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SUNAFIL Audit: How to Prepare Your Company in Peru

SUNAFIL inspection is the process through which the National Superintendency of Labor Inspection (SUNAFIL) monitors compliance with social and labor regulations, as well as occupational safety and health regulations, at companies throughout Peru. This agency has the authority to inspect any employer, both in Lima and in the regions, to verify compliance with labor rights, social benefits, proper payroll management, and workplace safety conditions.

What is a SUNAFIL audit, and why is it crucial for your business?

Wiseplan provides this service in Peru

We provide labor law representation to companies in Lima and other regions. If you'd like to explore this option for your company, please contact us and we'll send you a proposal.

Preparing for a SUNAFIL audit is essential to avoid penalties, fines, and legal proceedings that could seriously harm your company’s reputation and operations. In addition, proper labor management contributes to a healthy work environment and ensures compliance with legal obligations.

Audits may be scheduled or unannounced, and cover the verification of payments such as the minimum living wage (RMV), family allowances, CTS, bonuses, and vacation pay, as well as the correct reporting of this information in the T-Registro and PLAME sections of the electronic payroll submitted to SUNAT. SUNAFIL also reviews compliance with Law 29783 on occupational safety and health, the issuance of pay stubs, and the timely payment of EsSalud, AFP, or ONP contributions, among other aspects.

Why is SUNAFIL a key player in business management?

  • It protects workers' rights and ensures that they receive their benefits as required by law.
  • It promotes business formality and combats labor informality in all sectors.
  • It promotes occupational hazard prevention and workplace safety.
  • It encourages continuous improvement of internal human resources and regulatory compliance processes.

Ignoring the importance of SUNAFIL audits can result in consequences such as fines, temporary closure of business premises, or even a ban on contracting with the government. Therefore, it is essential that companies seek specialized advice in human resources consulting and periodically review their payroll management processes to ensure full compliance with current regulations.

Keep in mind that SUNAFIL pays special attention to sectors with high employee turnover, companies that outsource services, and those with a history of labor complaints. Preparing your company for an audit involves training, organizing documents, and fostering a culture of compliance that must be promoted by senior management.

Relevant Peruvian Regulations Governing SUNAFIL Audits

SUNAFIL audits are based on a specific regulatory framework that every company must understand and comply with. Among the key regulations are:

  • TUO of Legislative Decree 728 (D.S. 003-97-TR): regulates the labor regime for the private sector.
  • Law 29783: Occupational Safety and Health Act.
  • Law 27735: Regulates statutory bonuses.
  • Law 29733: Personal Data Protection Act.
  • Law 27626 and Law 29245: on labor intermediation and outsourcing.
  • SUNAFIL regulations and directives: These establish audit procedures and criteria.

In addition, SUNAFIL coordinates with entities such as the Ministry of Labor and Employment Promotion (MTPE), SUNAT, and EsSalud to verify full compliance with labor obligations.

Compliance with these regulations is not only essential to avoid penalties, but also ensures legal certainty and protects the company’s reputation. For example, the Consolidated Text of Legislative Decree 728 requires that contracts be properly drafted and that employees receive all statutory benefits, such as severance pay (CTS), bonuses, and vacation time, in accordance with the law. Similarly, Law 29783 requires the company to implement an occupational safety and health management system, which entails maintaining properly documented records, training programs, and preventive measures.

Key Obligations to Monitor

  • Registration and payment of electronic payroll (T-Registro and PLAME) correctly filed with SUNAT.
  • Distribution of pay stubs and receipts for social benefits deposits.
  • Compliance with working hours, rest periods, and overtime pay in accordance with Legislative Decree 728.
  • Implementation of verifiable occupational safety and health measures.
  • Protection and proper handling of employees' personal data.

SUNAFIL inspectors may request documentation demonstrating compliance with these regulations and conduct on-site verification of internal policies and procedures. It is important for companies to keep all labor-related information up to date and to periodically review their internal processes to identify and correct any potential noncompliance.

