Salud mental 2026;

ISSN: 0185-3325

DOI: 10.17711/SM.0185-3325.2026.02

Psychosocial Risk in Mexico: Beyond Regulatory Compliance with NOM-035

Erika Villavicencio-Ayub1 , Eva Yunue Cárdenas Marín2 , Carlos Humberto Zúñiga Cruz3 , Jorge Mérida Puga4


1 Executive Board. President, Colegio Nacional de Psicología para el Trabajo. Mexico City, Mexico

2 Executive Board. Founding President, Colegio Nacional de Psicología para el Trabajo. Mexico City, Mexico

3 Executive Board. Vice President of Strategy and Institutional Relations, Colegio Nacional de Psicología para el Trabajo. Mexico City, Mexico

4 Executive Board. Vice-President of Mental Health in the Workplace Colegio Nacional de Psicología para el Trabajo. Mexico City, Mexico

Correspondence: Jorge Mérida Puga Ometusco 35, 5o Piso, Oficina 5 Hipódromo, Cuauhtémoc 06100 Mexico City, Mexico. Phone: +52 (55) 7084-4244 Email: jorge_merida@conapsit.org




NOM-035-STPS-2018 is an occupational health standard issued by the Mexicangovernment in 2018, designed to identify, analyze, and prevent Psychosocial Risk Factors(PRFs) in the workplace, and promote a favorable organizational environment (Secretaríadel Trabajo y Previsión Social [STPS], 2018). Since it came into force in 2019, the standardhas formally acknowledged that work can determine mental health when organizationalconditions create sustained exposure to psychosocial risks.

Contrary to popular belief, NOM-035 is not a “law against stress,” but rather a riskmanagement instrument shifting the focus from individual maladjustment to structural organizationalfactors. This perspective aligns with international evidence indicating thatpsychosocial risks are fundamentally rooted in the organization of work rather than individualvulnerability (International Labour Organization [ILO], 2022. From a public healthstandpoint, the standard represents progress in recognizing the right to mental health protectionwithin the workplace. The World Health Organization (WHO) has declared thatdecent work and healthy organizational environments are key determinants of psychologicalwell-being (WHO, 2022). Acknowledging PRFs involves accepting that work-relatedharm extends beyond physical injury to include psychosocial dimensions with potentialclinical implications.

A critical appraisal of NOM-035 reveals both strengths and limitations. Its contributionsinclude the recognition of mental health protection as an employer’s legal obligation,the promotion of structural prevention through organizational review, and the potential toreduce hidden costs associated with burnout, absenteeism, and turnover. The ILO estimatesthat work-related stress and mental health disorders account for productivity losses of upto 4% of GDP in certain contexts (ILO, 2016). These figures show that psychosocial risk isnot merely an ethical concern, but also a macroeconomic variable.

However, several years into its implementation, field experience suggests that NOM-035 tends to polarize organizational responses. Professional practice in psychosocial risk assessmentand intervention across multiple productive sectors has uncovered two contrastingpatterns: organizations that reduce the standard to a compliance exercise, and those that useit as a strategic lever for cultural transformation. The difference lies not in the questionnaireincluded in NOM-035 itself, but in the willingness to intervene based on its results.

In many workplaces, compliance remains largely procedural, prioritizing the periodicadministration of surveys over structural redesign. When implementation is limited to documentationwithout addressing workload distribution, leadership practices, or clear clinicalreferral pathways, the standard risks losing legitimacy among employees. This simulationeffect weakens preventive culture and reinforces distrust. Although noncompliance maytrigger substantial economic sanctions under the applicable labor enforcement framework(STPS, 2018), enforcement capacity remains limited relative to the total number of workplacesnationwide. Therefore, sustainable implementation cannot depend solely on regulatoryoversight; it must be anchored in organizational leadership.

National indicators reflect mixed outcomes. Recent reports indicate that anxiety(52.8%) and depression (25.1%) remain among the most frequently reported conditionswithin the working population in Mexico (Gobierno de México, 2024). At the same time,Mexico continues to rank among the OECD countries with the highest annual working hours (Organisation for Economic Co-operation and Development[OECD], 2023). These data suggest that regulatoryrecognition has not yet translated into a substantial reductionin perceived psychological distress.

Persistent psychosocial risks include work–family interference,negative leadership styles, workplace violence,and unrealistic workload demands. Empirical research hasconsistently shown that chronic exposure to high job demandsand low control increases perceived stress. It alsoalters emotion regulation, sleep architecture, and neuroendocrinestress responses, potentially precipitating clinicallysignificant anxiety, depressive disorders, and stress-relatedsyndromes in vulnerable individuals (Karasek & Theorell,1990; WHO, 2022). When these conditions are normalizedwithin organizational culture, risk evolves from situationalstress to potential clinical impairment.

Within this framework, the 2030 horizon requires adecisive transition from measurement to intervention. The2030 Agenda for Sustainable Development—particularlySustainable Development Goal (SDG) 3 (Good Healthand Well-Being) and SDG 8 (Decent Work and EconomicGrowth)—underscores the need to incorporate health considerationsinto labor and economic policy (United Nations,2015). Moreover, the recent inclusion of stress and anxietydisorders in Mexico’s official table of occupational diseasesreinforces the medico-legal implications of psychosocialrisk exposure. In this context, psychosocial risk managementbecomes directly linked to occupational disability, insurancepremiums, and potential litigation.

From a clinical standpoint, it is essential to emphasizethat NOM-035 is not a diagnostic instrument. While itsfindings may guide organizational decision-making, theydo not substitute individual clinical evaluation. When exposureto PRFs becomes chronic, organizational distress canevolve into clinically significant anxiety, depressive disorders,or stress-related conditions (WHO, 2022). Under thesecircumstances, collective detection mechanisms must be articulatedwith clear referral pathways and specialized care.Otherwise, there is a risk of institutionalizing assessmentwithout ensuring adequate intervention.

Importantly, this discussion does not imply transferring full responsibility to the business sector or replacing the public health system, which faces structural limitations in coverage and infrastructure. However, when organizational conditions directly contribute to psychosocial risk generation, preventive omission becomes ethically and strategically unsustainable. In a health system already operating under capacity constraints, externalizing the clinical consequences of workplace-related psychosocial exposure without modifying its structural causes constitutes an unstable equation.

NOM-035 offers Mexico the opportunity to consolidate a mature model of psychosocial risk governance—one that integrates regulation, evidence-based organizational redesign, and clinical articulation. Properly implemented, the standard can serve not merely as a compliance requirement, but also as an indicator of corporate governance, sustainable productivity, and human rights commitment. Improperly implemented, it risks becoming a bureaucratic artifact disconnected from actual prevention.

In conclusion, NOM-035 represents a significant regulatory step in recognizing mental health as an integral component of the work environment. Its long-term effectiveness will depend on the capacity to move beyond administrative compliance and toward an integrated model articulating regulation, organizational practice, and specialized clinical intervention, consistent with international commitments to sustainable development. Measuring psychosocial risk is a starting point; transforming organizational conditions would be the decisive step. The future of mental health in the workplace in Mexico will not be determined by the existence of the standard, but by the depth and integrity of its implementation.

Citation:

Villavicencio-Ayub, E., Cárdenas Marín, E. Y., Zúñiga Cruz, C. H., & Mérida Puga, J. (2026). Psychosocial Risk in Mexico: Beyond Regulatory Compliance with NOM-035. Salud Mental, 49(1), 1–2. https://doi.org/10.17711/SM.0185-3325.2026.02

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