On December 30, 1971, the Panamanian government issued Cabinet Decree 252, published in Official Gazette 17040 and effective as of April 2, 1972. That instrument created the Labor Code still in force today. The decree abrogated Law 67 of November 11, 1947 — the country's first labor code — and Cabinet Decree 191 of 1971, which had governed dismissals. The text was structured in five books: individual employment relations, occupational hazards, collective labor relations, labor procedural law, and implementing provisions. At the time, it represented a modern codification that consolidated decades of scattered legislation.

Amendments came quickly. Law 55 of 1976 and Law 95 of the same year modified and supplemented provisions of the code, responding to tensions that the first years of practical application had revealed. In 1980, Law 22 introduced further modifications. The following year, Law 3 of 1981 restored articles that had been suspended, and Law 8 of 1981 went further: it abrogated Law 95 of 1976 and directly amended the code. This cycle of partial adjustments reflected the difficulty of implementing an ambitious body of law within a transforming economy. The Supreme Court of Justice also intervened during this early period: as early as 1973 it had declared certain provisions of the original decree unconstitutional, inaugurating a line of constitutional review that would persist for decades.

The deepest reform of the twentieth century came with Law 44 of August 12, 1995, published in Official Gazette 22847. That law modernized labor relations in a structural way: it abrogated, amended, and supplemented numerous articles, and replaced entire institutions, among them the Conciliation and Decision Boards established by Law 7 of 1975. Law 44 sought to balance the flexibility demanded by employers with the protections championed by trade unions, in a context of economic opening. Nevertheless, the Supreme Court continued its work of constitutional revision: joining the 1973 ruling came decisions in 1993, 1994, 1997, 1999, 2002, and — most recently — the ruling of August 24, 2007, which declared unconstitutional provisions of both the original Cabinet Decree 252 and Law 44 of 1995 itself.

The most turbulent episode of recent decades unfolded in 2010. Law 30 of June 16 of that year, an omnibus statute covering several subject areas, amended the Labor Code on three sensitive fronts: union dues, the legal effects of strikes, and the composition of the Workers' Council. The changes triggered protests that reached particular intensity in the province of Bocas del Toro. The legislative response was swift: Law 39 of August 16, 2010 suspended the contested articles and restored the original provisions for a period of ninety days. Once that period elapsed, Law 68 of October 26, 2010 replaced the labor provisions of Law 30 with a revised text, formally closing the regulatory crisis even as the underlying social debate continued.

The covid-19 pandemic prompted a new wave of reforms in 2020. Law 126 incorporated remote work into the labor framework; Law 135 strengthened nursing protections in the workplace; and Law 157 established mechanisms to protect employment during the health emergency. In 2021, Law 237 added complementary provisions, and in 2022, Law 291 introduced further adjustments. In parallel, the Ministry of Labor issued several executive decrees that regulated specific articles of the code in areas including maritime employment, subcontracting arrangements, and labor migration.

More than fifty years after its enactment, Cabinet Decree 252 of 1971 remains the foundational legal text for employment relations in Panama. It has never been abrogated in its entirety. But the text applied today is, in large measure, the product of successive layers of reform: articles amended by Law 44 of 1995, provisions revised by the Supreme Court across several rulings, urgent adjustments such as those of 2010, and recent additions such as those stemming from the pandemic. Panama's Labor Code is no longer the text published in Official Gazette 17040; it is a collective legal construction that fifty years of legislation, jurisprudence, and negotiation have shaped upon that original foundation.