Computing wages and labor awards does not call for an accounting expert
Accounting expert evidence in labor matters. As a general rule it is inadmissible when its purpose is to quantify the integrated wage or the awards in a liquidation incident arising from benefits under a collective bargaining agreement.
Official heading (Spanish): PRUEBA PERICIAL CONTABLE EN MATERIA LABORAL. POR REGLA GENERAL ES INADMISIBLE CUANDO SU OBJETO ES CUANTIFICAR EL SALARIO INTEGRADO O LAS CONDENAS EN UN INCIDENTE DE LIQUIDACIÓN DERIVADAS DEL PAGO DE PRESTACIONES PREVISTAS EN UN CONTRATO COLECTIVO DE TRABAJO.
The ruling
Resolving conflicting rulings, the Regional Plenary Court addressed whether accounting expert evidence may be admitted to quantify the integrated wage or awards in a liquidation incident under a collective bargaining agreement. It held that, as a general rule, it is inadmissible: these are calculations for the labor court to make on the evidence filed, under articles 776 and 821 of the Federal Labor Law.
Our take
The ruling speeds up liquidation incidents and removes a cost many employers took for granted. But it shifts the risk: if the court does the math itself, the quality of the result depends on the documents the parties filed. Employers with complex collective agreements should put the pay scales, formulas and payroll receipts in the record so each item can be rebuilt. The exception remains: if the calculation requires technical knowledge beyond the court's expertise, expert evidence may still be justified. Argue that point precisely where it applies.
What to do
- File pay scales, collective agreement formulas and payroll receipts before the liquidation stage.
- Submit your own calculations as argument, not as expert evidence, to guide the court.
- Offer expert evidence only when technical knowledge beyond the court's expertise is justified.
Details
- Court
- Regional Plenary Courts
- Type
- Binding precedent (jurisprudencia)
- Identifier
- PR.P.T.CS. J/18 L (12a.)
- Digital registry
- 2032430
- Published
- July 10, 2026
- Area
- Labor and social security
- View official source ↗
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Prepared by Artegia for information only; not legal advice. Headings in English are unofficial translations. The official text is the one published in the Semanario Judicial de la Federación or the TFJA journal.