MINTRAB Salary Book Fine 2026: Minimum Wages, Not Quetzales Per Day

Correction (20 August 2026): an earlier version of this page stated that the salary-book fine was Q3 to Q14 per day of non-compliance per worker, that recidivism doubled it, and it carried worked “inspection cases” built on that formula. All of that was wrong and has been removed. Article 272 of the Codigo de Trabajo denominates every labour fine in minimum wages, never in quetzales, and never per day or per worker. The most likely origin of the error: the pre-2017 text of Article 272 literal b) read “entre tres y catorce salarios minimos mensuales” — three to fourteen minimum wages — and those two numbers were misread as quetzales.

Summary: Failing to keep an authorized Electronic Salary Book is a breach of Article 102 of the Codigo de Trabajo. The fine comes from Article 272, as reformed by Decreto 7-2017, and it is expressed in monthly minimum wages for non-agricultural activities — for employers, ranges running from 2 to 18 wages depending on how the inspector classifies the breach. No literal of Article 272 names the salary book, so the applicable range is a classification question, not a lookup. Two rules matter more than the headline number: correcting the fault and saying so when you pay exonerates 50% of the fine, and in a labour lawsuit Article 353 presumes the worker’s figures true if you cannot produce the book when the judge orders it.

What the fine is actually denominated in

Article 272 was rewritten in full by Article 5 of Decreto 7-2017. Every single literal in the current text sets its fine as a multiple of the salario minimo mensual vigente para las actividades no agricolas — the monthly minimum wage for non-agricultural activities. For workers and trade unions some literals use daily minimum wages; for employers, all of them use monthly minimum wages.

That has three consequences the old version of this page got backwards:

1. The fine is not a quetzal figure. It moves whenever the minimum wage moves. For 2026 the non-agricultural monthly minimum is Q4,002.28 in Economic Zone 1 (Guatemala department) and Q3,816.90 in Zone 2 (rest of the country), set by Acuerdo Gubernativo 256-2025. See Guatemala Minimum Wage 2026.
2. There is no per-day multiplier. Nothing in Article 272 counts days of non-compliance. A breach is sanctioned once, within a range.
3. There is no per-worker multiplier either. The number of workers affected is one of the factors Article 271 tells the Departmental Delegate to weigh when choosing a point inside the range — alongside the economic circumstances of the sanctioned party, their record and personal conditions, the harm caused and the exposure to danger. It is an aggravating factor, not a multiplier.

Which literal applies to the salary book — and the honest answer

No literal of Article 272 mentions the salary book. That is worth stating plainly, because several published summaries in circulation (including this page’s earlier version) assert that literal c) covers it.

Literal c) in the current text covers a violation of a preceptive provision “del titulo tercero de este Codigo, otra ley y otra disposicion de trabajo y prevision social referente a jornadas o descansos” — working hours or rest days — at 6 to 12 monthly minimum wages. Article 102 does sit in Title III of the Code, but in the salaries chapter, not the hours-and-rest chapters. The pre-2017 version of literal c) also covered provisions referente a salarios; the 2017 reform dropped that word.

So the applicable range depends on how the labour inspector classifies the breach in the acta de infraccion. The two plausible frames:

Literal g) is the more natural fit for a recordkeeping obligation; literal a) is the frame an inspector would reach for when the missing book sits on top of unpaid or under-paid wages. Article 271 bis requires the acta de infraccion to state the rules breached and the proposed sanction “conforme al articulo 272 de este Codigo, de acuerdo a la graduacion de la infraccion” — so the classification is written down and is what you argue against on appeal.

The statutory scale, in quetzales

The table below converts the statutory multiples into quetzales at the 2026 minimum wage. This is the scale the Code sets, not a schedule of real fines — the amount inside each range is chosen by the Departmental Delegate under the Article 271 factors, and no real case is being described here.

Reading the two frames that matter for a missing salary book: Q8,005 to Q36,021 in Zone 1 under literal g), or Q32,018 to Q72,041 under literal a). To convert those to dollars, the Banco de Guatemala reference rate today is Q7.64 per US dollar (2026-09-26) — the history is on our exchange rate tracker. These are per-sanction figures, not annual, and they do not stack by headcount.

For workers and trade unions the same article uses daily minimum wages in several literals — a much smaller order of magnitude. This page is written from the employer’s side.

Recidivism adds 50%, and expires after a year

Article 271, as reformed by Decreto 7-2017, is explicit: “La reincidencia obliga a la imposicion de un incremento de un cincuenta por ciento (50%) en la multa incurrida. No hay reincidencia si ha transcurrido un año entre la fecha en que se hizo efectiva la multa impuesta y la fecha de comision de la nueva falta.”

