## Pension Reform in Comoros

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### Executive Summary
- CRC (Caisse des Retraites des Comores) is the main public pension system and a key component of the formal safety net.
- Mounting financial imbalances threaten CRC’s ability to meet benefit commitments, with particular vulnerability in the civil servants’ scheme.
- Actuarial analyses (conducted with the ILO) quantify projected financing gaps and identify drivers of imbalance.
- Even under the most comprehensive combination of parametric adjustments, the system is projected to continue requiring some level of transitional financing over the medium term.

### Context
- Social protection coverage in Comoros was about 3 percent of the population covered by at least one branch of the social protection system in 2022, excluding health.
- The 3 percent figure is below the 9.7 percent average for low-income countries (LIC).
- Structural constraints on coverage:
  - Predominance of informal employment: estimated at 88 percent of the active population.
  - Regulatory gaps and limited coordination across institutions.
- CRC provides income support to retirees and their families but faces sustainability challenges exacerbated by demographic trends and weak governance.
- The paper quantifies CRC’s projected financing gap and examines parametric reform scenarios via actuarial simulations.

### Pension System Structure and Key Parameters
- CRC administers three defined-benefit schemes: Civil servants; Non-civil servants (including private sector employees and non-civil servant public workers); Members of Parliament (MPs).
- Operates de facto on a pay-as-you-go (PAYG) basis with no accumulated reserves and informal cross-financing across schemes.
- Participation mandatory for formal sector workers; contributions shared between employers and employees.
- Key statutory parameters:
  - Civil Servants: Contribution Rate 17% (12% employer, 5% employee); Statutory Retirement Age 55–65 (category-dependent); Minimum Contribution Period 15 years; Benefit Formula 2% × years of service × last 6 months’ average salary.
  - Non-Civil Servants: Contribution Rate 8% (5% employer, 3% employee); Statutory Retirement Age 55–65 (category-dependent); Minimum Contribution Period 15 years; Benefit Formula 1.33% × years of service × last 6 months’ average salary.
  - Members of Parliament: Contribution Rate 26% (10% employer, 16% employee); Statutory Retirement Age 55; Minimum Contribution Period 5 years; Benefit Formula 5% × years of service × final parliamentary indemnity.
- Structural weakness: short salary reference period (average of the last six months) inflates pension liabilities relative to the contribution base.
- Demographics:
  - Civil servants’ scheme demographic ratio: fell from 4.1 in 2020 to 2.9 in 2024.
  - System-wide demographic ratio projected to fall from 2.9 in 2024 to 1.6 by 2035.
- Drivers of adverse demographic trend:
  - Stagnant contributory base, constrained by public sector hiring freezes.
  - Low enforcement of mandatory registration and weak compliance among non-civil servants.
  - Rising life expectancy lengthening retirement duration.
  - Declining fertility rates increasing demographic dependency.
- Main technical parameters (retirement age, minimum length of service, accrual rate) have remained unchanged.

### Methodology
- Analysis based on a financial sustainability study requested by Comorian authorities; full report (“Report to the Comoros Pension Fund – Sustainability Study”, ILO, forthcoming) submitted to authorities.
- Data collection: targeted CRC requests, field visits, technical exchanges.
- Significant administrative data gaps required substantial data reconstruction using best-estimated assumptions; supplementary data from the Ministry of Civil Service used.
- Scheme-by-scheme approach before consolidation:
  - Civil servants’ scheme: cohort-based projection using ILO actuarial modelling tool.
  - MPs and non-civil servants: projections based on aggregate assumptions calibrated to recent financial flows.
- Results are indicative estimates; key recommendations include improving data quality (individual member records), conducting external audits of financial statements, and strengthening monitoring of pension indicators.

