Registering employees with EPS, pension, ARL and compensation funds: the employer's duties
Registering employees with EPS, pension, ARL and compensation funds: the employer's duties
An employee starts on a Monday and is exposed from that same day. They may fall ill, have an accident in the warehouse, crash on the way to work. When that happens, the question is not whether they were on the payroll: it is whether they were registered. Registration with health (EPS), pension, work-risk insurance (ARL) and the compensation fund is not a first-week formality, and it is not something to fix when the payroll filing comes due. It begins on day one of the employment relationship, and when it is missing, the cost shifts to the employer.
This article covers the right order, who decides what, which documents to collect and keep, which changes must be reported, and how to check before paying that nobody was left out. It closes with a full onboarding, step by step with dates, and with the contrast of what happens when registration is done on the last day of the month.
The obligation starts on day one, not when the payroll filing is due
The employer must register the employee from the first day of the employment relationship with health, pension and work-risk insurance, and also with the compensation fund. No probation period suspends that duty. There is no window in which the employee "does not count yet": from the moment they work under subordination, coverage has to exist.
Many companies find this out late. The payroll is paid once a month; registration is needed on day one. They are two different calendars, and confusing them is the most common cause of people without coverage. Paying the payroll on time repairs nothing if registration was filed after the start date: the contribution can exist while the employee remains uncovered.
The other calendar mistake is the order. First you register, then you report the start in the payroll. If you report the start of someone who is not yet registered, the administrator has nobody to apply the contribution to.
Who chooses what, and why that changes the process
Registration is not one decision. It is four, and the same person does not make them all. The employee chooses the EPS and the pension fund. The employer chooses the ARL, because that choice depends on the economic activity and on the real risk level of the tasks. The compensation fund is defined by the company and is mandatory for its employees.
| Decision | Who decides | On what criteria | What to check |
|---|---|---|---|
| EPS (health) | The employee | Their preference and the network available where they live | That the choice is in writing and that the EPS accepts it |
| Pension fund | The employee | A private fund (AFP) or the public regime, as they choose | That the start report goes to the chosen fund |
| ARL (work risks) | The employer | Economic activity and risk level of the tasks | That the declared risk matches what people actually do |
| Compensation fund | The employer | Mandatory for employees | That the employee is registered and can access the benefits |
That split explains why the process jams. The company cannot impose an EPS or a fund, and the employee cannot choose the ARL. When someone in human resources "settles" all four boxes on their own, two problems appear at once: a registration the employee does not recognise and a declared risk that does not match what people do on shift.
Put the choice in writing, with a date. It is the support that prevents arguments when the employee transfers or when someone reviews their contribution history.
The right order: three registrations, one fund and one report
The order is not administrative whim. Each step produces a registration number that the next one needs, and the last step can only be closed when the previous four have an answer.
- Health. File the form with the EPS chosen by the employee, attach ID document and contract, and register the dependants who qualify.
- Pension. File with the fund chosen by the employee, whether a private AFP or the public regime. The company does not replace that choice.
- Work risks. Here the employer decides. The ARL is chosen by economic activity and risk level of the tasks, not by what is cheapest.
- Compensation fund. The employee is registered. It is mandatory and it is the door to subsidies, housing and recreation.
- Start report. With the four registrations accepted, report the start in the period's payroll and pay the contribution.
Some companies invert the order and report first, because the payroll has a deadline and the administrator's process does not. It is the most expensive choice: it leaves a paid contribution with no beneficiary.
Documents and forms: what to ask for on day one and what to keep
Registration is formalised with the registration form, the ID document and the contract. Add the dependants' supporting documents and each administrator's answer. Many of these steps are electronic today, which changes the format but not the duty to prove.
| Document | What it is for | When it is requested | Where it is kept |
|---|---|---|---|
| Registration form | Formalises the request with EPS, pension fund, ARL and compensation fund | On the start date | Employee file |
| ID document | Identifies the employee and their dependants | On the start date | Employee file |
| Employment contract | Proves the relationship and the start date | On the start date | Employee file |
| Dependants' supporting documents | Prove the family relationship | When registering dependants | Employee file |
| Registration confirmation | Proves the administrator accepted | When the answer arrives | Employee file and payroll support |
| Change report | Supports exit, transfer, salary change or incapacity | In the period in which it occurs | Employee file |
The trap of the electronic process is that nobody prints the confirmation: the submitted form is kept and the answer is lost. Registration exists when the administrator accepted it, not when it was filed. Keep the answer, not the filing receipt.
