Regulatory Update
Internal Work Regulations: The June 25, 2026 Deadline Has Passed
Law 2466 of 2025 gave companies twelve months to update their internal work regulations. That deadline was met on June 25, 2026. If your company has not updated its regulations yet, the obligation still stands: the deadline passing does not remove it, and outdated regulations leave a company exposed in any disciplinary process or labor claim that depends on them. The reform did not rewrite internal work regulations from top to bottom. It changed two specific things and left the rest as it was, although that is not always how it gets reported.
Schedule a consultationThe deadline has passed: what to do now
If your internal work regulations do not yet include the two changes brought by Law 2466 of 2025 (the disciplinary procedure under Article 115 and the mandatory digital publication under Article 120, both explained below), the update is still pending. The law does not set an automatic fine simply for missing the deadline, but regulations that do not reflect the current disciplinary procedure can weaken any sanction the company imposes based on them, and before a labor judge, outdated regulations work against the company, not in its favor. The prudent course is to review the regulations now, not wait for a disciplinary process or an inspection to force the issue.
Two real changes, not twenty
Various sources circulating about this reform list changes that the law's text does not contain. Only two articles governing internal work regulations actually changed.
Article 115: A More Detailed Disciplinary Due Process
Article 115 of the Colombian Labor Code, which governs the procedure for applying disciplinary sanctions, now requires a seven-step process: formally notifying the worker in writing that the process is opening, stating in writing the facts or conduct that motivate it, giving the worker access to all the evidence, allowing the worker to respond to those grounds and challenge the evidence (with a term the law sets at no less than five days), issuing a reasoned final decision, imposing a proportional sanction where applicable, and recognizing the worker's right to appeal the decision. Domestic workers and microenterprises with fewer than ten workers fall outside this formal process, although they must still hear the worker out under basic due-process guarantees.
Article 120: Mandatory Digital Publication
Article 120 already required posting two legible copies of the regulations in two different locations at the workplace. The reform adds that publication must also be digital, so workers can access the regulations at any time: for example, by posting them on the company's website if it has one, or sending them through a company-owned digital channel, with a record of that communication kept on file. When a company has several worksites, digital publication removes the need to post physical copies at each one.
What the reform did not change
Three things circulate as if they were part of this reform, and they are not.
The worker threshold that requires a company to have internal work regulations is still the one set by Article 105 of the Colombian Labor Code, and it did not change: more than five permanent workers for commercial companies, more than ten for industrial companies, and more than twenty for agricultural, livestock, or forestry companies; for companies with mixed activities, the threshold is more than ten. That is a different threshold from the one that applies, for example, to the Joint Committee on Occupational Health and Safety, and the two should not be confused.
Internal work regulations have not required approval from the Ministry of Labor since Law 1429 of 2010 removed that requirement. They still do not require it.
The right to disconnect from work, which some sources mention alongside this reform, comes from Law 2191 of 2022, not from Law 2466 of 2025.
Updating internal work regulations to reflect these two changes, rather than the longer list that circulates, is how a company complies with the reform without rewriting a document that otherwise remains in force as it was.
