The employee file is one of the pillars of labor management in Peru. Every company is required to maintain complete documentation of its workers, and the Superintendencia Nacional de Fiscalizacion Laboral (SUNAFIL) can request it at any time during an inspection. However, the majority of Peruvian companies still manage this documentation on paper —with the risks, costs, and inefficiencies that entails.
The good news is that Peru's legal framework already enables digital management of the employee file. Ley 27269 on Digital Signatures and Certificates, Decreto Legislativo 1310 on administrative simplification, and SUNAFIL provisions allow companies to migrate from paper to digital format with full legal validity. This article explores the regulatory framework, practical requirements, and specific considerations for Peru's most heavily inspected sectors.
What the employee file must contain in Peru
Peruvian labor legislation, primarily the Texto Unico Ordenado of Decreto Legislativo 728 (Ley de Productividad y Competitividad Laboral) and its complementary regulations, establishes that the employer must maintain complete documentation for each worker. A typical employee file in Peru includes:
- Employment contract registered with the Ministerio de Trabajo y Promocion del Empleo (MTPE).
- Personal data form with contact information, family details, and beneficiaries.
- Copy of DNI and identity documents.
- T-Registro certificate (SUNAT).
- Payslips signed by the worker.
- CTS deposit certificates.
- Vacation records: scheduling, actual use, and settlement.
- Performance evaluations and training plans.
- Occupational safety and health (OSH) documentation: occupational medical exams, training certificates, PPE delivery records.
- Disciplinary actions and memorandums.
- Resignation letter or termination notice and settlement of social benefits.
The absence of any of these documents during a SUNAFIL inspection can result in significant fines, which vary based on the severity of the infraction and the size of the company.
Legal framework enabling the digital employee file in Peru
Peru has a regulatory ecosystem that supports the digitization of labor documents. Understanding these regulations is essential for implementing the digital file with legal certainty.
Ley 27269: Digital Signatures and Certificates
Ley 27269, enacted in 2000 and regulated by Decreto Supremo 052-2008-PCM, recognizes the electronic signature as a valid mechanism to express consent in electronic documents. This means an employee can sign their payslip, a memorandum, or a training certificate electronically, and that document has the same validity as its paper version with a handwritten signature.
For the labor context, the relevant point is that the electronic signature allows proof of authorship and document integrity. The platform used must guarantee that the signed document cannot be altered afterward and that a record of who signed, when, and from where is maintained in an unalterable manner.
Decreto Legislativo 1310: administrative simplification
DL 1310, issued in 2016 with subsequent amendments, promotes process simplification and the elimination of bureaucratic barriers between companies and government entities. In the labor context, it reinforces the principle that electronic documents have the same validity as physical ones, provided they meet integrity and authenticity requirements.
This decree is particularly relevant because it establishes that public entities —including SUNAFIL— must accept documentation submitted in electronic format when it complies with legal requirements.
SUNAFIL resolutions on digital documentation
SUNAFIL has been adapting its enforcement processes to accept documentation in digital format. During inspections, inspectors can receive the required information in electronic format, as long as the company can demonstrate the integrity and authenticity of the documents.
In practice, companies that present organized digital documentation with electronic signature traceability during a SUNAFIL inspection tend to receive faster resolutions than those that must search for physical documents across scattered archives.
SUNAFIL requirements and how to prepare for inspections
SUNAFIL inspections can be scheduled or unannounced, and the company's response capability is critical. When an inspector requests documentation, the company has a limited period to present it —and missing documentation is interpreted as non-compliance.
Most frequently requested documents in inspections
Based on the experience of companies operating in Peru, the documents most frequently requested by SUNAFIL are:
- Payslips from the last 5 years with evidence of delivery to the worker.
- Current employment contracts and their amendments.
- Working hours records (attendance control).
- OSH documentation: medical exams, training records, IPERC, OSH policy.
- Semi-annual CTS deposit certificates.
- Vacation records: scheduling and actual use.
- Electronic payroll (PLAME) and T-Registro certificates.
Advantages of the digital file for inspections
With a properly implemented digital file, the response to an inspection changes radically:
- Response time: from hours or days searching for physical documents to minutes generating digital reports.
- Completeness: the system alerts about missing documents before the inspector requests them.
- Traceability: each document has a record of when it was generated, who signed it, and when it was archived.
- Remote access: if the inspection occurs at one location and the documentation is at another, digital access eliminates that problem.
Platforms like Rokisoft allow generating completeness reports by employee or by document type, which facilitates preventive preparation for potential inspections.
Considerations for high-enforcement sectors
Some sectors in Peru face more intensive labor enforcement due to the nature of their operations and associated risks. The digital file becomes especially important in these cases.
Mining
Peru's mining sector is one of the most regulated in labor and safety matters. Mining companies must maintain exhaustive OSH documentation, including periodic medical exams, position-specific training, risk agent exposure records, and specialized PPE delivery certificates.
With operations in remote locations and personnel rotation between camps, paper-based document management is particularly problematic. The digital file allows a worker's documentation to be available at any mining unit, without depending on the physical transfer of files.
Construction
The construction labor regime in Peru has particularities that complicate document management: high personnel turnover, project-based contracts, and specific OSH training requirements. Construction companies must be able to demonstrate to SUNAFIL that each worker has complete documentation from their first day of work on the project.