Health dependants: who can be included and what documents are required
Health registration can include dependants: spouse or permanent partner, children and, in some cases, parents. Each one requires a document proving the relationship and compliance with the conditions set by the EPS. It is not an open list and it is not automatic.
Two warnings. First: registration happens with the enrolment, not months later, because time without registration is time without coverage for those people. Second: when the family changes —a child is born, a couple separates, a dependant dies— the change is reported. A dependant still active after a change that already happened produces rejections and, in a review, questions nobody wants to answer with "it slipped past us".
The documents each EPS requires vary. Confirm them before promising anyone coverage.
What you cannot do, even if the employee agrees
Two prohibitions are broken more often than admitted.
The first: employment cannot be conditioned on a specific EPS or fund. The employee chooses, and that choice is not negotiable as part of the contract. The detour of "everyone here is with this EPS" does not work either, nor does hinting that the job depends on accepting the company's preference.
The second: the cost of registration cannot be deducted from the employee. The employer bears the process. A deduction for "registration management" or "paperwork" is not a saving: it is an amount that comes back when someone reviews the payroll closely.
There is a third practice that is not a written prohibition but works just as badly: registering only when the employee asks. The duty does not depend on the request. An employee who does not complain still creates liability for the company, and silence cannot be argued as a defence.
If you do not register, the employer answers directly
When the employer does not register, it answers directly for the services and benefits the system would have covered. It is not a fine: it is the value of the care. If the employee falls ill, the bill reaches the company. If they have an accident, the company assumes what the ARL would have covered. If there is an incapacity, the company pays what the system would have recognised.
That cost has three uncomfortable features. It arrives without warning, because the event is not scheduled. It arrives in full, because there is no co-payment or cap to limit it as in the system. And it arrives later, when the past can no longer be corrected: registering today does not cover yesterday's days.
The most expensive case is not the employee who was never registered, but the one registered late. The company believes it is covered because it sees the contribution in the payroll, and finds out it was not on the day of the accident.
Changes: the contract moves and the registration has to move with it
Registration is not a one-time step. During the relationship, facts appear that modify it, and each one is reported to the administrator and reflected in the payroll. What is not reported does not correct itself.
| Change | What it involves | Where it is reported | What is checked afterwards |
|---|---|---|---|
| Start | Enrolment of the employee and their dependants | Administrator and payroll | That the registration was accepted |
| Exit | End of the employment relationship | Administrator and payroll | That the last period's contribution is applied |
| EPS or fund transfer | Change of administrator chosen by the employee | Administrator | That no period is left without any |
| Salary change | New contribution base | Period payroll | That the base matches what was paid |
| Incapacity | Change affecting the reported period | Administrator and payroll | That the period is reported correctly |
| Dependant change | Adding or removing dependants | EPS | That coverage reflects the real family situation |
The typical mistake is on exit: the employee is settled, the letter is filed and nobody reports the change. Months later a contribution appears for someone who no longer works there.
Check before paying the payroll: the box that avoids the problem
Before paying, check each employee's registration status. A rejected registration leaves the contribution with no destination: the company pays, the money is returned or held, and the employee remains uncovered. The error does not show up on the payment receipt; it shows up when someone needs the service.
The check is short and concrete. Three questions per person: did the administrator accept the registration? does the start date in the system match the contract? are the registered dependants the right ones? If any answer is no, payment waits until it is resolved.
This works as a routine, not as heroics. Five minutes of checking before paying save weeks of paperwork afterwards.
