Company Doctor and Occupational Safety Specialist: Mandatory from the First Employee

Anyone who employs at least one member of staff must, from day one, organise occupational medical care and occupational safety support – regardless of industry or company size.

In short: From the first employee, employers must appoint a company doctor and an occupational safety specialist, as required by the Occupational Safety Act (Arbeitssicherheitsgesetz, ASiG). All businesses with employees are affected; small businesses can use the simplified entrepreneur model for up to 20 employees. If the support is missing entirely, fines of up to 25,000 euros are looming.

Who is affected by the obligation of occupational medical and safety support?

Every employer who employs at least one person is affected – from the one-person business with its first hire to the mid-sized company with several locations. The Occupational Safety Act (ASiG) makes no distinction by industry: whether a craft business, an office service provider or a manufacturing company, as soon as there are employees, support by a company doctor and an occupational safety specialist must be ensured. Alongside the ASiG, which regulates the basic obligation to appoint, DGUV Regulation 2 of the Berufsgenossenschaften (the statutory accident insurance bodies) specifies how this support is to be organised in practice. Company size is then decisive for the concrete arrangement, since it determines whether the classic standard support or the simplified entrepreneur model comes into question.

Standard support or entrepreneur model – which suits your business?

Since 2026, small businesses can choose between two routes: the classic standard support through an appointed company doctor and an appointed occupational safety specialist, or the entrepreneur model, in which the entrepreneur takes on part of the occupational safety tasks themselves after training. The entrepreneur model is open to businesses with up to 20 employees; an alternative needs-based support is also possible for up to 50 employees. Anyone who opts for the entrepreneur model must actually complete the prescribed entrepreneur training – without this training, the support is not organised in compliance with the law, even if an entrepreneur model has formally been chosen. Standard support, in turn, involves more external services, but relieves management and owners of the training obligation.

By when must the support be in place – and how often must it be renewed?

Unlike some other entrepreneurial obligations, there is no one-off deadline here that you tick off once. The obligation arises with the first hire and must be met continuously from that point on – the support must never have gaps or be missing entirely. If the business grows beyond the threshold of 20 or 50 employees, you should check whether the form of support chosen so far is still permissible or whether you must switch to standard support. A change of the inter-company service or the departure of an appointed company doctor also makes a prompt new appointment necessary, so that no gap in support arises.

What do you need to do in concrete terms?

Organising the support follows a clear sequence:

1. Choose the form of support according to company size (standard support or entrepreneur model for up to 20 employees).
2. Appoint the company doctor and the occupational safety specialist via an inter-company service or directly.
3. Under the entrepreneur model, complete the prescribed entrepreneur training.
4. Define basic support and event-driven support by contract.
5. Document the appointment and the support services.

Inter-company services, for example from the competent Berufsgenossenschaft, often bundle the company doctor and the occupational safety specialist into a single contract. This considerably reduces the organisational effort compared with two separate appointments and also makes later documentation easier, because proof of services comes from a single source. Anyone who opts for the entrepreneur model instead saves running costs, but must in return take part in the prescribed training – the time this requires should be firmly planned from the start, so that the support does not remain formally incomplete. The distinction between basic support and event-driven support should be clearly set out by contract: basic support covers the regular, plannable tasks, while event-driven support applies to special events such as conversions, new work processes or repeated accidents.

What is the penalty for a violation?

If occupational medical or safety support is missing entirely or is not properly organised, fines of up to 25,000 euros are looming. This is not a purely theoretical order of magnitude, but can be applied in concrete terms during inspections by the competent authority. A tool such as Company Audit gives an overview of which further obligations apply to your company in occupational health and safety and beyond.

The key points at a glance:

Frequently asked questions

From how many employees do I need a company doctor?

The obligation applies from the first employee. There is no minimum size from which occupational medical and safety support only kicks in.

What is the entrepreneur model?

Under the entrepreneur model, the entrepreneur takes on part of the occupational safety support themselves after prescribed training. It is open to businesses with up to 20 employees; an alternative needs-based support is possible for up to 50 employees.

Can I commission the company doctor and the occupational safety specialist together?

Yes. Inter-company services, for example from the competent Berufsgenossenschaft, often bundle both services into a joint contract instead of appointing them separately.

What do I need to document?

Both the appointment of the company doctor and the occupational safety specialist and the support services provided should be recorded in writing, as should the contractually agreed basic support and event-driven support.

What happens if I do not organise any support?

Without organised occupational medical and safety support, fines of up to 25,000 euros are looming under the provisions of the ASiG and DGUV Regulation 2.

Source: ASiG · DGUV Regulation 2. This article is general information and does not replace legal advice in an individual case. As of: July 2026.