

Tom Klukowski
Fyware Partner · Valcre Marketing
How can we help?
What's in the file
An Excel file with four sheets, ready for your 2027 DNC, the training needs assessment Mexican law requires.
Needs matrix
24 columns: position, critical tasks, standard and section, gap, identification method, refresher due date, priority, action and owner. With dropdown lists and two example rows.
NOM matrix
20 STPS standards that require training, with their section and frequency, checked against the Official Gazette (Diario Oficial de la Federación, DOF) as of October 20, 2026.
Worker survey
Six questions so each person can say what they are missing, as NOM-035 requires.
Instructions with legal basis
The five steps and what the law requires, with the article and the official source for each point.
What the law requires, and what changed in 2025 and 2026
- The DNC is required by name. NOM-035-STPS-2018, section 8.2, item i), subitem 3), requires employers “to carry out a training needs assessment at least every two years and integrate its results into the training program.” It applies to every workplace, of any size.
- The plan covers every position and lasts up to two years. The Federal Labor Law (Ley Federal del Trabajo, LFT) requires plans and programs to cover all positions and levels, span periods of no more than two years and specify their stages (art. 153-H).
- It is agreed with the workers. It is drawn up by mutual agreement with the union or the majority of the workers (art. 153-A). In companies with more than 50 workers, it is overseen by the Joint Training, Instruction and Productivity Committee (Comisión Mixta de Capacitación, Adiestramiento y Productividad), under art. 153-E. An agreement published in the DOF on May 27, 2026 eliminated the procedure for reporting the committee's creation; the committee is still mandatory.
- The plan is not filed with the STPS. The company keeps it available to the Ministry of Labor and Social Welfare (Secretaría del Trabajo y Previsión Social, STPS) and shows it if the authority asks for it (art. 153-F Bis). The DC-2 form is filled out and kept in the company's records.
- The DC-4 form was withdrawn by the agreement of April 4, 2025. DC-3 certificates are reported online through SIRCE's “Notice of compliance with competency or labor skills certificates” (Aviso de cumplimiento de constancias de competencia o habilidades laborales), within 60 business days after the end of each year of the plan.
- The fine is counted per worker. Failing to train carries a fine of 250 to 5,000 UMA (art. 994 fr. IV) for each affected worker (art. 992). With the 2026 UMA (Unidad de Medida y Actualización) at MXN 117.31, that is MXN 29,327.50 to MXN 586,550.00 per person.
Sources: Federal Labor Law (last amended DOF 14-05-2026), NOM-035-STPS-2018 and STPS agreements published in the DOF on 14-06-2013, 04-04-2025 and 27-05-2026. Reviewed on October 20, 2026.
How to fill it in, in five steps
List the positions
Every position and level, by area and shift, with its headcount.
Cross-check the standards
In the NOM matrix sheet, mark which standard applies to each position and when the last course took place. An overdue NOM-006 (forklifts) or NOM-017 (PPE) refresher is priority A.
Ask your people
Hand out the survey or use it in interviews, as NOM-035 requires. Then compare the answers with what your plant already records: incidents, rework, stoppages and complaints.
Filter and prioritize
A course will not fix a missing guard. Mark which gaps training solves and give them a priority: A required or overdue, B risk, C improvement.
Validate it and move it into the program
Review the matrix with the Joint Training, Instruction and Productivity Committee (Comisión Mixta de Capacitación, Adiestramiento y Productividad) or with the workers, and carry each action into the 2027 program with dates, hours, instructor and owner.
Download the template (Excel)
It is a working guide: not an official form or legal advice, and each company is responsible for how it uses it.
When the gap is in a task you can't practice on the line
Maneuvering a forklift among pedestrians or discharging an extinguisher onto a fire is not practiced on equipment in production. For those gaps, Fyware develops virtual reality simulators: each person practices in the headset and their progress is recorded by module.
See Fyware Safe
Prefer to have a consultant run it with you?
SIISA Consultores, serving all of Mexico, provides NOM-030 compliance consulting and delivers courses with DC-3 certificates signed by its STPS-registered instructor. It is a Fyware partner.
Go to SIISA Consultores
Frequently asked questions about the DNC
Is the DNC mandatory?
Yes. NOM-035-STPS-2018, in section 8.2 i) 3), requires carrying out a training needs assessment at least every two years and integrating its results into the training program, in every workplace. The term DNC does not appear in the Federal Labor Law (Ley Federal del Trabajo, LFT), which requires the plan to cover all positions and levels (art. 153-H).
How often do you need to do the DNC?
At least every two years, under NOM-035. It makes sense to redo it sooner if new equipment arrives or a standard changes. The training plan cannot exceed two years either (LFT art. 153-H).
Is the training program filed with the STPS?
No. Since the 2012 reform, the plan and programs are kept available to the Ministry of Labor and Social Welfare (Secretaría del Trabajo y Previsión Social, STPS) and shown if the authority asks for them (LFT art. 153-F Bis). What is filed, online in SIRCE, is the notice of the DC-3 certificates issued in each year of the plan.
More questions
What happened to the DC-4 form?
It was withdrawn by the STPS agreement published in the DOF on April 4, 2025. The list of certificates is reported through the “Notice of compliance with competency or labor skills certificates” (Aviso de cumplimiento de constancias de competencia o habilidades laborales), filed online in SIRCE within 60 business days after the end of each year of the plan.
Do I need a Joint Training Committee (Comisión Mixta de Capacitación)?
Yes, if the company has more than 50 workers (LFT art. 153-E). With an agreement published in the DOF on May 27, 2026, the STPS eliminated the procedure for reporting its creation, but the obligation to have one remains. Keep its founding record (acta de integración) and its minutes.
How much is the fine for not training?
From 250 to 5,000 UMA for each affected worker (LFT arts. 992 and 994 fr. IV). With the 2026 UMA (Unidad de Medida y Actualización) at MXN 117.31, that is MXN 29,327.50 to MXN 586,550.00 per worker, and a repeat violation doubles the fine.
Let's talk about your plant
Tell us what you want to solve in your plant. Fyware designs extended reality around the equipment and constraints of your operation, and builds it to grow from a pilot to the whole site.
Tom Klukowski, Fyware Partner · Valcre Marketing We reply in under 24 business hours, with scope, timeline and investment range.In the meeting you see the simulator running and what it would take to bring it to your plant, with scenarios adapted to your layout. And if you need to sell it internally, this page is your presentation: share it with your team.