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Please note: This article concerns French legislation. The requirements described may not apply in other countries.
The regulatory framework for the professional prevention account (C2P) was recently updated as part of the pension reform. This is a great opportunity for us to review the current regulations!
What is the professional prevention account (C2P)?
The professional prevention account (C2P) is a compensation system for workers exposed to specific occupational risk factors.
The C2P is a digital account where workers can accumulate points. Employers must report their employees' exposure to occupational risk factors to the Primary Health Insurance Fund (CPAM). The CPAM then assigns points to employees based on their level of exposure.
Workers can use their C2P points to access certain benefits, most notably early retirement.
ℹ Note : Since October 1st , 2017, the C2P has replaced the personal prevention of arduous work account created in 2015. The term "arduousness" was removed in 2017, although it is still sometimes used. We now prefer the term "occupational wear and tear."
Which professions and roles are covered by the professional prevention account?
The benefits offered by the professional prevention account apply to specific risk factors (Article L4161-1 of the French Labor Code) related to:
- significant physical demands
Physical demands are present in many fields of activity, but certain professions such as those in construction and public works (BTP), farming, or manual labor are more exposed to them.
- a harsh physical environment
These generally involve jobs exposed to extreme temperatures or high-pressure environments, such as deep-sea divers, scientists, firefighters, foundry workers, welders, and certain construction roles.
- specific work schedules
Positions involving specific work schedules such as night work, shift work, or tasks involving repetitive movements of the upper limbs are considered roles that involve occupational risk factors.
Consequently, jobs involving risk factors from these three categories may potentially entitle exposed employees to accumulate points in their professional prevention account.
However, eligibility for a professional prevention account also depends on the degree of employee exposure. Therefore, only employees exposed to occupational risk factors above the established thresholds are eligible to earn points on their professional prevention accounts (Article L4163-1 of the French Labor Code).
What are the regulatory obligations regarding the professional prevention account (C2P)?
Declaration of employee exposure
Employers must declare employees exposed to occupational risk factors exceeding authorized thresholds each year.
The following table lists the occupational risk factors that qualify for the C2P, along with their exposure thresholds (Article D4163-2 of the Labor Code):
| Occupational risk factors | Exposure threshold | ||
| Action or situation | Minimum intensity | Minimum duration | |
| • a) Activities carried out in a hyperbaric environment | • Interventions or work | • 1,200 hectopascals | • 60 interventions or jobs per year |
| • b) Extreme temperatures | • Temperature of 5°C or below, or 30°C or above | • 900 hours per year | |
| • c) Noise | • Over an 8-hour reference period, at least 81 decibels (A) | • 600 hours per year | |
| • Exposure to a peak sound pressure level ≥ 135 decibels (C) | • 120 times per year | ||
| OCCUPATIONAL RISK FACTOR | THRESHOLD | ||
| Action or situation | Minimum intensity | Minimum duration | |
| • a) Night work under the conditions set out in Articles L. 3122-2 to L. 3122-5 | • One hour of work between midnight and 5am | • 100 nights per year | |
| • b) Alternating shift work | • Alternating shift work involving at least one hour of work between midnight and 5am | • 30 nights per year | |
| • c) Repetitive work involving repeated movements of the upper limbs | • Cycle ≤ 30 seconds: 15 or more technical actions | • 900 hours per year | |
| • Cycle > 30 seconds: 30 or more technical actions per minute | |||
Source: Labor Code, Article D4163-2.
🔎 Focus : Exposure to occupational risk factors is assessed after taking into account the collective and individual protective measures implemented by the employer (Article D4163-5 of the Labor Code).
The declaration is made to the Primary Health Insurance Fund (CPAM) and concerns the following six risk factors (Article L4163-1 of the Labor Code) :
- activities performed in a hyperbaric environment;
- extreme temperatures;
- noise exposure ;
- night work;
- shift work;
- repetitive work.
Since October 1st , 2017, only these six risk factors remain within the C2P and must be declared by the employer. The following four risk factors, which were previously included in the professional prevention account for arduous work, have therefore been "removed" from the C2P:
- manual handling of loads;
- strenuous postures;
- mechanical vibrations;
- exposure to hazardous chemical agents.
Nevertheless, provisions have been made for these four risk factors, in particular the possibility of early retirement under certain conditions.
⚠️ Please note : The employer's declaration must be submitted at the end of each calendar year, no later than the December payroll, or at the time of the final paycheck for contracts ending during the calendar year (Article R4163-8 of the French Labor Code).
To ensure accuracy, the declaration must be based on the standard working conditions for the position in question, assessed as an annual average.
⚠️ Please note : An employee who disagrees with their employer regarding their level of exposure to occupational risk factors may only file a claim with the CPAM if they have first raised this dispute with the employer (Article L4163-18 of the French Labor Code).
