Key points
- Distinguish matters governed by internal work regulations from technical and administrative instructions.
- Form the joint committee and meet the filing and communication requirements of the Federal Labour Law.
- Review disciplinary rules and consistency with contracts and actual working practices.
Distinguish the internal instruments
A company may have operating manuals, codes of conduct, human resources policies and internal work regulations. Although used together, they serve different purposes. Before documents are updated, the company should identify which rules govern the performance of work and which concern instructions for technical or administrative execution of particular tasks.
Article 422 of the Federal Labour Law defines internal work regulations and excludes technical and administrative instructions issued directly by the company for carrying out work. A document's title does not determine its nature: calling a rule a policy does not settle its substance or the formalities that may apply. [1]
Review the content against actual operations
Article 423 covers matters including starting and finishing times, meals and rest periods, leave, risk prevention and disciplinary provisions. Review should establish whether the rules are clear and workable at the particular workplace, considering shifts, departments, supervisory responsibilities and the channels used to report incidents in day-to-day operations. [1]
Disciplinary rules require particular care. Suspension as a disciplinary measure cannot exceed eight days, and the employee has the right to be heard before a sanction is imposed. Documentation should identify the alleged conduct, applicable rule and procedure followed, without automating decisions on the basis of isolated reports. [1]
Document formation, filing and communication
The law requires internal work regulations to be prepared by a joint committee of employee and employer representatives. Where agreement is reached, either party must file them with the CFCRL within eight days after signature. Provisions contrary to employment legislation or collective agreements have no legal effect. [1]
The simplification agreement published on 19 August 2026 updates the requirements: an online form, the regulations in PDF and the record establishing the joint committee, with an annex establishing the identity and legal capacity of the signatories and applicant. It also removes proof of address. General guidance pages should be checked against these requirements and the rules applicable on the filing date, rather than reusing earlier lists in full. [2] [3]
Signatures, powers and consistency between attachments should be checked. Under Article 425, the regulations take effect upon filing and must be printed, distributed to employees and displayed prominently. [1]
Maintain consistent and accessible versions
After filing, human resources needs to retain the text and filing evidence, withdraw outdated versions from operational use and coordinate communication. Managers should know which rules they may apply and which decisions need review. Distributing a document without explaining its use may leave the practices that prompted its update unchanged.
Periodic review can identify conflicts with individual contracts, collective instruments or new working arrangements. Amendments should follow the process appropriate to their substance; an internal circular should not replace legal formalities. The usefulness of internal work regulations depends both on their proper adoption and on consistent application across the relevant workplace.
Sources consulted
- Federal Labour Law Articles 422, 423 paragraph X, 424 paragraphs I to III, and 425.
- Registration of internal work regulations: filing requirements Requirements section, items 2 to 7, as administrative context. The complete list must be checked against the Agreement published on 19 August 2026; the proof of address in item 8 is not adopted as a current requirement.
- Agreement establishing simplification measures for procedures before the Federal Centre for Labour Conciliation and Registration Official Gazette of 19 August 2026. Article One, table, item 2; Article Four, table, item 2, procedure CENFECOREL-2021-326-029; Articles Six and Seven and first and second transitional provisions.
General information. Application to a particular matter requires assessment of its circumstances and the provisions in force.
