Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

North Macedonia

Labour Inspection Convention, 1947 (No. 81) (Ratification: 1991)
Labour Inspection (Agriculture) Convention, 1969 (No. 129) (Ratification: 1991)

In order to provide a comprehensive view of the issues relating to the application of the ratified Conventions on labour inspection and labour administration, the Committee considers it appropriate to examine Conventions Nos 81 (labour inspection) and129 (labour inspection in agriculture) together.

Article 4 of Convention No. 81 and Article 7 of Convention No. 129. Structure of the labour inspection system. Supervision and control by a central authority. The Government indicates in its report that the Inspection Council continues to ensure oversight and improvement of inspection services by systematically reviewing their plans and reports, offering guidance, issuing relevant opinions, as well as issuing orders for the performance of extraordinary inspections on issues pertaining to labour relations and occupational safety and health (OSH). The Committee once again requests the Government to provide information on the impact of supervision by the Inspection Council on the activities of the State Labour Inspectorate, including the content of the indications and guidelines given by the Council to improve the work of the labour inspection services.

Articles 5(a), 17 and 18 of Convention No. 81 and Articles 13, 22, 23 and 24 of Convention No. 129. Legal proceedings and adequate penalties. Cooperation with the judiciary. The Committee notes the information provided by the Government on the number of violations identified in 2023 and in the first half of 2024, as well as on the penalties imposed in 2023 both for OSH and labour relations, and those imposed in the first half of 2024 only for labour relations. In its previous comments, the Committee noted the Government’s indication that, in 2022, the Inspection Council submitted an instruction to the Ministry of Labour and Social Policy on the need to amend the Labour Relations Law of 2015 to reinforce measures and penalties for labour offences related to the payment of wages and other payments from employment. The Government has not provided information in this respect. At the same time, the Committee notes that section 22 of the Law on Labour Inspection regarding fines imposed on employers for obstructing labour inspectors or unsealing sealed work premises or equipment was amended in 2020. While previously, a flat fine of €4,000 applied uniformly to all employers, under the revised provision, fines are now scaled according to the size of the employer: micro and small employers face fines between €500 and €1,000, medium-sized employers between €1,000 and €2,000, and large employers between €2,000 and €3,000. Regarding the impact of the settlement procedure on the protection of workers’ rights, the Government indicates that this mechanism serves at realizing the preventive activity of the State Labour Inspectorate. The Government indicates that the fact that only 35 offence proceedings were initiated out of 241 issued payment orders in 2023 indicates that most perpetrators accepted the settlement procedure and complied by paying the outstanding fines, before the initiation of criminal proceedings. The Committee requests the Government to indicate how it ensures that sanctions for violations of the legal provisions enforceable by labour inspectors and for obstructing labour inspectors in the performance of their duties are effectively enforced and remain sufficiently dissuasive, including in the context of a possible amendment of the Labour Relations Law of 2015. It also requests the Government to continue to provide statistics on violations and penalties imposed disaggregated by the nature of infringements for both OSH and labour relations.

Article 5(b) of Convention No. 81 and Article 13 of Convention No. 129. Collaboration with employers and workers or their organizations. In its previous comments the Committee noted the Government’s indication that under section 18(1)(19) of the Law on Inspection Supervision, employers’ and workers’ organizations can submit petitions and proposals for inspections to be conducted to protect their rights. Noting the absence of information in this respect, the Committee once again requests the Government to provide information on the number and nature of petitions and proposals for inspection submitted by employers’ or workers’ organizations, as well as any other information regarding how it ensures the collaboration between the labour inspectorate and employers and workers or their organizations, including with regard to activities undertaken by the Council for Occupational Safety and Health and the Economic and Social Council in relation to labour inspection.

Article 6 of Convention No. 81 and Article 8(1) of Convention No. 129. Status and conditions of service of labour inspection staff. In reply to Committee’s previous request the Government indicates that as of June 2024, 123 labour inspectors received a salary increase due to the existence of a high risk to life and health during the performance of tasks, in accordance with section 48(2) of the Law on Inspection Supervision. Regarding the Committee’s previous request on the number of labour inspectors receiving salary increases for good performance under section 51 of the Law on Inspection, the Government indicates that there is no salary increase for inspectors due to good work. Concerning disciplinary procedures, the Government indicates that, in 2023, 8 disciplinary proceedings were initiated, from which 5 were time-barred; 1 was initiated, and 2 were rejected. The Committee requests the Government to clarify whether section 51 of the Law on Inspection Supervision applies to labour inspectors, and if so, to indicate how it is applied in practice, as well as the number of labour inspectors receiving salary increase under this section.

Article 7 of Convention No. 81 and Article 9 of Convention No. 129. Training of labour inspectors and specific training for labour inspectors in agriculture. The Government indicates that the Annual Plans for the individual professional development of state labour inspectors include both generic and specialized trainings. It provides detailed information on the 2023 trainings and indicates that since 2022, an electronic system for managing inspector training (“the LMS platform”) enables the Inspection Council to deliver planned generic trainings to inspectors at both central and local levels, and offer a three-month interactive licensing course for new inspectors. The Committee notes that the implementation of the 2024 Annual Training Plan adopted by the State Labour Inspectorate has been prolonged. With regard to training of labour inspectors in agriculture, the Government indicates that trainings include training on OSH, particularly in the agricultural sector, despite the lack of specific regulations for this industry. In this respect it indicates that the Inspectorate plans to introduce training focused on technical knowledge and skills for labour inspectors in this sector in 2025. The Committee takes note of this information which addresses its previous request.

