Contractors · Social security
Contractor social security: what the hiring company must verify
Contractor social security is the enrollment in, and payment of contributions to, health, pension, and occupational risk insurance (ARL) for people who provide services to a company without an employment contract, and for the workers of contractor companies. The hiring company must verify it: Article 108 of the Tax Statute makes the deduction of payments to independent contractors conditional on that verification, and Decree 1072 of 2015 requires verifying occupational risk enrollment before work starts and periodically.
This page explains the general framework. It doesn’t replace reading the current regulatory text or the advice of a labor or tax professional.
What contractor social security is and why the hiring company verifies it
Social security in Colombia has three components: health, pension, and occupational risk. If the person is the company’s employee, the company enrolls them and pays. If they come in through a service agreement, or as a worker of another company, enrollment and payment are in someone else’s hands, and the hiring company’s job is to verify that they exist.
- EPS: entidad promotora de salud (health insurer) The entity the person enrolls with for health coverage
- Pension fund administrator The entity that receives the contributions toward the person’s pension
- ARL: administradora de riesgos laborales (Colombia’s occupational risk insurer) The entity that covers work accidents and occupational diseases
- PILA: Planilla Integrada de Liquidación de Aportes (integrated contribution form) The channel through which social security contributions are calculated and paid
What you verify depends on who comes in: an individual who contributes as an independent worker, or a contractor company that answers for its workers as their employer.
| Individual under a service agreement | Contractor company with its own workers | |
|---|---|---|
| Who pays health and pension | The contractor, as an independent worker, through the PILA | The contractor company, as its workers’ employer |
| Who enrolls them with the ARL | The hiring company, when the agreement is in writing and lasts more than one month | The contractor company, as the employer |
| What the hiring company verifies | ARL enrollment and payment of the period’s contributions | ARL enrollment of every worker who enters, before work starts and periodically |
| Reference rule | Law 1562 of 2012, Decree 1072 of 2015, and Article 108 of the Tax Statute | Decree 1072 of 2015, Article 2.2.4.6.28, and Article 34 of the Labor Code |
Social security is one piece of each contractor’s file. The other documents required for each activity are organized in the document requirements matrix.
Individual contractors: enrollment and contributions of an independent worker
Law 1562 of 2012 made people hired under a formal service agreement lasting more than one month mandatory members of the General Occupational Risk System. Decree 1072 of 2015 specifies that a formal agreement is one that is in writing.
For these contractors, enrollment with the ARL is the hiring company’s responsibility, and it must happen at least one day before the work starts, because coverage begins the next calendar day. If the hiring company doesn’t enroll the contractor, it is liable for any financial and medical benefits that apply. The contractor pays the ARL contribution when the enrollment is at risk class I, II, or III, and the hiring company pays it at risk class IV or V.
For health and pension, the contractor contributes as an independent worker. Under Decree 780 of 2016, as amended by Decree 1273 of 2018, they pay in monthly periods, in arrears, through the PILA. Each period produces a new contribution form, and that is the proof they submit.
Decree 1072 of 2015 also requires the hiring company to include these contractors in its OHS management system (SG-SST) and to verify at any time that they meet the occupational health and safety requirements for the contracted activity.
Why verification is also a tax matter
Paragraph 2 of Article 108 of the Tax Statute (Estatuto Tributario), added by Law 1393 of 2010, provides that, for payments to independent workers to be deductible, the hiring company must verify the contractor’s enrollment and payment of the social protection contributions the law requires of them, under the regulations issued by the national government.
So verification isn’t only an occupational health and safety practice: whether the payment to the contractor is deductible on the company’s income tax return depends on it. That’s why three areas care about it: purchasing or the contract administrator, who requests the proof; OHS, which needs it before entry; and accounting, which needs it for the close.
Which proof is enough, and how the contribution must match the value of the contract, is developed in the regulations and in tax authority guidance, both of which change. That reading belongs to the company’s accounting or tax team.
Contractor companies: the workers who enter your operation
When the contractor is a company, it enrolls its workers and pays their contributions. The hiring company doesn’t pay that social security, but it does verify it. Article 2.2.4.6.28 of Decree 1072 of 2015 requires the employer to ensure that suppliers, contractors, and their workers or subcontractors comply with the occupational health and safety rules of its company. At a minimum, it must:
- Include occupational health and safety in the evaluation and selection of suppliers and contractors.
