New Employer Obligations on the Occupational Health and Safety Training of Employees
In occupational health and safety law, training is one of the most fundamental preventive obligations of the employer in preventing occupational accidents and diseases. The Regulation on the Procedures and Principles of the Occupational Health and Safety Training of Employees (“Regulation”), published in the Official Gazette No. 33212 of 2 April 2026, repeals the previous regulation dated 15 May 2013 and imposes clearer, measurable and auditable obligations on employers with respect to the timing, method, duration, content, assessment, certification and retention of training. Regulation covers all workplaces within the scope of Occupational Health and Safety Law No. 6331, as well as the persons, institutions and organisations that will provide training to employees at such workplaces. In this information note prepared by our team, the principal innovations introduced by Regulation and the compliance steps to which employers should pay attention are addressed.
- General Framework and Entry into Force
Regulation is based on Articles 16, 17, 18 and 30 of Law No. 6331 and the relevant provisions of Presidential Decree No. 1, and entered into force on its publication date, 2 April 2026. The framework treats the training obligation not as a one-off, formal requirement but as a dynamic and continuous compliance process that takes into account the hazard class of the workplace, its field of activity, the equipment used, the employee profile and evolving risks.
- Start-of-Work Training: A New and Standalone Obligation
One of the most notable innovations is start-of-work training, regulated as an obligation separate from and independent of basic training. Accordingly, all employees, including apprentices and interns, must receive start-of-work training before actually commencing work. This training covers the work to be performed, any work equipment to be used, the risks arising from the working environment and workplace-specific measures, and is delivered in a practical, face-to-face manner. Organised as at least two hours per employee, the time spent in this training does not count towards the basic training period; it is recorded in minutes signed by the trainer, the employee and the employer or its representative and is kept in the employee’s personnel file.
- Basic Training: Duration, Content and Completion Period
The duration of basic training is set according to the hazard class of the workplace: at least eight course hours in low-hazard workplaces, at least twelve in hazardous workplaces and at least sixteen in highly hazardous workplaces. Regulation introduces, for the first time, a definition of a course hour as a sixty-minute period consisting of a forty-five-minute lesson and a fifteen-minute break. Basic training must be completed as soon as possible after the employee commences work and, in any event, within no more than three months. Its content covers, as a minimum, the subject headings set out in Annex-1 and is prepared in line with the participants’ level, the workplace’s field of activity and sector-specific matters.
- The Distinction Between Distance and Face-to-Face Training
While Regulation expressly permits distance training, it requires face-to-face delivery for certain subjects. The first, second and third subject headings of Annex-1 may be delivered in all workplaces by distance, face-to-face or blended methods. By contrast, the fourth subject heading may be delivered by distance or blended methods in low-hazard workplaces but must be delivered face-to-face in hazardous and highly hazardous workplaces. Where training is delivered by distance methods, the employer must ensure that log-in and log-out times, completion rates and assessment results are recorded, monitored and reported; must prevent practices that reduce the efficiency of the training, such as fast-forwarding, tab-switching or window-closing; and must support the employee’s active participation through pop-ups or short questions at defined intervals.
- Measurement, Assessment and the Success Criterion
Regulation requires not only that training be delivered but also that its effectiveness be measured. Employees’ individual levels are determined before basic training, and measurement and assessment are carried out at the end by distance, face-to-face or blended methods. Participants scoring at least sixty out of one hundred are deemed successful. Those who fail the first examination are granted a maximum of two further attempts; employees who also fail these must retake the basic training. Training quality is thereby tied to an outcome-based criterion beyond mere formal attendance.
- Certification, Records and Personnel-File Obligations
For face-to-face basic training, the employer records attendance through participation minutes containing the place and date of the training, the name, surname and signature of the participant and the trainer, the duration and the subject headings. For distance training, system data are relied upon. Employees who successfully complete the training are issued a basic training certificate in line with the template in Annex-2, which is kept in the personnel file. Where the employee so requests upon leaving employment, a signed copy of the certificate is delivered to them. Documents within the scope of Regulation may be signed and archived electronically in accordance with Electronic Signature Law No. 5070.
- Repetition Periods
Basic training is repeated at regular intervals, taking into account changing and newly arising risks: at least once a year in highly hazardous workplaces, at least once every two years in hazardous workplaces and at least once every three years in low-hazard workplaces. Refresher training is organised as a minimum of eight course hours regardless of hazard class. In cases such as a change of workplace or job, a change of work equipment or the application of new technology, additional training must be provided without waiting for these intervals.
- Additional Training for Special Circumstances
Regulation provides for additional training obligations in certain situations. Employees who remain away from work for more than six months for any reason receive refresher training before being returned to work. Employees who have suffered an occupational accident or contracted an occupational disease are provided, before resuming work upon their return, with additional training on the causes of the accident or disease, methods of protection and safe working practices. In addition, training suited to their characteristics must be provided to groups requiring special policy, such as young employees between fifteen and eighteen, elderly, disabled, pregnant or breastfeeding employees, with training for disabled employees delivered in alternative formats compliant with accessibility standards.
- Principal Employer–Subcontractor and Temporary Employment Relationships
In workplaces with a principal employer–subcontractor relationship, each employer is responsible for the training of its own employees. That said, the principal employer is obliged to check the training records of the subcontractor’s employees and to inform those employees about workplace-specific risks before they commence work. In a temporary employment relationship, the employer with whom the temporary relationship is established is responsible for ensuring that the employee receives the necessary occupational health and safety training.
- Other Key Employer Obligations
Regulation also expressly confirms two important principles from the employer’s perspective. First, the cost of occupational health and safety training may not be passed on to employees. Second, time spent in training counts as working time; where such time exceeds the weekly working time, the excess is treated as overtime work or work at additional hours. The employer is further obliged to prepare and approve an annual training programme, having obtained the views of employees or their representatives.
- Transitional Provisions
Regulation deems valid the training and briefings provided under the 2013 regulation it repeals. Basic training certificates issued under the former regime retain their validity throughout the repetition periods set out in the new Regulation. By contrast, training and briefings that were previously provided but could not be certified must be certified within one month of Regulation’s publication date. This provision creates a short-term and priority compliance obligation for employers whose training records are incomplete.
- Assessment and Compliance Steps for Employers
The new Regulation turns occupational health and safety training into an integrated compliance area to be managed jointly by the human resources, occupational safety, operations and legal functions. Employers are advised to integrate start-of-work training into recruitment and onboarding processes, to update annual training programmes and repetition calendars, to align distance-training infrastructure with the technical and record-keeping requirements of Regulation, to establish measurement, assessment and certification processes, and to review personnel-file records. These steps will not only reduce the risk of administrative fines but will also strengthen the employer’s duty of care in terms of civil and criminal liability arising from occupational accidents and diseases.