Finally, companies that use outsourcing services must ensure that their providers also comply with current regulations, as they may be held jointly liable in the event of violations. Staying informed and training human resources teams is key to taking preventive measures in preparation for a SUNAFIL audit.

SUNAFIL Audit Methods and Types

SUNAFIL audits can take various forms, depending on the purpose and scope of the inspection. The main types are:

  • Routine audits: Scheduled on a regular basis, in accordance with SUNAFIL's annual plan.
  • Special audit: Initiated based on complaints from employees, unions, or third parties.
  • Enforcement through sector-specific campaigns: Focused on sectors with a high incidence of noncompliance (construction, agribusiness, services, etc.).
  • Virtual Auditing: Document review via digital platforms, particularly for verifying electronic payroll records, pay stubs, and tax returns in the PLAME system.

Audits can range from verifying payroll records and the payment of employee benefits to reviewing occupational safety and health conditions, as well as ensuring the proper application of regulations governing outsourcing and labor brokerage.

In addition, SUNAFIL may conduct targeted inspections on specific issues, depending on the context and the risks identified in each sector or region. For example, in Lima, there has been an increase in virtual audits to verify compliance with the Electronic Payroll System and proper registration in SUNAT’s T-Registro, while in agricultural regions, the focus tends to be on the formalization of employment and the payment of the minimum living wage and family allowance.

What documents does SUNAFIL require for each category?

  • For routine and special audits: payroll records, pay stubs, employment contracts, attendance records, CTS deposit statements, proof of bonus payments, evidence of EsSalud payments, and contributions to the AFP or ONP.
  • For virtual audits: digital files from the Electronic Payroll System (PLAME) and T-Registro, as well as documents supporting the employee benefits granted.

It is important for companies to keep these documents up to date and ready to be submitted to SUNAFIL. Incomplete documentation, failure to include employees on the payroll, or incorrect reporting in the PLAME may result in penalties and more thorough audits.

Finally, SUNAFIL may also conduct unannounced inspections—that is, without prior notice—especially when there are indications of serious violations. For this reason, ongoing preparation and specialized human resources consulting are key to handling any type of audit.

Stages of the SUNAFIL Audit Process

The SUNAFIL audit process follows a structured sequence, which is important to understand in order to take timely and appropriate action:

  1. Notice: SUNAFIL formally notifies the party of the start of the inspection, stating the reason and scope.
  2. Inspection visit: Inspectors visit the workplace or request information online, reviewing documents and interviewing workers.
  3. Request for Information: We request that you submit employment documents and records within a specified time frame.
  4. Notice of Violation: If noncompliance is detected, a notice is issued detailing the violations and setting a deadline for correcting them (if applicable).
  5. Rebuttals: The company may submit rebuttals or evidence that refutes the observations.
  6. Decision and Penalty: SUNAFIL issues a decision imposing penalties or closing the case if the issues raised have been resolved.

During an audit, SUNAFIL may request key documents such as the electronic payroll, pay stubs, employment contracts, attendance records, and proof of payment for social benefits such as CTS, bonuses, and contributions to EsSalud, AFP, or ONP. It is advisable to keep all these documents up to date and properly filed, as the absence of any of them may be considered a violation.

Common Errors in SUNAFIL Audits

  • Failure to respond to requests for information within the specified time frame.
  • Submitting incomplete or outdated documents, especially regarding the T-Registro and PLAME.
  • Failure to provide proof of timely payment of employee benefits or lack of evidence of bank deposits made.
  • Lack of clear internal policies on occupational safety and health, in accordance with Law 29783.

An audit may be triggered by complaints from employees, industry-specific inspections, or random checks. Therefore, prevention and ongoing training of the human resources team are essential to avoid penalties.

Having expert advice on Peruvian labor regulations and conducting periodic internal audits makes it possible to identify potential risks before a SUNAFIL inspection. If the company receives a notice, it is advisable to immediately coordinate with specialists in human resources consulting or legal defense to prepare the necessary documentation and response strategies.

At Wiseplan, we work with companies to review their internal processes and prepare for audits, helping them minimize risks and comply with current labor regulations.

