¿QUÉ SANCIONES EXISTEN SI NO SE ELABORA EL PLAN DE IGUALDAD?

Desde hoy (7 de marzo de 2021) las empresas de más de 100 trabajadores tienen la obligación de implantar un PLAN DE IGUALDAD en su empresa.

Respecto de esta obligación puede existir alguna confusión a efectos de sanciones en caso de su incumplimiento.

¿Qué SANCIONES existen si no se elabora el plan de igualdad?

En materia de planes de igualdad existen dos tipos sancionadores en el Texto Refundido de la Ley de Infracciones y Sanciones en el Orden Social (en adelante TRLISOS):

Art. 7. 13 TRLISOS – Se impone este tipo cuando la empresa NO elabora el plan de igualdad o incumple las medidas derivadas de dicho plan. La dicción legal establece:

No cumplir las obligaciones que en materia de planes y medidas de igualdad establecen la Ley Orgánica 3/2007, de 22 de marzo, para la igualdad efectiva de mujeres y hombres, el Estatuto de los Trabajadores o el convenio colectivo que sea de aplicación.

Es decir, NO ELABORAR el plan de igualdad cuando se está legalmente obligado a ello es una INFRACCION GRAVE que puede llevar aparejadas sanciones de hasta 6.250 euros.

El otro tipo es el Art. 8.17. TRLISOS:

No elaborar o no aplicar el plan de igualdad, o hacerlo incumpliendo manifiestamente los términos previstos, cuando la obligación de realizar dicho plan responda a lo establecido en el apartado 2 del artículo 46 bis de esta Ley.

¿Cuándo se aplica? Cuando se incumpla la obligación de elaborar el plan de igualdad impuesto por la Autoridad Laboral. Os explico.

Si una empresa comete alguna infracción en materia de discriminación (Art. 8. 12, 13 y 13.bis TRLISOS), además de las sanciones económicas que se pueden imponer en virtud del art. 40 TRLISOS, lleva aparejada SANCION ACCESORIA del art.46. bis.

Pues bien, el art. 46.bis.2 establece que en el caso de infracciones relativas a DISCRIMINACIÓN directa o indirecta por razón de SEXO (art. 8.12 LISOS) las sanciones accesorias del art. 46.bis podrán ser sustituidas por la elaboración y aplicación de un plan de igualdad en la empresa, y siempre que la empresa no estuviere obligada a la elaboración de dicho plan en virtud de norma legal, reglamentaria o convencional, o decisión administrativa, si así SE DETERMINA por la Autoridad Laboral.

Es decir, la Autoridad Laboral puede sustituir esa sanción accesoria de pérdida de bonificaciones siempre que se elabore un plan de igualdad. Esto último solo se aplica si la empresa, en principio, no estuviera legalmente obligada a elaborar dicho plan.

Partiendo de lo anterior, si la Autoridad Laboral te obliga a elaborar el plan de igualdad, como obligación sustitutoria de la sanción accesoria, y la empresa INCUMPLE la obligación de elaborarlo, entonces es cuando entra en acción el art. 8.17 TRLISOS que es la infracción MUY GRAVE.

Para concluir, en materia de planes de igualdad:

Si no se elabora el plan en la empresa o se incumple medidas derivadas de dicho plan es INFRACCION GRAVE.

Si se incumple la obligación de elaborar el plan de igualdad cuando venga impuesto por resolución de la Autoridad Laboral como sustitutoria de la sanción accesoria del art. 46.bis es INFRACCION MUY GRAVE.

Además, hay que recalcar que la infracción del art. 7.13 (no elaborar el plan) NO
CONLLEVA SANCCION ACCESORIA DEL ART. 46 o 46.BIS TRLISOS. Las sanciones accesorias solo se aplican en los supuestos tasados en los mencionados preceptos.

En cambio, si la empresa comete la infracción del art. 8.17 TRLISOS además de la sanción económica, se aplicará la sanción accesoria que inicialmente se había “perdonado” por la Autoridad Laboral.

1.738 comentarios en «¿QUÉ SANCIONES EXISTEN SI NO SE ELABORA EL PLAN DE IGUALDAD?»

  1. Buenos días
    Se agradece el artículo.
    No obstante, si me permiten, sugiero una nueva entrada que aborde las consecuencias de los incumplimientos de los RDL 901 y 902 de octubre del 2020
    Planes de Igualdad aprobados y registrados antes de enero del 2021:
    1. Sin Auditoría retributiva
    2. Mediante comisión ad hoc, al carecer la empresa de RLT

    ¿Qué sanciones se derivarán del incumplimiento de ambos RDL, a pesar de tener un Plan de igualdad aprobado conforme a normativa anterior a octubre del 2020?

    Un cordial saludo

    Daniel

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