Colombia: Decree 1435 of 2025 Extends the Special Early Retirement Regime for High-Risk Activities

Introduction

On 26 December 2025, the National Government, through the Ministry of Labour, issued Decree 1435 of 2025, which extends the validity of the special pension regime for high-risk activities originally established under Decree-Law 2090 of 2003. This extension remains in force pending the issuance of a comprehensive law by Congress regulating early retirement pensions for high-risk activities.

It should be recalled that the validity of Decree-Law 2090 of 2003 had previously been extended until December 31, 2024, pursuant to Decree 2655 of 2014.

 

Scope of the Extension

Decree 1435 of 2025 does not modify the list of high-risk activities set out in Article 2 of Decree-Law 2090 of 2003, nor does it alter the legal definition of such activities. Accordingly, the special regime continues to apply to all workers who perform high-risk activities included in the existing catalogue, regardless of their date of hire, provided they meet the conditions established under the applicable regulations.

The extension will remain in effect until Congress enacts definitive legislation governing early retirement pensions for high-risk activities.

 

Legislative Outlook and Institutional Oversight

Within twelve months following the entry into force of Decree 1435 of 2025, the National Government is required to submit a bill to Congress aimed at comprehensively regulating old-age pensions associated with high-risk activities.

In parallel, the Ministry of Labour, in coordination with the National Council of Occupational Risks, will carry out ongoing technical monitoring of high-risk activities to assess whether the conditions justifying the special pension regime continue to exist.

 

Employer Considerations

In light of the extension of the special regime and the anticipated period of regulatory transition, employers should consider reviewing their compliance with obligations related to high-risk activities, including:

• Verifying the eligibility of workers exposed to objectively defined high-risk conditions, taking into account job positions, roles, shifts, and functions, as well as the proper payment of the additional contribution to the General Pension System.
• Extending verification controls to contractors and subcontractors performing activities included in the current high-risk catalogue, in order to ensure consistent protection standards and adequate documentary compliance in the event of inspections.
• Preparing for potential audits or inspections by compiling relevant internal policies, job classification matrices, exposure records, COPASST minutes, and evidence of differentiated pension contributions, enabling an effective response during the technical monitoring period and the transition to the future statutory framework.

 

Conclusions

Decree 1435 of 2025 temporarily preserves the legal continuity of the special early retirement regime for high-risk activities, while deferring its definitive regulation to Congress. During this interim period, employers remain subject to existing obligations under Decree-Law 2090 of 2003 and should expect increased technical monitoring by labour authorities. The extension underscores the importance of maintaining accurate classification of high-risk roles, proper contribution payments, and robust documentation to mitigate regulatory and enforcement risks ahead of the forthcoming legislative reform.