Preparing for the pension reform: a challenge that goes beyond payroll
For a company, preparing for the pension reform does not mean merely adjusting payroll. It also involves understanding the pension situation of its workers, reviewing their employment histories, and promptly identifying transition situations, pension proximity, and retirement that may affect human management.
In this context, companies face a decisive challenge following the Constitutional Court's ruling in Judgment C-264 of 2026, through which it declared the provisions of Law 2381 of 2024 that were validly approved to be enforceable and established that they will enter into force as of April 1, 2027. Some provisions remained subject to the remediation procedure ordered to the Chamber of Representatives.
As of the publication of this article, the Chamber of Representatives is carrying out the remediation procedure ordered by the Constitutional Court; the judgment was notified on September 17, 2026, and the 30-business-day deadline expires on October 29, 2026.
The period prior to the entry into force of the reform represents a key opportunity for organizations to review their payroll, social security, and human management processes and anticipate the necessary adjustments.
Adapting the company to the pension reform is not a simple IT or payroll adjustment; it involves reviewing operational and compliance obligations toward its workers and the Social Security System.
The four pillars of the new pension system
The new pension system is structured around four pillars: Solidarity, Semi-contributory, Contributory, and Voluntary Savings. For companies, beyond knowing this structure, what will be relevant is translating its effects into concrete payroll and human management processes:
- Parameterization of contributions.
- Review of employment histories.
- Identification of workers in transition.
- Analysis of pension proximity.
Transition regime: who is covered?
Once this new scheme enters into force, the pension reform will not cover all workers uniformly. The regulation provides for a transition regime that respects the conditions of Law 100 of 1993 for those employees who are closest to meeting their pension requirements under this system.
This transition regime covers women who have 750 weeks of contributions or more and men who have 900 weeks of contributions or more at the entry into force of the new System. The rules of Law 100 of 1993 will continue to apply to them in full, meaning they would not be subject to the new pillar scheme for purposes of consolidating their pension.
Contributory Pillar: two components and a single contribution
For workers not covered by the transition regime, the Contributory Pillar will have two components:
- Contributions corresponding to income up to 2.3 SMLMV will be linked to the Average Premium Component.
- The portion of income exceeding that limit and up to 25 SMLMV will be allocated to the Complementary Individual Savings Component.
The mandatory contribution will continue to be 16% of the contribution base income, of which the employer bears 75% and the worker 25%. This will require payroll and human management areas to review the proper parameterization and reporting of each worker's information.
The coexistence of two pension logics within the same organization
Accordingly, it is advisable for employers to identify the pension situation of their workers through internal audits and employment history review sessions, in order to determine how they will handle pension contributions and the pension proximity situation of each of the workers comprising their staff.
This regulatory transition means that, within the same organization, workers subject to two different contribution and pension logics may coexist.
Risks that a timely diagnosis makes it possible to identify
An adequate corporate diagnosis and the individualized analysis of each worker's employment history, with specialized legal support, enable the company to identify and prevent, among others, the following risks:
- Inconsistencies in employment histories: periods not contributed, weeks not consolidated, or information requiring validation.
- Labor contingencies: errors in determining the pension situation or in the reporting and settlement of contributions.
- Pension proximity: identification of workers close to consolidating pension requirements and analysis of their effects on employment decisions.
- Audit risks: inconsistencies in contributions to the Social Security System that may lead to requests from the UGPP.
Is your company prepared to answer these questions?
- Have you identified which of your workers could be covered by the transition regime, and do you have the supporting documents to substantiate that classification?
- Have you reviewed your workers' employment histories to identify inconsistencies that could modify their pension situation?
- Have you validated that the contributions made and your payroll parameterization correspond to each worker's particular situation?
- Have you identified workers close to retirement and evaluated the labor implications of adopting decisions regarding them?
- Do you have a procedure to correct inconsistencies in employment histories, manage actions before the administrators, and plan the retirement, guidance, and succession of workers close to retirement?
From diagnosis to preventive plan
Answering these questions requires more than an administrative review of payroll. It entails individually analyzing the employment history, weeks contributed, applicable regime, social security obligations, and the possible labor implications of each case. In addition, identifying workers close to retirement in advance makes it possible to guide them properly and plan knowledge transfer and the succession of duties.
Therefore, the next step is to turn this review into a preventive plan: clean up employment histories, classify workers according to their pension situation, validate payroll parameterization, and define the necessary labor and human management actions.
A corporate pension diagnosis, with specialized legal support, makes it possible to transform this review into a risk map and concrete actions in response to the changes expected as of 2027.
