MINTRAB Salary Book vs SAT Payroll Guatemala 2026: Which Do You Need? (Both)

Summary: The Electronic Salary Book (MINTRAB) and the SAT Payroll are two SEPARATE obligations that the employer must comply with IN PARALLEL. The MINTRAB book fulfills Article 102 of the Labor Code (labor obligation, only if you have 10+ workers). The SAT payroll fulfills the ISR Law (tax obligation, from the first worker). They are not interchangeable: complying with one does not exempt you from the other. Both are free, monthly and 100% online.

What each one is

Electronic Salary Book (MINTRAB)

This is the mandatory labor registry where the employer records monthly payroll for workers. It is administered by the Ministry of Labor and Social Welfare through the General Directorate of Labor, at the portal librosalarios.mintrabajo.gob.gt.

• Legal basis: Article 102 of the Codigo de Trabajo (Decreto 1441) + Ministerial Agreement 124-2019.
• Who: employers permanently occupying 10 or more workers. Below that, from 3 workers up, Art. 102 requires planillas on the IGSS models instead.
• Purpose: evidence in labor lawsuits, base for severance calculations, requirement for Labor Solvency.
• Core data: work hours, days worked, overtime, incentive bonus, net salary, payment method.

See full guide: MINTRAB Electronic Salary Book.

SAT Payroll

This is the monthly tax filing where the employer reports to SAT how much ISR (income tax) was withheld from workers and how much IGSS was paid. It is administered by the Tax Administration Superintendence (SAT) through Agencia Virtual SAT.

• Legal basis: Tax Update Law (Decree 10-2012, Art. 67-72) + Tax Code (Decree 6-91).
• Who: every employer with at least 1 worker in a dependent relationship.
• Purpose: remit withheld ISR to SAT, support employer deductions and obtain Tax Solvency.
• Core data: ISR withheld, monthly taxable base, IGSS paid by employer and worker.

Side-by-side comparison table

Which do you need? (5-question quiz)

To figure out which obligations apply, answer these 5 questions:

1. Do you have at least 1 worker in a dependent relationship (fixed salary, schedule, subordination)?

   • Yes → you need SAT Payroll.
   • No → you need neither (you are self-employed or an independent professional).

2. Are those workers 10 or more permanent?

   • Yes → you also need MINTRAB Book.
   • No (1-9 workers) → only SAT Payroll is mandatory. MINTRAB Book is optional.

3. Are you registered as a patron with IGSS?

   • Yes → you already meet the prerequisite. Proceed with payroll and book.
   • No → first complete IGSS Patron Registration. Without a patron number, neither MINTRAB nor SAT will validate the payroll.

4. Is your SAT RTU up to date (less than 6 months)?

   • Yes → you can operate both portals.
   • No → first update your RTU. MINTRAB cross-references with SAT and rejects expired RTUs.

5. Do you pay your workers above Q48,000 per year (about Q4,000/month net)?

   • Yes → in addition to payroll, there is actual monthly ISR withholding. Calculating the withholding correctly is critical.
   • No → SAT payroll is still filed but ISR withholding may be Q0. The administrative obligation does not disappear.

Quiz results:

What happens if you only do one

Case A — You only file SAT Payroll, skip MINTRAB Book

This is the most common mistake: the accountant files the monthly SAT payroll and the employer assumes “I’m up to date.” But MINTRAB never finds out — these are separate systems that do NOT sync automatically.

Likely consequences:

• MINTRAB fine: a single sanction under Art. 272 of the Codigo de Trabajo, set in monthly minimum wages — the catch-all in literal g) runs 2 to 9 for employers, roughly Q8,005 to Q36,021 at the 2026 Zone 1 minimum of Q4,002.28. It is not a per-day or per-worker meter; headcount and duration push the amount up inside the range (Art. 271), they do not multiply it.
• Labor Solvency blocked: without a current book, no Electronic Labor Solvency — and Art. 272 itself bars a company with pending sanctions and uncorrected breaches from tax or tariff benefits, tenders, and State contracting.
• Lawsuit vulnerability: Article 353 of the Codigo de Trabajo lets a worker offer the salary book or planillas in evidence; the judge orders their exhibition for the first hearing, and an employer who disobeys is fined Q50 to Q500 and the data alleged by the worker on that point is presumed true. That is the real mechanism — the phrase in dubio pro operario does not appear in the Code, and Article 281 (often cited for it) simply lists the powers of labour inspectors.
• MINTRAB inspection: the General Labor Inspectorate can arrive unannounced. It cross-references your IGSS patron number against the book system. If you have IGSS up to date but an empty book, the alarm goes off.

Case B — You only keep the MINTRAB Book, skip SAT Payroll

Less common but equally serious. Happens when the employer delegates the book to an administrative assistant but has no external accountant.