The digital file facilitates compliance by allowing document uploading and signing from mobile devices, even at construction sites without office infrastructure.
Agribusiness
The agricultural regime, with its salary and benefit particularities, requires specific documentation. The geographic dispersion of operations —farms, processing plants, collection centers— makes centralizing physical documentation costly and inefficient. The digital file solves this fragmentation by centralizing information on a platform accessible from any location.
Digital payslips: the most immediate use case
The payslip is the highest-volume and most frequent labor document. In Peru, the employer is required to deliver the payslip to the worker and obtain evidence of its receipt. This process, when done on paper, consumes significant resources each month.
Legal framework for electronic payslips
Decreto Supremo 001-98-TR and its amendments allow payslip delivery in electronic format, provided that effective receipt by the worker is guaranteed. The employee's electronic signature at the time of receiving the payslip constitutes sufficient evidence of delivery.
Operational benefits
Migrating payslips to digital format generates immediate and measurable benefits:
- Elimination of printing: in a company with 500 workers, more than 6,000 payslips per year stop being printed.
- Elimination of distribution logistics: no more envelopes, manual delivery, or collection of signed copies.
- Immediate availability: the worker accesses their payslip from their phone on the same day of payment.
- Automatic archiving: each signed payslip is automatically archived in the employee's digital file.
- Demonstrable compliance: complete record of delivery and signature for any SUNAFIL request.
Payslips are the ideal entry point for digitizing the employee file. The benefit is visible to the entire organization from the first month and builds confidence for digitizing more complex documents.
Occupational safety and health: critical documentation
Ley 29783 on Occupational Safety and Health and its regulation (DS 005-2012-TR) establish a series of documentary obligations that companies must fulfill. Digital management of this documentation not only facilitates compliance but can prevent accidents by ensuring no worker begins duties without the required documentation.
OSH documents that must be in the file
- Pre-employment occupational medical exam: mandatory before the start of activities.
- Periodic occupational medical exams: frequency varies based on the risk level of the position.
- Training certificates: a minimum of 4 OSH training sessions per year.
- PPE delivery certificate: with details of the equipment delivered and the worker's signature.
- Position-specific induction certificate.
With the digital file, automatic alerts can be configured to notify when a medical exam is about to expire or when a worker has not completed their mandatory training. This preventive control significantly reduces the risk of penalties and, more importantly, protects workers' health.
How to migrate from paper to digital: practical steps
The migration from physical to digital files must be carried out in a planned manner to avoid operational interruptions and ensure document integrity.
Step 1: Audit of current status
Before digitizing, you need to know what you have and what is missing. Conduct a representative sampling of physical files to determine the average level of completeness. This assessment allows you to gauge the regularization effort needed.
Step 2: Define the digital file structure
Establish the categories and subcategories of the digital file aligned with SUNAFIL requirements. A typical structure includes: personal data, hiring, compensation, vacations, OSH, training, disciplinary actions, and termination.
Step 3: Start with new hires
From the implementation date, every new hire is managed 100% in digital format. This ensures that the most recent files are complete and well-structured from the start.
Step 4: Progressive digitization of historical records
Digitize files of active personnel in a phased manner, prioritizing current and highest legal-risk documents (contracts, recent payslips, OSH documentation). Files of terminated personnel are digitized on demand.
Step 5: Integration with existing systems
Connect the digital file platform with your payroll systems to automate the generation and archiving of payslips, CTS certificates, and other recurring documents. Rokisoft offers native integrations with the major payroll systems used in Peru.
SUNAFIL fines: the cost of inaction
SUNAFIL fines are calculated based on Unidades Impositivas Tributarias (UIT) and vary according to the severity of the infraction and the number of affected workers. Some relevant examples:
- Failure to deliver payslips: serious infraction, fine of up to 26.12 UIT for non-MYPE companies.
- Lacking occupational medical exams: serious OSH infraction, fine of up to 52.53 UIT.
- Failure to register the contract with the MTPE: serious infraction, with fines multiplied by the number of affected workers.
- Failure to maintain working hours records: serious infraction, which can result in a presumption of unpaid overtime.
For a medium or large company, a single inspection with multiple findings can result in fines exceeding S/ 200,000. The digital file does not eliminate the obligation to comply, but it ensures that documentation is complete, organized, and accessible when needed.
Conclusion: Peru is ready for the digital employee file
Peru's legal framework —with Ley 27269, DL 1310, and SUNAFIL's progressive openness toward electronic documentation— creates a favorable environment for digitizing the employee file. Companies that take this step in 2026 will gain concrete advantages: immediate response to inspections, reduced operating costs, elimination of lost documents, and preventive control that reduces the risk of penalties.
For the most heavily inspected sectors —mining, construction, agribusiness— the digital file is not a technological luxury: it is an operational survival tool. Geographic dispersion, high turnover, and intensive OSH requirements make paper-based management unsustainable as enforcement intensifies.
The transition does not require a radical overnight change. Starting with payslips, extending to OSH documentation, and progressively moving toward a 100% digital file is a proven path that minimizes resistance to change and maximizes return on investment.