### Financial Assessment and Short-Term Outlook
- CRC’s financial position deteriorated, creating significant liquidity pressures and sustainability risks.
- 2024 system deficit: over KMF 118 million (expenditures exceed ordinary contribution revenues).
- Legal average contribution rate broadly stable while PAYG required rate rose steadily and surpassed the legal rate in 2022.
  - Since 2022, ordinary contributions no longer suffice to meet annual obligations, causing liquidity shortfalls and pension payment delays.
- Exceptional and temporary supports mobilized:
  - Increase in civil servants’ contribution rate from 14 percent to 17 percent in January 2025.
  - Gradual clearance of government’s past unpaid contribution arrears via monthly transfers of KMF 60 million beginning in 2023, with outstanding payments expected to continue until 2029.
  - Ad-hoc budget support: two large disbursements of KMF 548 million in 2022 and KMF 527 million in 2024 to cover pension payments to civil servants and MPs.
- Without exceptional measures, CRC’s annual deficit would have exceeded KMF 1.3 billion in 2024.
- Scheme-level 2024 performance:
  - Non-civil servants’ scheme: generating a surplus.
  - Civil servants’ scheme: deficit of KMF 274 million in 2024 (theoretical figure); without exceptional state support, shortfall would have been over KMF 1.4 billion in 2024.
  - MPs’ scheme: deficit of KMF 69 million in 2024.
- Required PAYG contribution rates (2024):
  - Civil servants’ scheme: nearly 22 percent of salaries versus 14 percent legal rate in effect during the period.
  - MPs’ scheme: required rate exceeded 75 percent versus 26 percent legal rate.
- Arrears currently estimated at nearly KMF 2 billion.

### Actuarial Projections — System-wide and Scheme Drivers (2025–2035)
- Projection horizon: 2025–2035; baseline assumes no policy changes, stable contributor base, rising pensioners.
- System-wide baseline:
  - Nearly balanced in 2025 (due to arrears clearance and non-civil servants’ surplus) but annual deficit expected to exceed KMF 4.8 billion by 2035.
  - Cumulative financing requirement over 2025–2035 projected at over KMF 25.2 billion (excluding interest).
- Civil servants’ scheme:
  - Contributors-to-pensioners ratio declines from 3.8 in 2025 to 2.2 by 2035.
  - Annual deficit increases from KMF 364 million in 2025 to KMF 4.6 billion by 2035.
  - Cumulative financing needs reach KMF 26.6 billion over 2025–2035.
  - PAYG required contribution rate projected to rise from 22.5 percent in 2025 to nearly 38 percent by 2035 (statutory rate is 17 percent).
- MPs’ scheme:
  - Fewer than 35 active MPs depending on the legislature.
  - Annual deficit projected to grow from KMF 86 million in 2025 to nearly KMF 290 million by 2035.
  - By 2035 the MPs’ scheme accounts for less than 6 percent of CRC’s total projected financing gap.
- Non-civil servants’ scheme:
  - Currently in surplus under baseline with statutory contribution rate of 8 percent generating a cumulative surplus over the projection horizon.
  - Surplus is fragile and could be rapidly eroded by demographic or economic deterioration, slower formal job creation, or declining contribution compliance.

### Reform Options and Quantified Impacts (Civil Servants’ Scheme Focus)
- Simulations use ILO-Pension model and scheme-level data; reforms assessed individually and in combined packages.
- Contribution rate scenarios (civil servants statutory rate):
  - Baseline statutory rate: 17 percent.
  - Raising statutory rate to 23 percent by 2035 lowers cumulative financing need from KMF 26.6 billion to KMF 13.8 billion.
  - Even with higher statutory rates, PAYG required contribution remains above statutory rates (nearly 38 percent by 2035 in baseline).
- Accrual rate adjustments (prospective, preserve acquired rights):
  - Current accrual rate: 2 percent.
  - Reducing accrual to 1.75 or 1.33 percent (1.33 percent aligns with ILO Convention 102 minimum) yields gradual gains.
  - Lowering accrual to 1.33 percent reduces cumulative financing need from KMF 26.6 billion to KMF 24.9 billion by 2035.
- Salary reference period extension:
  - Current reference period: last six months.
  - Gradually extending to 60 months reduces cumulative financing need by KMF 2.5 billion by 2035.
- Minimum retirement age increase:
  - Baseline minimum retirement age: 55 years.
  - Reform scenario: gradual increase of six months per year starting in 2026 to reach 60 years by 2035.
  - Cumulative financing need declines from KMF 26.6 billion to KMF 25.1 billion by 2035.
- Combined reform packages:
  - Package 3 (most ambitious) includes, among others, 2-percentage points annual increase in population coverage and accrual rate aligned with ILO minimum.
  - Package 3 reduces cumulative financing need by over 90 percent, from KMF 26.6 billion to KMF 2.5 billion by 2035.
  - Under Package 3, PAYG required contribution rate stabilizes near 28 percent by 2035 (compared with nearly 38 percent in baseline).
  - Even Package 3 does not fully eliminate transitional financing needs through 2035.
- MPs’ scheme simulations:
  - Baseline statutory contribution rate for MPs: 26 percent.
  - Increasing to 44 percent fails to remove the structural deficit.
  - Structural solutions considered: transition to budgetary financing or integration under the civil servants’ regime with differentiated parameters.
- Non-civil servants’ sensitivities:
  - Baseline statutory contribution rate: 8 percent produces a cumulative surplus under current assumptions.
  - Surplus depends on maintaining coverage expansion and contribution recovery; risks could quickly erode surplus.