Example: start on 1 March with a salary of COP 2,000,000
An employee signs a contract starting 1 March with a salary of COP 2,000,000. The company works in warehousing and trade. This is the route that leaves no gaps.
| Step | When | What is done | Verifiable result |
|---|---|---|---|
| 1 | Before 1 March | Collect ID document and signed contract; ask the employee for their EPS and fund choice | Choice recorded in writing |
| 2 | 1 March | File the health registration with the chosen EPS | Request filed with the 1 March date |
| 3 | 1 March | File the pension registration with the chosen fund | Request filed with the 1 March date |
| 4 | 1 March | Register with the ARL according to activity and task risk | ARL assigned |
| 5 | 1 March | Register with the compensation fund | Fund registration recorded |
| 6 | 1 March | Register dependants with their documents | Dependants accepted |
| 7 | Before the first payment | Confirm that all four registrations were accepted | Confirmations on file |
| 8 | March payroll | Report the start and pay the period's contribution | Start reported in the payroll |
The step most often skipped is 1. The hiring happens on Friday, the person starts on Monday and the EPS choice is asked on Tuesday, when the filing is already due. Asking before costs one phone call; asking after costs days of coverage.
Step 7 is what separates a real registration from a folder of forms. Filing is not registering. The difference shows up exactly when the service has to be used.
The contrast: the same person registered on 30 March
Now the same company does the paperwork on 30 March. The contract still says 1 March, the salary is still COP 2,000,000 and the March payroll is paid in full. The only difference is the registration date.
Days 1 to 29 are left without coverage. That is not an interpretation: registration takes effect from the moment it exists, and in that interval the employee had no EPS, no ARL and no fund. If they fell ill on the 12th, the company assumes the care. If they had an accident on the 20th, the same. If they needed an incapacity leave, the company answers for what the system would have recognised.
To size the gap: that employee's daily salary is 2,000,000 ÷ 30 = 66,667. The 29 days without coverage come to 2,000,000 × 29 ÷ 30 = 1,933,333. That is not the exact value of a contingency, because it depends on the event, but it gives the order of magnitude of what sits without backing.
The detail that gets overlooked: in that scenario the employee appears in the March payroll with the contribution paid. The company has the receipt and does not have coverage for 29 days. No later payment buys it back.
Common mistakes and how they look in practice
- Registering "when the payroll comes out". Symptom: the start is reported and registration is filed days later. Consequence: days without coverage that nobody records.
- Reporting the start before registration is accepted. Symptom: the contribution shows as paid. Consequence: a contribution with no destination and an uncovered employee.
- Assuming the employee's choice. Symptom: the company "assigns" EPS and fund. Consequence: a registration the employee does not recognise.
- Choosing the ARL by cost and not by risk. Symptom: registration comes out cheaper. Consequence: coverage that does not match the real tasks of the role.
- Deducting registration from the payroll. Symptom: a small line item nobody questions. Consequence: repayment and findings when the period is reviewed.
- Not reporting changes. Symptom: the exit, transfer or salary change stays in the conversation. Consequence: badly reported periods and contributions applied to someone who has left.
- Not keeping the administrator's answer. Symptom: the submitted form is kept and nothing else. Consequence: no proof that the registration ever existed.
- Leaving dependants out of date. Symptom: nobody reviews the family composition. Consequence: people without real coverage and rejections when they need care.
Almost all of these mistakes share one origin: registration is treated as a document and not as a condition for working. The document gets filed; the condition has to be sustained every month.
An honest close before you hire
None of this replaces advice from an accountant or a labour lawyer. Deadlines at each administrator and the documents each EPS requires depend on the case, the activity and the city. What is described here is the order and the logic; the specific application is confirmed with whoever signs the payroll.
Nor does it apply the same way in every case. Some engagements have their own rules, and companies with several work sites face different risk per site. There, the conversation with the ARL and the fund is not optional.
If your company still tracks registration in a loose spreadsheet, the first step is not to buy anything: it is to build the list of active employees with their start date, EPS, fund, ARL and compensation fund, and compare it against last period's payroll. That list reveals in one afternoon where the gaps are. Tools such as Kardex Tauro help keep payroll and the filing in the same system, but the list comes first.
