Ministerial Agreement No. MDT-2025-054, issued on May 15, 2025, and published in Official Register No. 52 on June 4, 2025, amends the Regulation for the Qualification and Certification of Direct Substitutes for Persons with Disabilities, originally established by Ministerial Agreement MDT-2018-0180.
This update aligns the requirements with the technical criteria set forth in Ministerial Agreement 00086-2024, issued by the Ministry of Public Health (MSP).
Comparative Overview of Regulations on the Certification of Substitutes for Persons with Disabilities:
| Topic | Before (MDT-2018-0180) | After (MDT-2025-054) |
| Who determines if a disability is severe? | CONADIS (National Council for the Equality of Disabilities) | Ministry of Public Health |
| What was considered a severe disability? | Any disability equal to or greater than 75% | Varies according to the type of disability |
| Intellectual, psychosocial, or multiple disabilities | Considered severe if ≥75% | Considered severe if the severity level is serious, very serious, or complete, starting at 50% |
| Physical, visual, auditory, or speech disabilities | Also considered severe if ≥75% | Considered severe only if the severity level is very serious or complete, starting at 75% |
| What document did the substitute have to present? | CONADIS card + additional certificate | Only the national ID showing the rating granted by the Ministry of Public Health |
| Who issues the substitute certificate? | Ministry of Labor, based on CONADIS documents | Ministry of Labor, but now uses data exclusively from the Ministry of Public Health |
Amended Articles – Key Changes (MDT-2025-054)
1. Article 3:
- The reference to CONADIS is removed and replaced by the Ministry of Public Health (MSP) as the technical authority.
- The concept of “severe disability” is redefined.
2. Article 4, Paragraph 2:
- The percentage thresholds for determining a direct substitute for a person with a severe disability over the age of 18 are adjusted.
“The person with a disability must meet the following percentages: Intellectual, psychosocial, or multiple disabilities: with a severity level classified as serious, very serious, or complete, starting from 50% or more; or physical, auditory, visual, or speech disabilities: with a severity level classified as very serious or complete, starting from 75% or more, duly certified by the national health authority.”
3. Article 5:
- The requirements to certify direct substitutes for persons with severe disabilities are updated. Now, it is sufficient to present the national ID of the person with the disability, which must include the qualification issued by the Ministry of Public Health—this applies to both minors and adults.
4. Transitorial Provision:
Within a maximum period of 30 days, the Ministry of Labor must update the certification technology system to comply with the new technical and legal framework.
For further information, please contact us at: laboral@bustamantefabara.com.
Prepared by: Dr. Francisco Vacas and Atty. Emilia Montalvo B.