### Reform Scenarios (Annex Table 1 summary)
- Baseline: Population Growth 0.00; Contribution Rate 17.00; Accrual Rate 2; Reference Salary (months) 6; Minimum Retirement Age (years) 55.
- Package 1: Population Growth 1.00; Contribution Rate 19.00; Accrual Rate 1.75; Reference Salary (months) 36; Minimum Retirement Age (years) 60.
- Package 2: Population Growth 2.00; Contribution Rate 21.00; Accrual Rate 1.5; Reference Salary (months) 36; Minimum Retirement Age (years) 60.
- Package 3: Population Growth 2.00; Contribution Rate 23.00; Accrual Rate 1.33; Reference Salary (months) 60; Minimum Retirement Age (years) 60.

### Policy Recommendations and Implementation Priorities
- Tailored reforms by scheme:
  - Civil servants’ scheme: prioritize a coherent package of parametric reforms—minimum retirement age, wage reference period, accrual rates—applied prospectively and phased to protect social stability and accrued rights.
  - MPs’ scheme: require explicit political decision on financing—options include dedicated funding, integration into another scheme, or specific budget allocation.
  - Non-civil servants’ scheme: strengthen contribution collection and active membership; address payment collection weaknesses in the private sector; reduce arrears (currently nearly KMF 2 billion).
- Formalize and clarify financing and transfers:
  - Formalize budget transfers and establish a clear request mechanism integrated into the Fund’s budget process to stabilize cash flows and predictability.
  - Institute separate and transparent accounting for each scheme to identify financing needs and allow targeted parameter adjustments.
- Governance, administrative, and legal reforms:
  - Strengthen contribution collection, oversight, and compliance mechanisms.
  - Modernize administration and digitize information systems; prepare regular official, audited financial statements for transparency and actuarial monitoring.
  - Revise the legal framework to clarify institutional responsibilities, embed parametric adjustments, and provide a durable framework for financing mechanisms.
- Stakeholder engagement and political commitment:
  - Conduct tripartite dialogue (government, employers, employee representatives) to build consensus and legitimacy for reforms.
  - Secure strong political and institutional commitment to implement technical recommendations and sustain reforms.

### Concluding Remarks
- The civil servants’ scheme drives most medium-term financing requirements; the MPs’ scheme is structurally unsustainable; the non-civil servants’ scheme’s surplus is used to mask wider imbalances and is vulnerable.
- A combination of parametric reforms, institutional strengthening, formalized financing, and political buy-in is required to stabilize CRC and support broader social protection and state modernization objectives.
- Even under ambitious reform packages, some residual financing need remains through at least 2035, underscoring the need for complementary transitional financing and governance improvements.

*Source: sipea2026015 - 17. The CRC’s consolidated financial management masks a system of informal cross-*

### 2026. This paper is also published separately as IMF Country Report No 26/48.

### Pension Reform in Comoros

### Executive Summary
- The CRC (Caisse des Retraites des Comores) is the main public pension system in Comoros and a key component of the formal safety net.
- Mounting financial imbalances threaten the CRC’s ability to meet benefit commitments, with particular vulnerability in the civil servants’ scheme.
- Actuarial analyses (conducted with the ILO) quantify projected financing gaps and identify drivers of imbalance.
- Even under the most comprehensive combination of parametric adjustments, the system is projected to continue requiring some level of transitional financing over the medium term.

