The norm, in detail
The 90-day deadline the provinces have already missed
Law 27.802, art. 154 (Title XVIII)
in forceNATIONAL
Labor
Derives from: The comprehensive labor reform is now law
Provinces signed up to Law 27.348 had 90 days - until 4 June 2026 - to set up their occupational-risk forensic medical bodies. What happens if they do not comply.
What changed and who it applies to
What changed
Article 154 inserts an article 4 bis into Supplementary Occupational Risks Law No. 27.348 and imposes concrete, dated obligations on the provinces that signed up to that regime. It starts with the general rule: those jurisdictions «are bound to full compliance with the conditions established therein, including the strict application of the Table for the Assessment of Work Incapacity approved by Decree 659/96». It then sets out five paragraphs. a) Where there are no judicial medical experts meeting the conditions of article 2 of that law, «each jurisdiction shall establish, staff and guarantee the proper operation of Forensic Medical Bodies or equivalent bodies or entities». b) Those bodies must have «the operational capacity and specialisation required» to handle judicial disputes under the occupational risks system, «ensuring objectivity and independence in their findings». c) The deadline: «ninety (90) days, counted from the entry into force of the law inserting this article for jurisdictions already signed up, or from the date of their respective adherence law for those that sign up later». d) Within the same period, the jurisdictions must implement «the digital environments the Occupational Risks Superintendency makes available to them», which assist doctors and experts in calculating incapacity. e) Agreements are to be signed setting out the protocols and technical requirements. And the final paragraph is the one with teeth: non-compliance «once the periods provided for have elapsed shall entitle the Occupational Risks Superintendency to suspend technical assistance and/or specific funding, or to restrict or terminate any other form of support it directs to that jurisdiction in occupational risk matters», and the measure «may be maintained until the jurisdiction demonstrates full compliance». verif · Mar 6, 2026 ↗
In force
The article has been in force since 6 March 2026, under article 217 of the law. The 90-day deadline running against provinces already signed up expired on 4 June 2026. For those signing up later, the 90 days run from their own adherence law. verif · Mar 6, 2026 ↗
Are you in or out?
The worker injured at work who disputes their incapacity rating. The provincial forensic medical body is what issues findings once a case reaches the courts; if the province has not set one up, the case drags on or is decided by experts with no specialisation in occupational risks. The employer paying workers' compensation premiums. The predictability of accident litigation depends on the incapacity table being applied the same way in every jurisdiction, and that is exactly what the article requires be done «strictly». And the provincial government, which is the real addressee: setting up a specialised forensic medical body means money and staff, and non-compliance has a concrete consequence — the Superintendency can cut off its technical assistance and its specific occupational-risk funding. verif · Mar 6, 2026 ↗
The norm
Law 27.802 on Labour Modernisation, Title XVIII («Amendments to Supplementary Occupational Risks Law No. 27.348 — Medical commissions»), article 154, the sole article of the title, inserting article 4 bis into Law 27.348. Passed on 27 February 2026, published in the Official Gazette on 6 March 2026. verif · Mar 6, 2026 ↗
Our reading
thesis This article is the one that attaches a date and a penalty to a part of the system that until now depended on each province's goodwill, which is why it is worth looking at even though it has a single article. The logic is the same one that appears in other titles of the law: not repealing the provincial regime, but conditioning national money on the province doing its part. ⇒ For anyone assessing where to site an operation with many exposed workers — a mine, a construction job, a well site — this article makes a concrete question possible: *does this province have a forensic medical body specialised in occupational risks, or will my accident litigation be decided blind?* It is a piece of judicial-infrastructure information that previously had nowhere to be looked up and now has a dated obligation behind it. ⚠️ And here is what we cannot close, and we say so: we do not know which provinces signed up to Law 27.348, nor whether any met the deadline, nor whether the Superintendency has penalised anyone. The deadline expired on 4 June 2026 and we found no later act saying what happened. That is the missing half, and it is the half that turns this into a decision: without it we have the rule but not the map. thesis
Where it lands, province by province
Impact by province, pending
Once we measure how this rule lands in each province, it shows up here.
The other rules on this subject21
The comprehensive labor reform is now lawLey 27.802 (Official Gazette, Mar 6, 2026, promulgated by Decreto 137/2026)in force
Hire formally for 4 years with employer contributions of 2%+3%Decreto 315/2026 (Official Gazette, May 4, 2026), Ley 27.802 Title XXin force
The labor reform lands: transparent pay slip, ARCA and the end of ultra-activityDecreto 407/2026 (Official Gazette, Jun 1, 2026)in force
Ley Bases: labor modernization and registered employmentLey 27.742, Titles IV-V (Decreto 847/2024); Title II Ch. IV (Decreto 695/2024)in force
The dismissal number, section by sectionLaw 27.802, ss. 10, 51 and 54 to 57 (Title I), rewriting ss. 20, 245, 276, 277 and 278 of the Employment Contract Actin force
Ignacio Aredez· Chief analyst
Credentials and track record →- 10+ years in data science for clients across Europe and the Americas
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Fact sheet built on the published rule, with the gaps declared. Back to the reforms
How to read the seals → verif primary source · prob primary source pending · unconf not sufficiently backed · estim our own calculation · thesis our reading