17. The Supreme Court of Justice of the Argentine Nation proposes an abstract analysis in which it assesses whether the retrogressive measure in question is justified, 49 considering a special protection for the most vulnerable groups.50 18. The Constitutional Court of Ecuador has recognized that the principle is not exhausted by the abstention from adopting retrogressive measures, but rather the failure to take positive steps, such as legislative measures. Regarding the principle of nonretrogressivity in the analysis of legislative measures, it has considered that a provision is retrogressive, and therefore unconstitutional and non-conventional, when two elements have been verified: (i) the real reduction of the constitutional content of the rights, and (ii) that the measure has not been adopted based on the “most careful consideration.”51 Regarding the “most careful consideration” of the restrictions and of retrogressive legislative measures, it has determined the need for their justification in function of the satisfaction of another constitutional right and of their proportionality.52 19. Meanwhile, the Constitutional Court of Peru, even though, initially, it merely made an imprecise examination of the principle of retrogressivity in which the measure could be justified by reasons of the common good,53 in recent years it has opted for criteria that could be the starting point for a more detailed test for the analysis of retrogressive measures. For example, in order to analyze the constitutionality of a reduction in remuneration, it has noted whether: (i) it is justified for reasons of social interest or, which is the same, provided that there is a legal or objective cause that justifies it; (ii) it is a special measure; (iii) it is a measure to meet certain circumstances, and (iv) its effect is for a limited time. 54 20. The Constitutional Court of Guatemala has established that a measure may be retrogressive: (i) when it cuts or limits the substantive sphere of protection of the respective right to a social benefit; (ii) when it substantially increases the requirements to access the right in question, and (iii) when it decreases or deviates, effectively and significantly, the public resources allocated to satisfy the right, before compliance with the respective social benefit has been verified.55 Notwithstanding the foregoing, it has also considered that retrogression could be justified at a specific moment in time, provided that the principles of reasonableness and proportionality were respected.56 Cf. Argentine Supreme Court of Justice of the Nation, García Cancino, María Angélica v. Máxima A.F.J.P. S.A. ref. various submissions, S.C.G. 2.033 L. XXXIX. Judgment of February 16, 2010, and Cf. Argentine Supreme Court of Justice of the Nation, National Register of Rural Workers and Employers v. National Executive and Others/application for amparo. CSJ 906/2012 (48-R) /CS1. Appeal. Judgment of November 24, 2015, paragraph 6. 49 Cf. Argentine Supreme Court of Justice of the Nation, State Workers Association ref. action on unconstitutionality. A. 59B. XLIII. Appeal. Judgment of June 18, 2013, paragraph 11. 50 Cf. Constitutional Court of Ecuador, Judgment No. 002-18-SIN-CC, Cases No. 0035-15-IN and accumulated, June 7, 2017, pp. 78 and 79, March 21, 2018. 51 Cf. Constitutional Court of Ecuador, Judgment No. 017-17-SIN-CC, Case No. 0071-15-IN, June 7, 2017, pp. 15 and 16; Judgment No. 0006-15-SCN-CC, Case No. 0005-13-CN, May 27, 2015, pp. 15 and 16. 52 Cf. Constitutional Court of Peru, Lawyers’ Professional Associations of Cusco and Callao and more than five thousand citizens v. Congress of the Republic. Unconstitutionality proceedings. File No. 00050-2004-AI/TC, June 3, 2005, p. 60. 53 Cf. Constitutional Court of Peru, 0020–2012–PI/TC, April 16, 2014, p. 20. 54 Case of Educational Reform Law 2, SCT–01.014–PI, File Cf. Constitutional Court of Guatemala, General and partial unconstitutionality. Accumulated files 3-2011, 42011 and 52-2011, p. 25 and ff. 55 Thus, the examination of retrogressivity by the Constitutional Court of Guatemala consists in determining whether: (i) the measure adopted seeks to satisfy a constitutional purpose; (ii) is valid to achieve the objective sought; (iii) the different alternatives have been assessed and the measure is necessary to achieve the proposed 56 9