- Verify before work starts and periodically that the obligation to enroll in the General Occupational Risk System is met, taking into account staff turnover at suppliers, contractors, and subcontractors.
- Inform them, before the contract starts, of the hazards and risks of their work area and how to control them.
- Verify periodically, during the contract, that they comply with occupational health and safety regulations.
The reference to staff turnover is the one that weighs most: a contractor that changes crews changes the people to verify. Informing workers of hazards before they start is usually handled with a contractor induction.
Joint liability
Article 34 of the Labor Code (Código Sustantivo del Trabajo), as worded by Law 2466 of 2025, provides that whoever contracts or subcontracts works or services is jointly liable with the contractor for the wages, benefits, and severance owed to the contractor’s workers, unless the work is unrelated to the normal activities of its business. The same rule allows it to agree on guarantees with the contractor and to recover what it paid from them.
Verifying doesn’t remove that liability. It lets you detect early that a contractor isn’t meeting its obligations to its staff.
What proof to request and how often to renew it
Each document proves something different:
Paid PILA form
Proves payment of the contributions for one contribution period. It must match the period and include the person.
ARL enrollment certificate
Proves the person is enrolled in occupational risk insurance, with which insurer, and at which risk class.
Contractor company’s PILA form
If the contractor is a company, its form must include the workers who enter.
The PILA form covers one contribution period, so it is renewed every period for as long as the contract lasts. ARL enrollment is verified before work starts and periodically, especially every time a new person comes in.
- Before work starts Valid ARL enrollment for every person who will enter
- Every period The paid form for the period, with the person included
- During review The person, the period, the ARL, and the activity’s risk class all match
- Afterward Keep the proof and the record of who approved or rejected it, and when
Tracking the expiration of all of a contractor’s documents is covered separately, in contractor document expirations.
What happens if the company doesn’t verify
The consequences depend on the case. The rules cited here point to these:
| What’s missing | Consequence | Rule |
|---|---|---|
| ARL enrollment of an individual contractor | The hiring company is liable for any financial and medical benefits that apply | Decree 1072 of 2015, Art. 2.2.4.2.2.5 |
| Verification of the independent worker’s contributions | The deduction of the payment to the contractor may not be allowed | Tax Statute, Art. 108, Paragraph 2 |
| Verification of the contractor’s workers’ enrollment | Breach of the hiring company’s occupational health and safety obligations | Decree 1072 of 2015, Art. 2.2.4.6.28 |
| The contractor’s compliance with its staff | Joint liability for wages, benefits, and severance, unless the work is unrelated to the normal business | Labor Code, Art. 34 |
On top of that there is an operational risk: a person without valid enrollment who has an accident on your premises. That’s why it makes sense to treat this proof as a condition for entry, not only for payment.
Reviewing the proof can be run in a system
Part of what the rules require is document operations: requesting the proof, reviewing it, knowing when it stops being valid, and not letting in anyone whose proof isn’t current. In NAVA 360, the company defines in its document requirements matrix which proof it requires for each type of element and activity, how often it expires, who approves it, and which review criteria apply.
The contractor registers each person with their EPS, pension fund, ARL, and risk class, and uploads the proof as a PDF with its issue date; the system calculates the expiration date. Your team, or NAVA’s back office on the Plus plan, approves or rejects each document with the criteria in view, and every decision is logged with the person responsible and the date.
If the proof is marked as entry-restrictive and is expired or rejected, the person isn’t cleared for entry and access control doesn’t let them in. When an exception is needed, an entry override requires a recorded justification and is logged.
What NAVA doesn’t do
NAVA doesn’t replace the company’s social security management or its advisors. Specifically, NAVA:
- Doesn’t calculate or pay health, pension, or occupational risk contributions
- Doesn’t enroll contractors or workers with an EPS, a pension fund administrator, or an ARL
- Doesn’t query PILA operators or ARLs: it reviews the document the contractor uploads
- Doesn’t calculate the contribution base or determine the risk class of an activity
- Doesn’t provide labor or tax advice
What NAVA runs is the request, review, and validity of the proof, with evidence of every decision. What is required and when a document is sufficient is the company’s decision.