
Building a WHP Structure
How do I build a WHP structure that is well organized and meets the prerequisites for a funding conversation with a German statutory health insurer (Krankenkasse)?
Under German law, a WHP along the GKV guideline needs a steering committee (Health Working Group) with a management mandate that brings the key workplace actors together. Without such a body, the health insurer lacks the basis for funding a project under Section 20b SGB V — and a company has no legal entitlement to funding in any case.
Typical Composition of the Steering Committee
| Role on the Steering Committee | Reference | Task in the GKV Process |
|---|---|---|
| Management / Leadership | Section 20b SGB V with the GKV Prevention Guide | Grants the budget and the official project mandate — without a mandate, there is no steering group |
| Employee Representation (Works Council / Staff Council) | Section 87 BetrVG (Co-determination) | Secures co-determination and acceptance among employees |
| Occupational Medicine & Safety Specialist | Section 1 ASiG (Occupational Safety Act) | Links voluntary health promotion with mandatory occupational safety |
Why isn't a lone fighter from HR enough?
Note: this guide refers to German law and the requirements of Germany's statutory health insurers (GKV). Anyone who launches WHP as an HR project without backing from management burns resources in the wrong places and won't get far in the conversation with the health insurer. The GKV Prevention Guideline does not require isolated, uncoordinated effort as a condition for granting subsidies — it requires a permanently installed steering system.
Without a body with a clear mandate, the health insurer lacks the basis for funding a project under Section 20b SGB V. In the conversation with the insurer, what counts is whether the steering committee, coordination and management mandate actually exist — not just on paper.
In concrete terms: as soon as a WHP coordinator has to escalate every decision, the works council isn't involved or occupational medicine is missing, the conversation about project funding becomes difficult. Tax exemption under Section 3 No. 34 EStG (German tax law) depends on something else: ZPP-certified prevention courses or measures within a structured workplace health promotion process with a needs analysis and employee involvement. Only your tax advisor can confirm it.
Phase 1: Why does the management mandate come first?
Phase 1 of the workplace health promotion process under the GKV guideline begins with clarifying the assignment: management issues a written mandate for a structured WHP. This document is not a formality — it is proof to the health insurer that WHP is understood as an organizational task, not a leisure-time offering.
The management mandate must include the following elements: a budget framework (even if it is only refined at the first steering committee meeting), the name of the coordination person, a clear reference to the GKV guideline as the process framework, and the frequency of steering committee meetings (minimum: quarterly).
Practical tip: many companies underestimate how low the barrier is for this first step. A one-page document with management's signature is enough to get started. The effort takes under 30 minutes — the effect is enormous: without this document, every WHP initiative goes in circles.
Phase 2: What is the Health Working Group — and who belongs in it?
The Health Working Group (Arbeitskreis Gesundheit, AK Gesundheit) is the operational core of a GKV-compliant WHP. It is not the same as the occupational safety committee (ASA) — it complements it and has its own dedicated focus on health promotion.
Composition: management or a designated representative, HR leadership, the works council or staff council, the company physician, the occupational safety specialist, and — where available — a workplace health coordinator. Especially in smaller companies, the occupational safety specialist is often appointed externally — the ASiG expressly provides for this (external services, Section 19 ASiG).
The Health Working Group meets at least quarterly. Keep minutes of every meeting: they are the central proof that the body works continuously — and the most important evidence in the conversation with the health insurer about project funding.
Common mistake: the Health Working Group meets once, then takes a year off, and resurfaces only to file a funding application. This gets noticed. Continuity means at least four documented meetings per year.
Which three funding routes exist — and what does the committee contribute?
A functioning steering body is more than ticking a box: it carries the process on which two of three statutory funding routes (German law) build.
Tax allowance — Section 3 No. 34 EStG: employer health benefits are tax-free up to €600 per employee per year, on top of the wages already owed — an allowance, not a subsidy. Eligible are ZPP-certified prevention courses and measures within the workplace health promotion process with a needs analysis and employee involvement; the steering committee documents this process. Only your tax advisor can confirm the tax exemption.