Likely consequences:

• SAT fine: Q50 per day of delay, capped at Q1,000 per filing (Art. 94 num. 9 Tax Code, as reformed by Decreto 4-2012), plus resarcitorio interest at the rate the Junta Monetaria sets each semester (12.97% annual in the second half of 2026 — check Banguat for the current rate) on unremitted ISR.
• Tax Solvency blocked: without a current payroll, SAT does not issue Tax Solvency — blocks sales to large companies, government contracts, imports, exports.
• RTU blocked: if the omission extends, SAT can deactivate your RTU. Without an active RTU you cannot invoice or formally collect payments.
• The 100% fine plus criminal liability: if you withheld ISR from worker wages but didn’t remit it to SAT, the first penalty is a fine equal to 100% of the withheld tax (Art. 91 Tax Code, halved if you pay before SAT’s formal demand) — and it is also the crime of misappropriation of taxes (Art. 358 “C” Criminal Code, 1 to 6 years plus a fine equal to the tax). Not just a fine — there is risk of criminal proceedings.

Case C — You skip both

You accumulate both penalties at once. Worse: you lose Labor Solvency AND Tax Solvency. Any bank, supplier or client that checks solvency will detect it. Sustainable operations become impossible.

Special cases

Self-employed / independent professional (no employees)

• SAT Payroll: Does not apply (no workers to report).
• MINTRAB Book: Does not apply.
• Your obligations are different: monthly VAT filing, annual ISR filing (optional regime or on profits), RTU up to date. See SAT Hub.

Micro-business (1 to 9 workers)

• SAT Payroll: Yes — from the first worker. No size exceptions.
• MINTRAB Book: Not mandatory, but voluntary use is recommended. When your business grows past 10 workers, you will already have the system running without urgency. Also protects in labor lawsuits.

Small/medium business (10 to 50 workers)

• SAT Payroll: Yes — mandatory monthly.
• MINTRAB Book: Yes — mandatory monthly, plus one-time initial authorization.
• Recommendation: external or dedicated internal accountant. The volume crosses the threshold where one person can no longer handle SAT payroll, MINTRAB book, IGSS and benefits simultaneously.

Business with seasonal workers (sugar cane, harvest, construction)

• If contracts exceed 90 continuous days, they are legally permanent workers — counted toward the 10-worker MINTRAB threshold.
• SAT Payroll still reports them during the months they are active.
• The Labor Code does NOT allow using the “temporary” label to evade the book obligation.

Business with professional service contractors (no dependency)

• If the relationships are genuine professional services (no fixed schedule, no subordination, they issue invoices), they go on NEITHER the SAT payroll NOR the MINTRAB book. They pay their own VAT and ISR.
• But be careful: if there is a hidden labor relationship in practice (schedule, office, direct boss), both SAT and MINTRAB can reclassify and demand retroactive payrolls with interest.

Penalties for each one

MINTRAB penalties (for omitting the Salary Book)

Article 272 of the Codigo de Trabajo (Decreto 1441), as reformed by Decreto 7-2017. Every fine below is a single amount in monthly minimum wages for non-agricultural activities — Q4,002.28 in Economic Zone 1, Q3,816.90 in Zone 2 (Acuerdo Gubernativo 256-2025). No literal of Art. 272 names the salary book, so a book breach is classified by the inspector; the catch-all is the natural fit.

SAT penalties (for omitting Payroll)

Articles 88 and 94 of the Tax Code (Decree 6-91) and ISR Law:

Comparison in numbers — 20-worker company, 12-month omission:

• MINTRAB only: one fine in monthly minimum wages per determined infraction (catch-all range 2-9 wages = Q8,004-Q36,020 at the 2026 CE1 minimum) + loss of Labor Solvency.
• SAT only: Q50 per day of delay capped at Q1,000 per filing (a year of chronically late filings can approach Q12,000) + semester-set interest on unremitted ISR + possible RTU block.
• Both at once: two fine regimes + interest + two solvencies blocked = operations practically paralyzed.

Practical tip: upload the MINTRAB book and file the SAT payroll on the same day each month. Ideally day 5 — before both deadlines. That way IGSS, SAT, MINTRAB and your internal accounting all reflect the same numbers.

Related procedures

• MINTRAB Electronic Salary Book (full guide) — step by step on the book
• MINTRAB Guatemala Hub — all labor procedures
• SAT Guatemala Hub — all tax obligations
• SAT RTU — Unified Tax Registry — must be current for both portals
• IGSS Patron Registration — mandatory prerequisite
• MINTRAB Electronic Labor Solvency — requires current book
• RECIT — Electronic Contract Registry — required before the book
• Labor Severance Calculation — uses book data
• Minimum Wage in Guatemala 2026 — calculation base for both

Official links

• Electronic Salary Book — MINTRAB Portal
• SAT Virtual Agency
• MINTRAB — Main site
• SAT — Main site
• Codigo de Trabajo, Decreto 1441
• Tax Update Law (ISR) Decree 10-2012
• Tax Code Decree 6-91
• Ministerial Agreement 124-2019 (Book Regulation)