Two things follow:

• The increase is 50%, not 100%. A second sanction of 9 minimum wages becomes 13.5, not 18.
• The clock runs out. If a full year separates the date the earlier fine was made effective from the date the new offence was committed, there is no recidivism at all.

The earlier version of this page attributed doubling to a “final paragraph of Article 272”. No such paragraph exists — the closing paragraphs of Article 272 deal with payment, exoneration, execution and the Registry of Labour Offences.

The 50% exoneration — the most actionable rule on this page

The reformed Article 272 closes with a payment regime that most summaries leave out entirely:

“Una vez notificada la resolucion que impone la sancion, el infractor tendra cinco (5) dias para hacer el pago correspondiente en el Ministerio de Trabajo y Prevision Social, salvo que haya interpuesto recurso de revocatoria regulado en el articulo 275 del presente Codigo. Si al momento del pago, el infractor manifiesta que corrigio la falta por la que fue sancionado, el Ministerio de Trabajo y Prevision Social exonerara el cincuenta por ciento (50%) del monto de la multa, previa verificacion del cumplimiento.”

In practice:

1. Five days to pay from notification of the resolution, unless you filed the revocatoria.
2. Fix the breach first. Authorize the book, upload the pending payrolls, keep the confirmation PDFs.
3. State the correction at the moment of payment. The exoneration is not automatic — it is triggered by the offender declaring the fault was corrected, and it is granted after MINTRAB verifies compliance.
4. Half the fine disappears. On a 9-minimum-wage sanction in Zone 1 that is roughly Q18,010 saved.

If you pay but do not show the correction, the Inspection starts the execution process under Article 426 to force you to remedy the breach anyway. If you neither pay nor correct nor appeal, the same execution process is used to collect the fine and force the correction. A resolution that is consented to or confirmed is a titulo ejecutivo (Art. 271 bis).

There is one further consequence written into Article 272 itself: to obtain or keep any tax or tariff benefit, to take part in tenders or quotations, or to contract with the State, a company may not have pending payment of administrative sanctions and correction of breaches relating to general minimum conditions of employment, work, and occupational health and safety. That is the statutory basis for the Labor Clearance blocking public procurement.

How an inspection actually runs

Article 271 bis, added by Decreto 7-2017, sets the sequence — and it starts with a warning, not a fine:

1. Inspection actions must finish within 30 business days, extendable once by up to 15 business days by the Inspector General or a Subinspector General.
2. When the inspector finds a suspected breach, they raise an acta circunstanciada de prevencion, tell the responsible party, and recommend the measures needed to comply within a reasonable period. Article 281 lit. f) sets that period at no more than 8 days when the inspector requires corrective measures.
3. The Inspection then verifies. If you complied, the file is archived by acta circunstanciada.
4. Only on non-compliance (or failure to attend a citation) does the inspector raise the acta de infraccion that opens the sanctioning file. It goes to the Departmental Delegate within 3 days, and the Delegate issues the resolution within 10 business days.
5. Inspection can also happen by citation to the Inspection’s offices rather than a site visit, where the breach and the compliance can be checked from documents alone.

The practical reading: the prevention stage is where the fine is avoided. An employer who authorizes the book and uploads the pending payrolls inside the period the inspector granted never reaches the acta de infraccion.

The bigger risk is the evidence rule — Article 353, not Article 281

The earlier version of this page said Article 281 establishes in dubio pro operario and that a judge therefore believes whatever a worker claims. That is not what Article 281 says. Article 281 lists the obligations and powers of labour inspectors — visiting workplaces, examining documents and books including electronic storage, interviewing workers without the employer present, ordering corrective measures, halting work on imminent risk. The phrase in dubio pro operario appears nowhere in the Codigo de Trabajo.

The real rule sits in the procedural title, and it is more specific and more dangerous:

Article 353: when the exhibition of documents, books of account, salary books or planillas is offered as evidence by the claimant, the judge orders it for the first hearing, warning the defendant who must produce them, on pain of a fine of fifty to five hundred quetzales for disobedience — “sin perjuicio de presumirse ciertos los datos aducidos al respecto por el oferente de la prueba”: and without prejudice to the data alleged on the point by the party offering the evidence being presumed true.

So the mechanism is real, but it is narrower and better defined than “the judge believes the worker”:

• It is triggered when the worker offers the book in evidence and the judge orders its exhibition.
• The presumption covers the data alleged about the books — wages, hours, deductions as recorded — not the entire claim.
• The Q50 to Q500 disobedience fine is trivial. The presumption is not.