Key documents that SUNAFIL may request during an audit

During a SUNAFIL audit, inspectors may request a number of documents proving compliance with labor and safety obligations. Below is a handy list of the main documents required:

  • Electronic Form (T-Registro and PLAME) and proof of monthly filing with SUNAT.
  • Pay stubs signed by the employees.
  • Employment Contracts and Addenda.
  • Internal Work Regulations (if applicable based on the number of employees).
  • Internal Regulations on Occupational Safety and Health.
  • Deposit receipts for CTS and bonuses.
  • Proof of payment from EsSalud, an AFP, or the ONP.
  • Attendance tracking and hours worked tracking.
  • Personal Protective Equipment (PPE) Issuance Records.
  • Certificates of training in occupational safety and health.
  • Licenses, permits, and registrations required by Law 29783.
  • Documentation regarding family allowances, vacation time, profit-sharing, and other employee benefits.
  • Proof of payment for the minimum living wage (RMV) and family allowance (S/ 1,230 and S/ 123 as of October 2026, according to El Peruano).

The absence of any of these documents may be considered a serious or very serious violation, resulting in significant fines.

It is important to note that the scope of an audit may vary depending on the sector, economic activity, and size of the company. For example, companies with more than 20 employees are required to have Internal Labor Regulations, while all companies, without exception, must comply with Law 29783 on occupational safety and health. Failure to file the Electronic Payroll Form or to issue pay stubs can be easily detected by SUNAFIL through cross-checking information with SUNAT.

Recommendations for Proper Document Management

  • Periodically check to ensure that employment contracts and their amendments are up to date and signed.
  • Keep records of your filings with SUNAT and payment receipts in both paper and digital formats.
  • Keep the attendance record up to date and backed up, whether it is manual or electronic.
  • Be sure to distribute PPE and document its distribution, as well as occupational safety training sessions.
  • Verify that all employee benefits (CTS, bonuses, vacation pay, family allowances) are properly documented and paid by the statutory deadlines.

Preparing these documents in advance and keeping them readily available facilitates a quick response in the event of an inspection, minimizes risks, and demonstrates a culture of compliance. Don’t forget that SUNAFIL may also request additional information regarding labor intermediation (outsourcing) or subcontracting, in accordance with Law 27626 and Law 29245, if your company uses these services.

If you have questions about how to organize or update your employment records, you can seek specialized human resources consulting or legal counsel for businesses. For an effective defense against findings or penalties, check out our section on labor law defense.

Key Labor Obligations Monitored by SUNAFIL

SUNAFIL's audits place special emphasis on compliance with the following labor obligations:

Obligation Verified Aspects Applicable Standard
Entry in the worksheet Registrations, cancellations, and updates in T-Registro and PLAME TUO Legislative Decree 728, Electronic Tax Return
Payment of the Minimum Wage and Family Allowance Minimum Wage (RMV) of S/ 1,230 and Family Allowance of S/ 123 starting in October 2026 Supreme Decree No. 015-2026-TR, El Peruano
CTS Deposit Deposits in May and November, correct calculation MTPE Guidelines, Law 29352
Payment of Bonuses July and December, special bonus Law 27735, SUNAFIL
Payments from EsSalud and AFP/ONP EsSalud: 9% paid by the employer; ONP: 13% paid by the employee Gob.pe, SUNAT
Vacation Granting and Payment of 30 Days Per Year TUO Legislative Decree 728
Health and Safety Conditions Implementation of Law 29783 and Its Regulations Law 29783

Failure to comply with any of these obligations may result in substantial fines, depending on the number of employees affected and the severity of the violation.

During an audit, SUNAFIL verifies not only compliance with documentation requirements but also the effective enforcement of labor rights. For example, it checks to ensure that all workers are properly registered on the payroll from the start of their employment, that CTS deposits are made within the legal deadlines, and that pay stubs correctly reflect the amounts for the minimum wage (RMV), family allowance, and deductions for the AFP or ONP.

In addition, SUNAFIL verifies that bonuses are paid on time in July and December—including the special bonus—and that vacation time is granted and paid in accordance with established regulations. Regarding occupational safety and health, the inspection may request evidence of compliance with Law 29783, such as records of training, the provision of personal protective equipment, and the existence of an occupational safety and health committee.

