMPLOYEES PROTECTED BY REINFORCED EMPLOYMENT STABILITY

Through Circular No. 049 of 2026, the Ministry of Labor established internal guidelines governing applications for prior authorization to terminate the employment of employees protected by reinforced employment stability, implementing the criteria established by Constitutional Court Judgment SU-111 of 2025.

The Circular specifies the information and supporting documentation that employers must submit when requesting authorization, including evidence of the objective ground or just cause relied upon and, where applicable, documentation relating to any disciplinary proceedings conducted.

With respect to employees protected due to disability or a condition of manifest vulnerability, employers must also demonstrate that they have reasonably exhausted rehabilitation measures, reasonable accommodations, and alternatives for reassignment or reinstatement.

The Circular further regulates the procedure to be followed by Labor Inspectors, ensuring the employee's right to be heard, the opportunity to present evidence, and the issuance of a decision within a maximum period of three (3) months.

Finally, the Circular reiterates that prior authorization from the Ministry of Labor remains a mandatory legal requirement before terminating the employment of individuals protected by reinforced employment stability. Employers must demonstrate that the proposed termination is based on an objective or legally justified ground and does not constitute discriminatory treatment.

13. MANDATORY EMPLOYMENT QUOTAS FOR PEOPLE WITH DISABILITIES

Law 2466 of 2025 introduced a new obligation requiring employers to hire people with disabilities according to the size of their permanent workforce.

In general terms, employers with up to five hundred (500) permanent employees must employ at least two (2) people with disabilities for every one hundred (100) permanent employees. Employers with more than five hundred (500) permanent employees must hire one (1) additional employee with a disability for each additional group of one hundred (100) employees.

Employees hired to comply with this requirement must also be reported to the Ministry of Labor.

It should be noted that this obligation is independent from the tax incentives established under Law 361 of 1997, which remain in force and continue to grant tax benefits to employers hiring people with disabilities who satisfy the applicable legal requirements.

Accordingly, employers should review the number of permanent employees within their workforce to determine whether this new obligation applies to them and, where applicable, adopt the necessary measures to ensure compliance, including obtaining the relevant disability certification and completing the corresponding reporting requirements before the Ministry of Labor.

14. OBLIGATION TO ADOPT AND UPDATE INTERNAL POLICIES ON THE PREVENTION OF WORKPLACE HARASSMENT AND SEXUAL HARASSMENT

Employers are required to maintain separate internal policies addressing the prevention of workplace harassment and workplace sexual harassment, in accordance with Law 1010 of 2006, Law 2365 of 2024, and Law 2466 of 2025.

With respect to sexual harassment, Law 2365 of 2024 requires employers to adopt an internal prevention policy reflected in the company's Internal Work Regulations, employment agreements, internal protocols, reporting mechanisms, and response procedures, while ensuring that such policy is properly communicated to employees. Employers must also implement effective mechanisms for preventing and addressing complaints of sexual harassment, guarantee measures aimed at preventing recurrence, and comply with the applicable reporting obligations.

Additionally, Law 2466 of 2025 reinforces employers' duty to provide workplaces free from violence and harassment, regardless of the form of employment, through the implementation of effective protocols, procedures, and preventive measures consistent with the workplace harassment framework established under Law 1010 of 2006.

Accordingly, employers should review and update their internal documentation to ensure that they maintain, as separate instruments:

• A workplace harassment prevention policy, together with the corresponding reporting and case-management mechanisms overseen by the Workplace Coexistence Committee.
• A workplace sexual harassment prevention policy, including reporting channels, confidentiality safeguards, and protective measures.
• Updated internal protocols and procedures reflecting the current legal framework.
• Communication and training mechanisms designed to ensure that employees are properly informed of these policies.

This review is particularly important given the Ministry of Labor’s inspection and enforcement powers in this area, as failure to comply with these obligations may result in administrative sanctions.

15. FINAL RECOMMENDATIONS

Considering the regulatory changes taking effect as of July 2026, we recommend that employers undertake a comprehensive review of their employment practices, with particular attention to working time arrangements, payroll calculations, and compliance with the applicable formal and documentary obligations.

In particular, employers should verify the proper implementation of the 42-hour maximum statutory working week, update the parameters used to calculate overtime and statutory premium payments, ensure the correct application of the new premium rates for work performed on mandatory rest days, and, where applicable, update and publish their Internal Work Regulations.

Employers should also confirm compliance with the obligations relating to teleworking, the Occupational Health and Safety Management System (SG-SST), and the reporting requirements concerning the prevention of workplace sexual harassment, ensuring in all cases that adequate documentary evidence is maintained to demonstrate compliance.

These reviews will enable employers to anticipate potential employment-related contingencies, strengthen their internal compliance processes, and ensure a smooth transition in light of the regulatory changes applicable throughout 2026.

We hope that this bulletin provides useful guidance for navigating the regulatory changes and employment obligations currently in force. At MTA, we remain available to assist our clients with the implementation of these new requirements and to provide legal advice on any challenges that may arise in their application.

Should you have any questions or require further assistance, please do not hesitate to contact us.