### Context
- Social protection coverage in Comoros is limited: only about 3 percent of the population was covered by at least one branch of the social protection system in 2022, excluding health.
- This 3 percent figure is well below the 9.7 percent average for low-income countries (LIC).
- Structural factors constraining coverage include:
  - Predominance of informal employment, estimated at 88 percent of the active population.
  - Regulatory gaps and limited coordination across institutions.
- The CRC provides income support to retirees and their families but faces sustainability challenges exacerbated by demographic trends and weak governance.
- The paper quantifies the CRC’s projected financing gap and examines parametric reform scenarios via actuarial simulations.

### The Pension System’s Structure and Challenges
- The CRC administers three defined-benefit schemes:
  - Civil servants
  - Non-civil servants (including private sector employees and non-civil servant public workers)
  - Members of Parliament (MPs)
- System features:
  - Operates de facto on a pay-as-you-go (PAYG) basis with no accumulated reserves and cross-financing practices.
  - Participation is mandatory for formal sector workers; contributions are shared between employers and employees.
- Key statutory parameters (as presented):
  - Civil Servants: Contribution Rate 17% (12% employer, 5% employee); Statutory Retirement Age 55–65 (category-dependent); Minimum Contribution Period 15 years; Benefit Formula 2% × years of service × last 6 months’ average salary.
  - Non-Civil Servants: Contribution Rate 8% (5% employer, 3% employee); Statutory Retirement Age 55–65 (category-dependent); Minimum Contribution Period 15 years; Benefit Formula 1.33% × years of service × last 6 months’ average salary.
  - Members of Parliament: Contribution Rate 26% (10% employer, 16% employee); Statutory Retirement Age 55; Minimum Contribution Period 5 years; Benefit Formula 5% × years of service × final parliamentary indemnity.
- A common structural weakness: short salary reference period (average of the last six months) inflates pension liabilities relative to the contribution base.
- Demographic deterioration:
  - Civil servants’ scheme demographic ratio fell from 4.1 in 2020 to 2.9 in 2024.
  - System-wide demographic ratio projected to fall from 2.9 in 2024 to 1.6 by 2035.
- Drivers of adverse demographic trend:
  - Stagnant contributory base, constrained by public sector hiring freezes.
  - Low enforcement of mandatory registration and weak compliance among non-civil servants.
  - Rising life expectancy increasing retirement duration.
  - Declining fertility rates increasing demographic dependency.
- Despite these trends, main technical parameters (retirement age, minimum length of service, accrual rate) have remained unchanged.

### Methodology
- Analysis based on a financial sustainability study requested by Comorian authorities; a full report (“Report to the Comoros Pension Fund – Sustainability Study”, ILO, forthcoming) was submitted to authorities.
- Data collection involved targeted CRC requests, field visits, and technical exchanges.
- Significant administrative data gaps required substantial data reconstruction using best-estimated assumptions; supplementary data from the Ministry of Civil Service were used.
- A scheme-by-scheme approach was used before consolidation:
  - Civil servants’ scheme: cohort-based projection using ILO actuarial modelling tool.
  - MPs and non-civil servants: projections based on aggregate assumptions calibrated to recent financial flows.
- Results are indicative estimates; key recommendations include improving data quality (individual member records), conducting external audits of financial statements, and strengthening monitoring of pension indicators.

### Financial Assessment and Outlook
- CRC’s financial position has deteriorated, creating significant liquidity pressures and sustainability risks.
- 2024 system deficit: over KMF 118 million (expenditures exceed ordinary contribution revenues).
- The legal average contribution rate has remained broadly stable while the PAYG required rate rose steadily and surpassed the legal rate in 2022.
  - Since 2022, ordinary contributions no longer suffice to meet annual obligations, causing liquidity shortfalls and pension payment delays.
- Exceptional and temporary supports mobilized to meet obligations:
  - Increase in civil servants’ contribution rate from 14 percent to 17 percent in January 2025.
  - Gradual clearance of government’s past unpaid contribution arrears via monthly transfers of KMF 60 million beginning in 2023, with outstanding payments expected to continue until 2029.
  - Ad-hoc budget support: two large disbursements of KMF 548 million in 2022 and KMF 527 million in 2024 to cover pension payments to civil servants and MPs.
- Without exceptional measures, CRC’s annual deficit would have exceeded KMF 1.3 billion in 2024.
- Scheme-level performance:
  - Non-civil servants’ scheme: generating a surplus.
  - Civil servants’ scheme: deficit of KMF 274 million in 2024 (theoretical figure); without exceptional state support, shortfall would have been over KMF 1.4 billion in 2024.
  - MPs’ scheme: deficit of KMF 69 million in 2024.
- Required PAYG contribution rates (2024):
  - Civil servants’ scheme: nearly 22 percent of salaries versus 14 percent legal rate in effect during the period.
  - MPs’ scheme: required rate exceeded 75 percent versus 26 percent legal rate.