Common Errors Detected by SUNAFIL

  • Do not enroll all employees in the payroll system on their first day of work.
  • Omission or incorrect calculation of family allowances or bonuses.
  • Failing to deposit the CTS by the statutory deadlines or failing to include all eligible items.
  • Failure to maintain EsSalud enrollment or making incomplete contributions to an AFP or ONP.
  • Lack of effective implementation of occupational safety and health measures.

To avoid penalties and protect the company’s reputation, it is essential to periodically review these matters and seek specialized advice from human resources consultants or payroll outsourcing providers. If you have questions or need to bring any obligations into compliance, you can contact Wiseplan or visit the official SUNAFIL website.

Common Mistakes Companies Make During a SUNAFIL Audit

In Wiseplan's experience, many employers make mistakes that can be avoided with proper preparation. The most common ones are:

  • Failing to register all employees on the payroll or doing so after the deadline.
  • Failing to submit signed pay stubs or failing to keep them properly.
  • Errors in calculating CTS, bonuses, or vacation pay.
  • Failure to make EsSalud, AFP, or ONP contributions by the statutory deadlines.
  • Failure to implement or update the Internal Occupational Safety and Health Regulations.
  • Failure to document training or the distribution of PPE.
  • Failure to respond in a timely manner to SUNAFIL's requests.
  • Lack of knowledge of current regulations or recent changes (for example, the new minimum wage amount).

Avoiding these mistakes requires proactive management and support from experts in human resources consulting and payroll outsourcing.

Why do these errors occur?

In practice, many of these errors arise from a lack of knowledge of Peruvian regulations, a failure to stay up to date with new decrees, or the absence of clear procedures in the human resources department. For example, the failure to register an employee in the electronic payroll system may be due to a lack of oversight over personnel changes or to not having a designated person responsible for using the T-Registro and PLAME systems. Similarly, errors in calculating the CTS or bonuses may result from failing to consider certain compensation components—such as the 9% extraordinary bonus on bonuses—or from failing to account for the new amount of the Minimum Living Wage (RMV) established by Supreme Decree No. 015-2026-TR.

Consequences of These Errors in the Event of an Audit

When SUNAFIL detects any of these violations, it may impose significant fines and order the immediate rectification of the employment situation. In addition, the company’s reputation may be damaged, and in serious cases, the authority may refer the matter to other agencies, such as SUNAT or the Ministry of Labor and Employment Promotion (MTPE), for further investigation. Maintaining a proactive approach and seeking ongoing advice helps avoid penalties and ensures compliance with labor rights.

How can you best prepare?

  • Conduct periodic internal audits to verify compliance with labor obligations.
  • Train human resources staff on current labor regulations and updates.
  • Implement document control systems for the safekeeping of pay stubs, contracts, and training records.
  • Work with expert partners in HR consulting or payroll outsourcing who can help identify and address potential risks.

Prevention and regulatory compliance are the best strategies for successfully passing any SUNAFIL audit. If you have questions about how to improve your labor management practices, visit our Contact Us page to receive personalized guidance.

Practical Recommendations for Preparing Your Company for a SUNAFIL Audit

Preparing your company for a SUNAFIL audit involves not only having your documents in order but also fostering a culture of labor compliance. Here are some key recommendations:

  1. Periodic internal audit: Conduct internal reviews of your labor and safety processes to identify potential gaps. A well-structured audit allows you to detect noncompliance before it is detected by regulatory authorities, such as incomplete contracts or missing records in T-Registro and PLAME.
  2. Regulatory Updates: Stay up to date on legal changes, such as increases to the minimum wage (RMV) or new health and safety requirements. For example, the minimum wage (RMV) increased to S/ 1,230 as of October 2026 (Supreme Decree No. 015-2026-TR, El Peruano), which affects benefits such as family allowances and EsSalud.
  3. Training for Your Team: Train your human resources and payroll staff on current regulations and document management. It is essential that they understand the procedures for dealing with SUNAFIL and how to respond to inquiries from inspectors.
  4. Document Digitization: Use document management systems to store pay stubs, contracts, and attendance records. Digitization facilitates immediate access to information during an inspection and reduces the risk of losing physical documents.
  5. Inspection Drills: Conduct simulated inspection exercises to identify critical issues and train your staff. These drills may include reviewing employee records, verifying benefit payments, and checking safety equipment.
  6. Professional Consulting: Hire specialized labor consulting and legal defense services for matters before SUNAFIL. Having experts on your side helps you interpret regulations and prepare solid responses to observations or requests.

