Occupational health checks: the obligations employers have

Anyone who hires employees must, depending on the work they do, offer them occupational health checks or even arrange them as mandatory. This applies not only to hazardous substances or noise, but also to ordinary screen workstations in the office.
In brief: The German Ordinance on Occupational Health Care (ArbMedVV) requires employers to arrange mandatory, offered or on-request health checks for employees, depending on the risk assessment. All businesses with relevant activities are affected: for screen work, you must offer at least an optional health check that includes an eye examination. Employers who fail to arrange the checks risk fines.
Who is affected by occupational health checks?
Every employer whose employees carry out activities that require a health check under the ArbMedVV is affected. This ranges from physically demanding or hazardous-substance-related work to classic office work at a screen, for which the ordinance expressly provides for an offered check. The specific classification (mandatory, offered or on-request) does not follow from a blanket rule for an entire industry but from the workplace risk assessment for each job. Small and large businesses are equally bound as soon as a relevant activity exists.
What types of health checks are there and what do you need to do in practice?
The ArbMedVV distinguishes three types of health checks with different degrees of obligation. A mandatory check is a precondition for starting or continuing an activity and must demonstrably have taken place before work begins; without it, the activity may not be carried out. An offered check, for example for screen work, must be actively offered by you, but it is up to the employee whether to take it up. An on-request check must be made possible at the employee's request if damage to health from the work cannot be ruled out.
In practice, this means for your business:
- Derive from the risk assessment which type of check is required for each activity.
- Arrange mandatory checks and actively offer offered checks (e.g. screen work).
- Organize check appointments through the occupational physician.
- Provide an eye examination offer for screen workstations.
- Keep a health check register or records, without recording the physician's diagnostic data.
What role does the occupational physician play?
Occupational health checks are usually carried out by the same occupational physician who also supports the company's occupational safety services. This makes planning easier, because check appointments and the rest of the occupational health care can be coordinated from a single source. The difference between the types of checks remains important, though: a mandatory check is a precondition for the work and must be completed before work begins, whereas for an offered check only the provable offer counts, not whether employees actually take it up.
What applies specifically to screen work?
For employees at screen workstations, at least an offered health check is mandatory, and it expressly includes the offer of an eye examination. This applies regardless of whether there are additional hazards at the workplace: regular screen work alone triggers the duty to offer. Important: the examination must be offered actively and provably, for example through a documented invitation to see the occupational physician; a mere mention in the employment contract or job description is not enough.
By when and how often must checks be carried out?
A mandatory check must have taken place before the relevant activity begins and is then repeated at the intervals set out in the ArbMedVV. An offered check, for example for screen work, should be offered for the first time no later than before the activity starts and then offered again at reasonable intervals, so that the duty to provide evidence remains permanently met. Employers who involve the occupational physician firmly in their occupational safety services can usually plan check appointments and repeat deadlines together with them, rather than organizing individual appointments separately. This way, the checks can be built into existing occupational safety dates instead of being treated as additional administrative effort.
What are the consequences of non-compliance?
If occupational health checks are not arranged, fines may follow. In addition, the employer breaches its duty of care towards employees and takes on a liability risk in the event of harm if a required check demonstrably did not take place. A tool such as Company Audit shows which of these and other obligations apply to your company in practice.
Frequently asked questions
Do I as an employer have to bear the cost of the checks?
Yes, occupational health checks are free of charge for employees. The costs of the examinations, the eye examination and the occupational physician are borne by the employer.
May I as an employer find out the diagnosis from the health check?
No, diagnostic data is covered by medical confidentiality. The health check register only records that and when a check took place or was offered; the medical content stays with the occupational physician.
Is it enough to mention the offered check once in the employment contract?
No, the offer must be made actively and provably, for example through a documented invitation to see the occupational physician. A general mention in the employment contract or in a works agreement is not sufficient.
Who decides which type of check applies to which activity?
That follows from the company's risk assessment in conjunction with the requirements of the ArbMedVV. The occupational physician supports you in classifying the relevant activities.
Do I have to send employees at screen workstations to the examination?
No, for an offered check it is up to the employee whether to take up the offer. As an employer, you are only obliged to offer the check, including the eye examination, actively and provably.
Source: ArbMedVV. This article is general information and does not replace legal advice in individual cases. As of: July 2026.
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