*Source: IMF Selected Issues Paper (SIP/2026/015), “Pension Reform in Comoros”, prepared by Mehdi El-Herradi, Martin Blumhart, Moustapha Diouf, and Jasmina Papa; finalized January 27, 2026.*

### 17. The CRC’s consolidated financial management masks a system of informal cross-

### 17. The CRC’s consolidated financial management masks a system of informal cross-

### Key findings and system-wide outlook
- The Fund’s consolidated accounting conceals informal cross-subsidization: surpluses from the non-civil servants’ scheme are used to partially offset large deficits in the civil servants’ and MPs’ schemes.
- This cross-financing is not legally embedded and prevents the non-civil servants’ scheme from building reserves for its eventual maturity.
- The non-civil servants’ surplus has reached its limit and is no longer sufficient to offset rising deficits in the other schemes; continued reliance on these diminishing surpluses is expected to further exacerbate the CRC’s overall financing gap.
- System-wide projections (baseline, no policy change) show:
  - System nearly balanced in 2025 (due to arrears clearance and non-civil servants’ surplus) but annual deficit expected to exceed KMF 4.8 billion by 2035.
  - Cumulative financing requirement over 2025–2035 projected at over KMF 25.2 billion (excluding interest).
- Arrears are currently estimated at nearly KMF 2 billion.

### Actuarial projections — drivers and scheme-specific results
- Projection horizon: 2025–2035; baseline assumes no policy changes, stable contributor base, rising pensioners.
- Civil servants’ scheme:
  - Contributors-to-pensioners ratio declines from 3.8 in 2025 to 2.2 by 2035.
  - Annual deficit increases from KMF 364 million in 2025 to KMF 4.6 billion by 2035.
  - Cumulative financing needs reach KMF 26.6 billion over 2025–2035.
  - PAYG required contribution rate projected to rise from 22.5 percent in 2025 to nearly 38 percent by 2035 (statutory rate is 17 percent).
- MPs’ scheme:
  - Very limited contributor base—fewer than 35 active MPs depending on the legislature.
  - Annual deficit projected to grow from KMF 86 million in 2025 to nearly KMF 290 million by 2035.
  - By 2035 the MPs’ scheme accounts for less than 6 percent of the CRC’s total projected financing gap but contributes materially to system vulnerability.
- Non-civil servants’ scheme:
  - Currently in surplus under baseline with statutory contribution rate of 8 percent generating a cumulative surplus over the projection horizon.
  - Surplus is fragile: demographic or economic deterioration, slower formal job creation, or declining contribution compliance could rapidly erode it.