These steps will help you reduce risks and demonstrate your commitment to legal compliance. In addition, it is advisable to maintain clear communication with employees regarding their rights and responsibilities, and to hold regular meetings to address any questions they may have. Remember that SUNAFIL values not only compliance with documentation requirements but also best practices and the prevention of labor disputes.

If you need assistance with payroll management, regulatory compliance, or guidance during audits, learn more about our payroll outsourcing and human resources consulting services.

What should you do if you receive a SUNAFIL audit notice?

If your company receives a notice of a SUNAFIL audit, it is essential to act quickly and in an organized manner. The key here is preparation: proper management from the very beginning can make the difference between a successful audit and the imposition of costly penalties.

  • Read the notice carefully and verify the scope of the inspection.
  • Appoint an internal representative to coordinate support for the inspectors.
  • Gather all the requested documentation (pay stubs, pay slips, contracts, etc.).
  • Prepare a suitable space for the visit, ensuring access to information.
  • It trains employees to answer questions clearly and truthfully.
  • If you have any questions, seek immediate advice from labor consulting experts.
  • Record all actions and communications with the inspectors.

In addition, verify that the information submitted is up to date and matches what was reported on the electronic tax return (T-Registro and PLAME). It is advisable to have the most frequently requested documents on hand: employment contracts, pay stubs, attendance records, proof of payment for CTS, bonuses, and contributions to EsSalud, ONP, or AFP, as well as certificates of occupational safety and health training.

Common Mistakes to Avoid

  • Submitting documents that are incomplete or contain information inconsistent with what was reported to SUNAT.
  • Failure to inform workers in a timely manner about the SUNAFIL visit, which may lead to conflicting responses.
  • Failure to maintain an organized and up-to-date personnel file for each employee.
  • Failing to properly document communications and requests from inspectors.

Remember that SUNAFIL may request both physical and digital documents, and that a lack of cooperation or obstruction of the inspection process may lead to more severe consequences. If the audit results in findings or requirements, respond within the established deadlines and, if necessary, seek assistance from labor defense specialists to address any potential disciplinary proceedings.

A proactive and organized response can help avoid penalties and demonstrate the company’s good faith to SUNAFIL. To ensure comprehensive preparation, consider seeking advice from experts in human resources consulting or payroll outsourcing to keep your documentation up to date and in compliance with Peruvian regulations.

Fines and Penalties for Noncompliance Detected During the SUNAFIL Audit

The fines imposed by SUNAFIL vary depending on the severity of the violation, the number of affected workers, and the type of business. Among the most common violations are:

  • Failure to register employees in the electronic payroll system.
  • Failure to pay the minimum wage (RMV), family allowance, severance pay (CTS), bonuses, or vacation pay.
  • Failure to comply with occupational safety and health obligations.
  • Failing to provide pay stubs or failing to keep them properly.

Penalties can range from warnings to substantial fines, in addition to the requirement to remedy the violations. In serious cases, this may lead to labor court proceedings or even the suspension of operations.

How does SUNAFIL calculate fines?

The amount of the fine depends on several factors, including:

  • The number of workers affected by the violation.
  • Whether the company is a micro, small, medium, or large business.
  • Recidivism or habitual engagement in unlawful conduct.
  • The severity of the violation (minor, serious, or very serious, according to current labor regulations).

For example, failing to register an employee in the electronic payroll system, or failing to pay the minimum living wage (RMV) of S/ 1,230 as of October 2026, is considered a serious violation and may result in heavy fines, especially if it affects multiple employees (SUNAFIL).