Health insurer funding — Section 20b SGB V: statutory health insurers can support workplace health promotion projects, usually with an agreed project sum — the company has no entitlement to it. No certification is provided for workplace health promotion (the ZPP only reviews prevention courses under Section 20 SGB V); the insurer does, however, expect the measures to follow from a structured process with a needs analysis.
Benefits in kind — Section 8 (2) sentence 11 EStG: benefits in kind of up to €50 per employee per month remain tax-free, for example a corporate fitness contract. This exemption limit does not depend on the steering committee and applies alongside the allowance under Section 3 No. 34 EStG — but the same benefit cannot be made tax-free twice.
Checklist: Is Your WHP Structure Ready for the Conversation with the Health Insurer?
- Management mandate issued in writing and archived
- Health Working Group staffed with the key workplace actors (management, HR, works/staff council, company physician, safety specialist)
- WHP coordination person named
- At least 4 meeting dates per year planned and on the calendar
- Minutes template in place, first minutes archived
- Link to the risk assessment (Section 5 ArbSchG) established
- First health insurer contacted as a cooperation partner
Quick check
What's your company's workplace-health maturity?
Your maturity level shows how far your measures already sit within a structured health promotion process. Under German tax law, such a process is one way for measures to be tax-free up to the allowance of €600 per employee per year (§ 3 No. 34 EStG) — only your tax advisor can confirm this. Answer in about 7 minutes, no sign-up.
Start maturity check (about 7 min.)Related measures & topics
Key takeaways
- Without a management mandate, there is no solid basis for talking to the health insurer. The document takes under 30 minutes.
- The minutes of the steering committee (Health Working Group) are the central evidence for the health insurer.
- Four meetings per year with minutes are a good minimum standard.
- A functioning steering committee carries the workplace health promotion process — the basis for the conversation with the health insurer under Section 20b SGB V and for tax exemption under Section 3 No. 34 EStG (confirmed by your tax advisor). The €50 benefit in kind does not depend on the steering committee.
Frequently asked questions
How many employees must a company have to receive GKV funding?+
There is no statutory minimum company size. Even companies with 10 employees can apply for funding under Section 20b SGB V. For health insurer reports (anonymized health data), however, a minimum number of insured members at one insurer applies, set by each insurer itself — below that, company-specific reports are not possible.
Do all the listed roles need to be on the steering committee, or is a smaller group enough?+
The GKV guideline recommends bringing the key workplace actors together in the steering committee; there is no statutory obligation to staff it with equal representation. In small companies, a smaller group is often enough — but management and an employee representative should be part of it. The smaller the company, the more important it is to actively involve external occupational medicine.
Can the steering committee hold meetings digitally?+
Yes, digital meetings are common — agree this with your health insurer. What matters is the minutes: they must include the date, participants, agenda, and resolutions. A Zoom screenshot without minutes does not count.
What does it cost to build a GKV-compliant WHP structure?+
The pure structure build-up (management mandate, constituting the steering committee, first meeting) involves no direct investment — only staff time. A few working hours are enough for the initial setup. Ongoing costs are limited to the quarterly meetings. The coordination role can be staffed internally — in smaller companies, a small share of one position is often enough.
Check Your WHP Maturity Level
Where does your WHP currently stand — from L1 (statutory minimum) to L4 (excellence)? The free check shows the next step.
Sources
- GKV Prevention Guideline 2025 — chapter on workplace health promotion: steering body, mandate, coordination ↗
- Section 20b SGB V — Workplace Health Promotion ↗
- Section 3 No. 34 EStG — Tax Exemption for Workplace Health Promotion up to €600/Employee/Year ↗
- Section 87 BetrVG — Co-determination on Health Protection (No. 7) ↗
- Section 1 ASiG — Occupational Safety Act: Obligation to Provide a Company Physician and Safety Specialist ↗
Last updated: 2026-06-24. Not legal or tax advice — have your specific case reviewed by a professional.