Increased pensionable service: how workplaces are determined

Increased pensionable service means that for a worker at a particularly arduous and health-harmful workplace, every 12 months of effective work counts as 14 to 18 months of pensionable service, and their retirement age is reduced. The right is not acquired by an employer's decision or by a collective agreement — the workplace must be listed in a rulebook or, if it is not, established through a procedure with expert documentation before the Revision Commission. This article explains the whole procedure and what specifically must be proven.

What the law says

The basis is the Pension and Disability Insurance Act (Official Gazette of RM no. 98/12 with numerous subsequent amendments; the latest relevant ones are published in Official Gazette of RNM nos. 193/24, 75/25, 154/25, 269/25 and 62/26).

Under Article 108, service at an increased rate is counted for two categories of insured person:

• those working at particularly arduous and health-harmful workplaces, and
• those working at workplaces where, on reaching a certain age, they can no longer successfully perform their professional activity.

The rate of increase depends on the severity of the harm, or on the nature of the work. Workplaces are allocated to five groups, so that every 12 months of effective work counts as 14, 15, 16, 17 or 18 months of service.

Which workplaces qualify

This is the part most often misunderstood. Article 109(1) sets three cumulative conditions — all three must be met simultaneously:

1. In connection with performing the work there must be significant harmful effects on health and on working capacity — notwithstanding that all general and specific protective measures laid down by regulation have been applied, along with other measures capable of eliminating or reducing the harmful effects.
2. The work must be performed immediately beside the sources of the harmful effects, in the continuous flow of the work.
3. The work in those circumstances must be performed by the same worker on a full-time basis — where working time shorter than 40 hours a week also counts as full-time if it has been set that way precisely because of the special working conditions.

The first condition is the hardest to prove. It is not enough to show that noise or dust is present — you must show that the harmful effect remains significant after all prescribed protective measures have been applied. If the problem is solved by better ventilation or by rotating workers, the workplace does not qualify.

Article 109(2) covers the second category: occupations in which, because of the nature and severity of the work, the body's physiological functions decline to a point that prevents the worker from continuing to perform the same activity successfully.

How large the benefit is

The source is Article 19(1) of the Act. Where an insured person has spent periods at workplaces with different rates, the total reduction is calculated proportionally, as the sum of the individually determined reductions (Article 19(2)). A special rule applies to underground work: an insured person with different rates may acquire the right to an old-age pension with 40 years of pensionable service (men) or 35 years (women) — Article 19(3).

An important limitation: under Article 113, service is increased only for time actually spent at work.

The procedure: from expert documentation to the Fund

1. Checking whether the workplace is already on the list

The official list is in the Rulebook determining the workplaces at which pensionable service counts at an increased rate (Official Gazette of RNM no. 174/25, supplemented by nos. 74/26 and 158/26), adopted under Article 110 of the Act. The list is extensive — over 60 pages in alphabetical order — and covers mining, metallurgy, energy, the chemical industry, customs and other activities. If the workplace appears there with the exact title and rate, no separate procedure is needed; the rulebook applies.

2. If the workplace is not on the list

Article 111 then applies. Workplaces not covered by the rulebook, and the revision of those workplaces, are determined by the Commission for the Revision of Workplaces at which Pensionable Service Counts at an Increased Rate.

The Commission is established by the competent minister and has three members: two specialists competent in occupational safety and health, and one member from the field of pension and disability insurance.

The key provision is Article 111(3): the Commission carries out both the determination and the revision on the basis of an elaborate for determining workplaces with pensionable service at an increased rate, prepared in accordance with the Methodology for determining the standards for preparing that elaborate. The Methodology is adopted by the competent minister (Article 111(4)) and prescribes the standards — the manner of measuring, processing and evaluating the data the elaborate must contain.

This elaborate is what is known in practice as "expert documentation for increased pensionable service". Since the Methodology changes independently of the rulebook containing the list, it is worth checking its current version with the Ministry of Social Policy, Demography and Youth, or with the Revision Commission, before starting a procedure — so that documentation is not prepared against a superseded standard.

3. Revision every five years

The revision is carried out within five years at the latest from the day of determination (Article 111(1)). The documentation is not a one-off — the position is re-examined periodically, and if conditions have improved the rate may be reduced or the right may cease. Article 111(5) allows employers themselves to initiate a procedure to change the technical and technological working conditions — a better long-term strategy than permanently paying an increased contribution.

4. Notification to the Pension Fund

Once the decision becomes final, the employer must submit the data on the increase in service to the Fund's master records within eight working days of the decision becoming final, or of the day the factual position is established for the work at which service counts at an increased rate (Article 209, point 5 of the Act).

The contribution for service at an increased rate provides the funds to cover the increased obligations arising from the benefit and from the reduced retirement age (Article 189 of the Act) — the cost falls on the employer.

What the expert documentation must contain

The structure of the elaborate is determined by the Methodology under Article 111(4), but its burden of proof follows directly from the three cumulative conditions in Article 109. Whatever the form, the elaborate must convincingly demonstrate:

• a precise description of the workplace, the technological process and the work tasks, with details of the employer and the number of workers at that workplace
• identification of the sources of harmful effects and confirmation that the worker works immediately beside them, in a continuous flow, on a full-time basis
• a review of all general and specific protective measures already applied — technical, organisational and personal protective equipment
• measurement results showing that the harmful effect remains significant even after those measures, compared against the maximum permitted values
• an analysis of the effect on the health and working capacity of the workers
• a conclusion proposing the rate of increase in service, with reasons why that particular rate is proposed

If any of these elements is missing or merely declaratory, the Commission has grounds to request supplementation, which prolongs the procedure.

The role of hazard measurements

Measurements are the evidential foundation of the entire elaborate. Without them, the assertion that "the work is harmful" remains a description rather than proof.

Measurements of noise, vibration, dust, chemical hazards in workplace air, microclimate and illuminance are most often required. The results are compared against the maximum permitted values, and the gap between the measured and the permitted is what carries the argument.

That is why workplace environment measurements and an up-to-date risk assessment are usually the first step rather than the last — before the procedure begins, they show whether the case has any prospect.

Key changes 2023 – 2026

The practical consequence of 174/25 is that all previous versions of the list are repealed. If your internal documentation refers to the 2021 rulebook, that reference is out of date and should be aligned with 174/25 and the supplements in 74/26 and 158/26.

The two 2026 supplements illustrate how the system works in practice: the list is not replaced wholesale but extended with individual workplaces once the conditions of Article 109 are found to be met. Checking whether a workplace is on the list should therefore always be done against the latest version, not the one saved in your archive.

How we can help

RI-Opusproekt prepares the expert documentation for determining workplaces with pensionable service at an increased rate and carries out the hazard measurements that support it. Before a procedure is started, we assess whether the workplace meets the three conditions of Article 109 at all — so that no money is spent on documentation with no prospect. See the increased pensionable service service or request a quote with a list of the workplaces you are interested in.

This article is informational and does not replace professional advice. Regulations change — last updated: August 2026.