A parallel rule sits in Article 30 for the written contract: its absence is always imputed to the employer, and if the employer does not produce it when the labour authorities require it, the work stipulations asserted by the worker are presumed true unless proved otherwise. And Article 137 does the same for vacation: in private companies, vacation is presumed not to have been granted if the employer cannot show the signed record. The pattern across the Code is consistent — the employer carries the documentary burden, and the salary book is the document.

This is why the book matters more than the fine, and it is a claim we can source. What we cannot source, and therefore do not publish, is any figure for what a specific collective lawsuit costs.

How to appeal

The route in the earlier version of this page — reposicion before the inspector, then revocatoria before the Minister, then a three-month window for the administrative court — is not what the Code says. The statutory route:

Step 1 — Recurso de revocatoria (Art. 275). Filed in writing before the administrative unit of MINTRAB within 48 hours of notification of the resolution. The unit must immediately elevate the file to the Ministry, which must resolve within a non-extendable 8 days, revoking, confirming or modifying. If 8 days pass with no decision, the administrative route is deemed exhausted and the recurso deemed denied. Filing the revocatoria also lifts the 5-day payment obligation — Article 272 attaches it “salvo que haya interpuesto recurso de revocatoria regulado en el articulo 275”.

Reposicion under the same article exists, but it is for resolutions originating from the Ministry itself — not for a Departmental Delegate’s sanction.

Step 2 — Contencioso administrativo de Trabajo y Prevision Social (Art. 415 and 417). After exhausting the revocatoria, the action is brought before the Labour and Social Welfare Court of the jurisdiction where the work is performed, within 20 business days of notification of the revocatoria decision. Where the infraction concerns general minimum conditions of employment, work, health and safety, you must first prove you adopted the measures that guarantee compliance in order to bring the action. A single oral hearing is held within 10 business days of admission, and the judge rules at that hearing or within 3 business days.

Step 3 — Apelacion (Art. 418). Against the judgment, within 3 days. The appeal chamber gives the parties 48 hours to state grievances and resolves within 5 days.

If the sanction becomes final, execution runs under Article 426, and the right to bring that execution action prescribes in 3 months from the resolution becoming final.

How to avoid the fine

1. Authorize the book. Go to librosalarios.mintrabajo.gob.gt, create a user account with the company NIT, request authorization. Free, 3-5 business days, the documentary requirement is an up-to-date RTU. Full walkthrough: Electronic Salary Book MINTRAB.

2. Upload the payroll every month. The obligation is continuous. The Code does not fix a calendar day for the upload — see monthly filing deadlines — but keeping the book current and consistent with what you report to IGSS is what keeps you out of a cross-checked inspection.

3. Keep the supporting documents. Even with an electronic book, the file that survives a hearing includes signed individual contracts (registered via RECIT), monthly IGSS slips, signed pay stubs with CUI, ISR withholding statements, and proof of Bono 14 and Aguinaldo paid.

4. If an inspector has already been. Read the acta: a prevencion gives you a period to comply and the file is archived if you use it. An acta de infraccion starts the sanctioning file — from there, the two levers are the 48-hour revocatoria and the 50% exoneration for correcting the fault before you pay.

Related procedures

• Electronic Salary Book MINTRAB — main procedure page (how to authorize it)
• Monthly filing deadlines — what the law does and does not fix
• RECIT — Electronic Contract Registry — separate registration obligation
• MINTRAB Labor Solvency Certificate — blocked while a sanction is unpaid or uncorrected
• IGSS Employer Registration — the payroll data the book must reconcile with
• Severance and Labor Benefits Calculation — calculation base in a lawsuit
• Bono 14 Calculator — a separate payment obligation
• Guatemala Minimum Wage 2026 — the unit every Article 272 fine is measured in
• MINTRAB Hub Guatemala — all Ministry procedures

Official links

• Electronic Salary Book Portal
• MINTRAB — General Labor Inspectorate
• MINTRAB — main site
• Codigo de Trabajo, Decreto 1441 (Articles 102, 271, 272, 275, 281, 353)
• General Directorate of Labor
• Ministerial Agreement 124-2019 (Electronic Salary Book Regulation)
• Online labor complaint

Practical conclusion: the salary-book sanction is a single fine measured in monthly minimum wages, not a daily meter running against your headcount. The plausible employer bands are 2 to 9 minimum wages under the catch-all, or 8 to 18 if the inspector frames it as a salaries-and-benefits breach. Half of whatever lands can be exonerated by correcting the fault and saying so when you pay. And the reason to keep the book is not the fine at all — it is Article 353, which lets a worker’s figures stand as true when the employer cannot produce the book the judge ordered.