### Reform options and quantified impacts (civil servants’ scheme focus)
- Simulations use the ILO-Pension model and scheme-level data; reform impact assessed individually and in combined packages.
- Contribution rate increases (statutory rate scenarios for civil servants):
  - Baseline statutory rate: 17 percent.
  - Raising statutory rate to 23 percent by 2035 lowers cumulative financing need from KMF 26.6 billion to KMF 13.8 billion.
  - Even with higher statutory rates, the PAYG required contribution remains well above statutory rates (reaching 38 percent by 2035 in baseline).
- Accrual rate adjustments (apply prospectively, preserve acquired rights):
  - Current accrual rate: 2 percent.
  - Reducing accrual rate to 1.75 or 1.33 percent (1.33 percent aligns with ILO Convention 102 minimum) yields gradual gains.
  - Lowering accrual to 1.33 percent reduces cumulative financing need from KMF 26.6 billion to KMF 24.9 billion by 2035.
- Salary reference period extension:
  - Current reference period: last six months.
  - Gradually extending to 60 months reduces cumulative financing need by KMF 2.5 billion by 2035.
- Minimum retirement age increase:
  - Baseline minimum retirement age: 55 years.
  - Reform scenario: gradual increase of six months per year starting in 2026 to reach 60 years by 2035.
  - Cumulative financing need declines from KMF 26.6 billion to KMF 25.1 billion by 2035.
- Combined reform packages (assumptions summarized in Annex Table 1):
  - Package 3 (most ambitious): includes, among others, 2-percentage points annual increase in population coverage and accrual rate aligned with ILO minimum.
  - Package 3 reduces cumulative financing need by over 90 percent, from KMF 26.6 billion to KMF 2.5 billion by 2035.
  - Under Package 3, PAYG required contribution rate stabilizes near 28 percent by 2035 (compared with nearly 38 percent in baseline).
  - Even the most ambitious package does not fully eliminate transitional financing needs through 2035.
- MPs’ scheme reform simulations:
  - Baseline statutory contribution rate for MPs: 26 percent.
  - Even increasing to 44 percent fails to remove the structural deficit.
  - Structural solutions considered: transition to budgetary financing or integration under the civil servants’ regime with differentiated parameters.
- Non-civil servants’ scheme sensitivities:
  - Baseline statutory contribution rate: 8 percent produces a cumulative surplus under current assumptions.
  - Surplus depends on maintaining coverage expansion and contribution recovery; risks could quickly erode surplus.

### Reform scenarios summary (from Annex Table 1)
- Baseline: Population Growth 0.00; Contribution Rate 17.00; Accrual Rate 2; Reference Salary (months) 6; Minimum Retirement Age (years) 55.
- Package 1: Population Growth 1.00; Contribution Rate 19.00; Accrual Rate 1.75; Reference Salary (months) 36; Minimum Retirement Age (years) 60.
- Package 2: Population Growth 2.00; Contribution Rate 21.00; Accrual Rate 1.5; Reference Salary (months) 36; Minimum Retirement Age (years) 60.
- Package 3: Population Growth 2.00; Contribution Rate 23.00; Accrual Rate 1.33; Reference Salary (months) 60; Minimum Retirement Age (years) 60.

### Policy recommendations and implementation priorities
- Tailored reforms by scheme:
  - Civil servants’ scheme: prioritize a coherent package of parametric reforms—minimum retirement age, wage reference period, accrual rates—applied prospectively and phased to protect social stability and accrued rights.
  - MPs’ scheme: require explicit political decision on financing—options include dedicated funding, integration into another scheme, or specific budget allocation.
  - Non-civil servants’ scheme: strengthen contribution collection and active membership; address payment collection weaknesses in the private sector; reduce arrears (currently nearly KMF 2 billion).
- Formalize and clarify financing and transfers:
  - Formalize budget transfers and establish a clear request mechanism integrated into the Fund’s budget process to stabilize cash flows and predictability.
  - Institute separate and transparent accounting for each scheme to identify financing needs and allow targeted parameter adjustments.
- Governance, administrative, and legal reforms:
  - Strengthen contribution collection, oversight, and compliance mechanisms.
  - Modernize administration and digitize information systems; prepare regular official, audited financial statements for transparency and actuarial monitoring.
  - Revise the legal framework to clarify institutional responsibilities, embed parametric adjustments, and provide a durable framework for financing mechanisms.
- Stakeholder engagement and political commitment:
  - Conduct tripartite dialogue (government, employers, employee representatives) to build consensus and legitimacy for reforms.
  - Secure strong political and institutional commitment to implement technical recommendations and sustain reforms.

### Concluding remarks
- The civil servants’ scheme drives most medium-term financing requirements; the MPs’ scheme is structurally unsustainable; the non-civil servants’ scheme’s surplus is used to mask wider imbalances and is vulnerable.
- A combination of parametric reforms, institutional strengthening, formalized financing, and political buy-in is required to stabilize the CRC and support broader social protection and state modernization objectives.
- Even under ambitious reform packages, some residual financing need remains through at least 2035, underscoring the need for complementary transitional financing and governance improvements.

*Source: sipea2026015 - 17. The CRC’s consolidated financial management masks a system of informal cross-*

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_Source: https://www.imf.org/-/media/files/publications/selected-issues-papers/2026/english/sipea2026015.pdf_
