On 8 April 2026, the Colombian government issued Decree 369 of 2026, which adds Articles 2.6.12.1.27, 2.6.12.1.28 and 2.6.12.1.29 to Decree 2555 of 2010 and sets a 30% cap on the foreign investments that pension fund administrators (AFPs) may maintain. The measure introduces a significant change to the investment regime for mandatory pension funds under the Individual Savings with Solidarity Regime, with the aim of redirecting resources currently invested abroad to the local market. 

Mandatory pension funds currently manage approximately COP 500 trillion (approximately USD 135 billion), of which around COP 250 trillion (approximately USD 68 billion) is invested abroad. Under the new 30% cap, AFPs would need to redirect around COP 100 trillion (approximately USD 27 billion) to the local market over the transition period, representing a significant reallocation of pension savings.

For these purposes, “foreign investments” refers to the eligible investments in foreign issuers set out in Article 2.6.12.1.2 of Decree 2555 of 2010. These include, among others, debt securities issued or guaranteed by foreign governments or international entities, foreign equities, interests in international funds such as ETFs and mutual funds, as well as interests in private equity funds, private debt funds and hedge funds domiciled abroad, real estate vehicles such as REITs, and investment schemes linked to commodities or FX. 
In practice, the decree captures most of the international exposures typically held in AFP portfolios and does not differentiate by return profile, jurisdiction or investment-grade ratings in requiring pension savings to be redirected to the domestic market.

For purposes of calculating the cap, the 30% limit is applied on an aggregate basis per AFP, considering all the mandatory pension funds it manages. To facilitate the adjustment, the decree provides for a transition regime allowing AFPs that currently exceed 30% in foreign investments to comply gradually. In particular, AFPs with existing foreign investments must reduce exposure to 35% no later than year 3 and reach 30% within a maximum total period of 5 years. 

Additionally, within six months of the decree’s entry into force, i.e., by 8 October 2026, AFPs must submit to the Financial Superintendence an adjustment plan for informational purposes. At a minimum, this plan must set out the criteria and measures the AFP will adopt to safeguard the security, profitability and liquidity of the managed resources during the divestment process, the applicable comprehensive risk management mechanisms, and the reorientation of new contributions toward local investments. 

Importantly, the decree requires that the entire flow of new contributions be invested in domestic assets until the 30% aggregate cap is met. In practice, this means that, while AFPs adjust their international exposure, all growth in pension savings will be channelled to assets in the local capital markets, preventing new investments abroad. 

The decree also authorises the Ministry of Finance and Public Credit to promote the structuring of investment projects aimed at Colombia’s productive sector and to develop investment alternatives that channel resources from mandatory pension funds. To that end, the decree provides that the Ministry will lead coordination efforts with AFPs, the private sector and public entities. However, the decree does not define the criteria, standards or implementing regulation that would determine the conditions under which such projects could be considered admissible investments for AFPs, leaving the applicable framework unclear. 

The decree entered into force on 8 April 2026, from which date the transition regime and the deadlines for submitting the adjustment plan begin to run. In this context, AFPs with foreign investments will need to assess the impact of the new cap on their portfolios and carefully rebalance their investment strategies, considering not only the reduction in international exposure but also the regulatory restrictions applicable to local investments and the liquidity, return and risk conditions that must be observed in managing these resources.