Company agreement for the prevention of occupational risk factors
In companies with at least 50 employees, An agreement to prevent the effects of exposure to certain occupational risk factors must be negotiated when at least 25% of the workforce is exposed to such factors or when the accident rate index is greater than 0.25 (Article L4162-1 of the French Labor Code).
🔎 Focus : These agreements are of critical importance for sectors with high exposure to occupational risk factors, such as construction, aeronautics, metallurgy, mining, etc.
The agreement is concluded for a maximum duration of three years (Article L4162-3 of the French Labor Code) and must address at least two of the following topics (Article D4162-3 of the French Labor Code):
- reducing multiple exposures to occupational risk factors;
- adapting and modifying workstations;
- reducing exposure to occupational risk factors.
It must also address at least two of the following topics:
- improving working conditions;
- developing skills and qualifications;
- managing the end of careers;
- retaining employees exposed to risk factors in the workforce.
⚠️ Please note : for affected companies, failure to have such an agreement in place may result in a financial penalty for the employer (Article L4162-4 of the French Labor Code). This penalty is determined by the Regional Directorate for the Economy, Employment, Labor and Solidarity (DREETS) and cannot exceed 1% of the remuneration paid to workers exposed to risk factors (Article R4162-6 of the French Labor Code).
What are the main regulatory changes regarding the professional prevention account?
As part of the government's pension reform, the professional prevention account (C2P) has undergone several changes.
These changes include, in particular, the introduction of the option for employees to use the points accrued in their account to fund a professional career change. This initiative is combined with the funding of professional training and aims to provide access to jobs with lower exposure to risk factors.
Furthermore, two decrees published on August 11, 2023, and applicable since September 1st September 2023 (Decree No. 2023-759 of August 10, 2023 and Decree 2023-760 of August 10, 2023) have established the creation of an investment fund for the prevention of professional wear and tear (FIPU), dedicated to financing initiatives to prevent exposure to ergonomic risk factors (mechanical vibrations, heavy lifting, and strenuous postures).
ℹ Please note : the allocation of FIPU funds and general guidelines will be defined by the occupational accidents and diseases branch (AT-MP). It will also be responsible for "mapping" the relevant professions to better target the sectors involved.
Regarding the remaining changes, these are primarily adjustments to existing regulations:
- removal of the cap on the number of points recorded in the C2P;
- reduction of the exposure threshold for the risk factor related to night work, from 120 to 100 nights per year;
- reduction of the exposure threshold for the risk factor related to work in alternating successive shifts, from 50 to 30 nights per year;
- strengthening of rights acquisition due to multi-exposure to risk factors;
- implementation of a more favorable conversion scale for using C2P points for training and part-time work.
For more details, please feel free to consult the dedicated page on the Ministry of Labor website.
- The occupational prevention account offers benefits to employees exposed to certain occupational risk factors above the regulatory exposure thresholds;
- The employer must declare each year which of their employees are exposed to risk factors above the regulatory thresholds;
- A company agreement to prevent the effects of exposure to certain occupational risk factors must be put in place in companies with at least 50 employees;
- The C2P's regulatory framework recently changed as part of the pension reform.
How does the Professional Prevention Account (C2P) work?
The benefits offered by the Professional Prevention Account can be used in four ways (Article L4163-7 of the Labor Code):
- funding for continuing professional training;
- funding for salary top-ups when transitioning to part-time work;
- funding for early retirement (before the legal age);
- funding for a professional retraining project, including salary coverage during the retraining period.
Regarding the accrual of points on the Professional Prevention Account (C2P), exposure to each risk factor above the regulatory thresholds allows the employee to accumulate four points per year (Article R4163-9 of the Labor Code).
For workers who are not eligible to accrue rights under the Professional Prevention Account, an individual monitoring record detailing the risk factors to which they are exposed must be created by the employer to ensure proper medical follow-up for employees (Article D4163-4 of the Labor Code).
🔎 Focus : employees covered by a special pension scheme that includes specific provisions for recognizing and compensating the effects of exposure to certain occupational risks cannot earn points under the professional prevention account (Article L4163-4 of the French Labor Code).
Furthermore, the use of C2P points is regulated to ensure fair benefits for employees (Article R4163-11 of the French Labor Code):
- for financing training or professional retraining projects, one point is equivalent to 500 euros (compared to 375 euros previously);
- for reducing working hours to part-time, 10 points fund the salary supplement for four months (compared to three months previously);
- for financing early retirement, 10 points entitle the holder to one quarter of additional insurance duration.
In addition, the first 20 points earned are reserved for financing professional training or professional retraining projects (Article R4163-13 of the French Labor Code).
🔎 Focus : Requests to use C2P points for early retirement can only be made from the age of 55 (Article R4163-30 of the French Labor Code).
Conclusion
The professional prevention account (C2P) is designed to provide benefits to employees exposed to occupational risk factors exceeding regulatory thresholds. It is a crucial tool for preventing exposure to occupational risk factors and, consequently, for ensuring the physical and mental health of a company's employees.