Additional Consequences of the Sanctions

In addition to the financial penalty, SUNAFIL may require immediate rectification of the identified issue, such as retroactive registration of employees in the T-Registro or payment of omitted labor-related benefits (CTS, bonuses, family allowances, etc.). A repeat offense may increase the amount of the penalty and damage the company’s reputation with customers and suppliers.

In cases of repeated noncompliance, SUNAFIL may recommend to the Ministry of Labor that operations be partially or fully suspended, or may initiate legal proceedings for labor-related damages.

Recommendations for Avoiding Penalties

  • Periodically review compliance with labor obligations and occupational safety and health requirements.
  • Train payroll and human resources staff on current regulations.
  • Have access to expert advice to respond appropriately during an audit.

For details on the penalties and how to defend yourself, check out our section on legal defense before SUNAFIL.

How can Wiseplan help you with a SUNAFIL audit?

At Wiseplan, we assist companies in Lima and other regions throughout the entire process of preparing for, responding to, and defending against a SUNAFIL audit. Our services include:

  • Preventive audit of labor compliance and occupational safety and health.
  • Review and correction of electronic payroll, pay stubs, and employee benefits.
  • Training for human resources teams and management.
  • Consulting and representation in defense proceedings and administrative proceedings before SUNAFIL.
  • Implementation of payroll and document management outsourcing systems.
  • Legal defense in cases of penalties or proceedings resulting from an audit.

Having the support of experts will allow you to face any audit with confidence and minimize legal and financial risks.

SUNAFIL’s audits can range from verifying proper registration in the electronic payroll system (T-Registro and PLAME), the issuance of pay stubs, and compliance with employee benefits (such as CTS, bonuses, vacation pay, and family allowances), to the implementation of occupational health and safety policies required by Law 29783. Therefore, it is essential that your company have robust internal processes, supporting documentation, and a team prepared to address the authority’s requirements.

Benefits of Consulting Services Specializing in SUNAFIL Audits

  • Identification and timely correction of potential noncompliance issues prior to an inspection.
  • Reduced likelihood of financial and administrative penalties.
  • A better image and reputation among employees and authorities.
  • Regular updates on Peruvian labor regulations and SUNAFIL guidelines.

At Wiseplan, we not only guide you through the process of bringing your documents and procedures into compliance, but we also support you in developing preventive strategies, training your staff, and providing legal defense in the event of penalties. Our approach is comprehensive and personalized, tailored to the specific needs of each company, regardless of its size or industry.

If you're looking for peace of mind and compliance with SUNAFIL, learn more about our human resources consulting and labor law defense services, or contact our team directly through our contact page.

Frequently asked questions

What documents should I have ready for a SUNAFIL audit?

You must have electronic payroll forms (T-Registro and PLAME), pay stubs, contracts, attendance records, proof of payment for CTS, bonuses, EsSalud, AFP, or ONP, and documentation regarding occupational safety and health. Review the complete list in the “Key Documents” section.

What happens if SUNAFIL detects unregistered workers on the payroll?

The company may face a significant fine and be required to register its employees, pay any outstanding social benefits, and bring its contributions to EsSalud, AFP, or ONP into compliance. This is one of the most serious violations under Peruvian law.

How can I avoid fines during a SUNAFIL audit?

Conduct internal audits, keep your employment documentation up to date, train your team, and respond promptly to SUNAFIL’s requests. Consider seeking support from experts in labor consulting and payroll outsourcing to ensure compliance.

Can SUNAFIL inspect companies throughout Peru?

Yes, SUNAFIL has nationwide jurisdiction and can inspect companies both in Lima and in any region of Peru, regardless of their size or industry.

What are the benefits of having specialized advice when dealing with SUNAFIL?

Specialized consulting services help identify and correct noncompliance issues before an inspection, prepare the necessary documentation, and defend the company in the event of penalties, thereby minimizing legal and financial risks.

Do you need assistance with a SUNAFIL audit?

Wiseplan supports companies in Lima and other regions of Peru with their human resources management.

Contact Us →

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