Documentation & Retention

What must be documented in occupational safety — and how long must records be retained?

Under German law: employers must document risk assessments, training (signed), BEM meetings, occupational physician reports, ASA minutes, and accident reports. Fixed statutory retention periods exist only in a few cases (e.g., first-aid log: 5 years); for much of the rest, recommendations apply — and missing records are a frequent reason for inspection findings.

Retention periods at a glance

Document	Retention period
Risk assessment	no statutory period — the current version must be available at all times (Section 6 ArbSchG); keeping earlier versions is advisable
Training records	no statutory period — recommended: at least 2 years (former DGUV Information 211-005)
BEM files	no statutory period — common recommendation: up to 3 years after completion (standard limitation period, Section 195 BGB), then delete
First-aid log (Verbandbuch)	5 years after the last entry (Section 24(6) DGUV Regulation 1)

Why is documentation the sticking point in inspections?

During an inspection by the trade supervisory authority or the accident insurance carrier (Berufsgenossenschaft), documentation is checked first — not the actual state of the workplaces. A company with exemplary but undocumented occupational safety practices is formally considered non-compliant, because German law places the burden of proof on the employer (Section 6 of the Occupational Safety Act, ArbSchG). This applies especially to the psychosocial risk assessment (GBPsych), one of the most frequently cited deficiencies.

Which records must be available, specifically?

Risk assessments for all workplaces — including home office
Training sessions: date, content, attendee list with signatures
BEM meetings with the employee's written consent
Occupational physician reports and medical checkups
Minutes of the occupational safety committee (ASA, for more than 20 employees, Section 11 ASiG)
Accident reports and the resulting prevention measures

Which documentation mistakes happen most often in practice?

Most compliance findings arise not from a lack of occupational safety measures, but from incomplete records. Four patterns come up again and again in practice.

GBPsych was conducted but never documented in writing
Training sessions took place but without a signature list — unprovable during an inspection
The risk assessment is several years old and was not updated after changes
BEM meetings were held but not recorded in writing — a significant risk in wrongful-termination proceedings

Key takeaways

Inspections check documentation first, not the actual state.
Fixed statutory retention periods exist only in a few cases (first-aid log: 5 years); otherwise recommendations apply.
Missing GBPsych documentation is a frequent gap in practice.
Training without signatures can hardly be proven during an inspection.
Both the BEM offer and the refusal must be documented.

Frequently asked questions

Is digital documentation sufficient, or does everything need to be on paper?+

Digital documentation is permitted and standard practice, as long as it is complete, tamper-proof, and verifiable at all times (traceability) and can be produced during an inspection.

What happens if we try to prove training sessions without signatures?+

Without a signature or an equivalent digital record (e.g., confirmed attendance with a timestamp), the training can hardly be proven during an inspection — even if it actually took place.

Do we also need to document BEM meetings if the employee declines the BEM offer?+

Yes — both the BEM offer itself and the employee's refusal must be documented. Without this record, a later termination on medical grounds is significantly more vulnerable to challenge.

Keep records in one place

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Sources

Last updated: 2026-07-06. Not legal or tax advice — have your specific case reviewed by a professional.

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