Articles 10 and 16 of Convention No. 81 and Articles 14 and 21 of Convention No. 129. Resources of the labour inspection system and inspection visits. The Committee takes note of the detailed information on the number of labour inspections conducted in 2023 and in the first half of 2024, including on their nature and focus. In this respect, it notes that the number of labour inspection visits caried out decreased from 24,917 in 2022 to 22,938 in 2023. At the same time the Committee notes that the number of labour inspectors increased from 104 in 2023 to 123 in 2024 and that the budgetary allocation to the State Labour Inspectorate increased from 147.4 million North Macedonian denars in 2023 to 158.5 million denars in 2024, primarily due to higher allocations for salaries and allowances. The Committee also notes the detailed information on the distribution of this budget to expenditures for salaries and allowances, goods and services, and subsidies and transfers. The Government once again has not provided information on the number of workplaces liable to inspection. The Committee requests the Government to provide information on the measures taken to ensure that the number of labour inspectors is sufficient to secure the effective discharge of the duties of the State Labour Inspectorate and to continue to provide information on the number of labour inspectors, the number of labour inspection visits undertaken, as well as the budgetary allocation to the State Labour Inspectorate.

Article 14 of Convention No. 81 and Article 19 of Convention No. 129. Notification of industrial accidents and cases of occupational disease. The Committee notes that the number of reported occupational injuries sharply increased from 798 in 2022 to 2,254 in 2023 and that in the first half of 2024 there were 1,130 occupational injuries reported. The Committee notes once again that the Government did not provide information on the cases of occupational diseases notified to the labour inspectorate. The Committee refers to its comments under the Occupational Safety and Health Convention, 1981 (No. 155), and the Promotional Framework for Occupational Safety and Health Convention, 2006 (No. 187), where it noted the Government’s indication that official data on occupational diseases are insufficient and unreliable. The Committee requests the Government to indicate the reason for the increase of occupational injuries reported. It requests the Government provide information on any measures taken or envisaged to improve the notification of cases of occupational diseases to the labour inspectorate, in accordance with Articles 14 of Convention No. 81 and 19 of Convention No. 129.

Articles 19, 20 and 21 of Convention No. 81 and Articles 19, 25, 26 and 27 of Convention No. 129. Publication, communication and content of annual reports on the work of the labour inspection services. The Committee notes that although annual labour inspection reports are not available, six-monthly reports on the work of the labour inspection services are available on the website of the State Labour Inspectorate until the end of the first semester of 2024. It notes the statistical information contained in these reports for the second half of 2023 and the first half of 2024 as well as in the Government’s report, cover most of the matters enumerated in Article 21 of Convention No. 81 with the exception of statistics of workplaces liable to inspection and the number of workers employed therein (Article 21(c) of Convention No. 81) and statistics of occupational diseases (Article 21(g) of Convention No. 81). At the same time, the Committee notes that the labour inspection reports for the second half of 2023 and the first half of 2024 do not contain breakdown statistics for the agricultural sector as required under Article 27 of Convention No. 129. The only information relevant to agriculture pertains to the number of occupational injuries and fatalities reported. The Committee requests the Government to indicate the measures taken to ensure that the annual labour inspection reports are regularly published and communicated to the ILO, and that they contain information on all the subjects listed in Article 21 of Convention No. 81 and Article 27 of Convention No. 129, including information on statistics of workplaces liable to inspection and the number of workers employed therein (Article 21(c) of Convention No. 81 and Article 27(c) of Convention No. 129) and statistics of occupational diseases (Article 21(g) of Convention No. 81 and Article 27(g) of Convention No. 129).It requests the Government to provide disaggregated data for agriculture in particular.

Issues specifically concerning labour inspection in agriculture

Article 12 of Convention No. 129. Cooperation between the inspection services in agriculture and government services. The Committee notes the Government’s indication that the State Labour Inspectorate and the State Inspectorate for Agriculture have launched jointly coordinated extraordinary inspections targeting legal entities engaged in agriculture, forestry, and fisheries, which were identified based on proposals from the State Inspectorate for Agriculture. These inspections are being carried out by labour inspectors and state phytosanitary inspectors from the respective inspectorates. The Government indicates that as part of this collaboration, additional joint activities, including training sessions and further coordinated inspections, will be organized as needed to strengthen the effective enforcement of legislation in both sectors. The Committee requests the Government to provide information on the number and frequency of joint inspections carried out by the Labour Inspectorate in cooperation with other government services, including the State Inspectorate for Agriculture.

In addition, the Committee recalls the pending comment regarding the Labour Administration Convention, 1978 (No. 150), adopted by the Committee in 2023, for which the Government will be requested to reply in its next report.