DGUV Regulation 2 in Germany: support by company doctors and occupational safety specialists
Every employer in Germany must arrange support from a company doctor and an occupational safety specialist. Which support model applies, how many hours are needed, what the revised DGUV Regulation 2 changes and since when it applies.
Last updated on 7 min readAMS Go editorial team
Key points at a glance
- DGUV Regulation 2 (DGUV Vorschrift 2) specifies the Occupational Safety Act (ASiG): every employer must appoint company doctors and occupational safety specialists in writing, and the regulation sets out in what form and to what extent they support the company.
- Each accident insurance institution puts the revision based on the DGUV model text of November 2024 into force itself – the BGHM on 1 April 2025, the VBG on 1 December 2025, the BGN on 1 January 2026 and the BGW on 1 June 2026.
- Companies with up to 20 employees (previously 10) receive standard support without fixed service hours; above that, basic support of 2.5, 1.5 or 0.5 hours per employee per year applies depending on the support group, plus company-specific support.
- The company doctor and the safety specialist each cover at least 20 per cent of basic support, as a rule no more than one third of support may be provided digitally, and in their regular reports both must now prove their continuing training.
What does DGUV Regulation 2 cover?
DGUV Regulation 2 “Company doctors and occupational safety specialists” is the accident prevention regulation that specifies the Occupational Safety Act (Arbeitssicherheitsgesetz, ASiG). It sets out in what form and to what extent company doctors and occupational safety specialists must support a company – from standard support with fixed service hours to alternative models for small companies.
The basic duty is laid down in the ASiG: the employer must appoint company doctors and occupational safety specialists in writing (Sections 2 and 5) and assign them the tasks under Sections 3 and 6 – advising, inspecting the premises, contributing to the risk assessment and investigating accidents and work-related illnesses. Instead of employing their own experts, employers can engage an external service (Section 19 ASiG).
The revision: since when it applies and what changes
In November 2024, the DGUV general assembly adopted a new model text that replaces the previous version of 2011 or 2012. Each accident insurance institution puts it into force itself: the BGHM went first on 1 April 2025, followed among others by the VBG on 1 December 2025, the BGN on 1 January 2026 and the BGW on 1 June 2026. As long as your institution has not put the revision into force, the previous version applies to you.
Standard support without fixed service hours
Previous versionup to 10 employees
Revised versionup to 20 employees
Basic support with fixed service hours
Previous versionmore than 10 employees
Revised versionmore than 20 employees
Minimum share per discipline
Previous version20 per cent of basic support, at least 0.2 hours per employee per year
Revised version20 per cent of basic support, no lower limit in hours
Digital support
Previous versionno specific rule
Revised versionas a rule up to one third, provided the company doctor or safety specialist has got to know the company on site first
Report
Previous versionregularly in writing on how the tasks were performed
Revised versionelectronically or in writing, additionally with proof of continuing training
Access to the role of occupational safety specialist
Previous versionengineers, technicians and master craftspeople
Revised versionadditionally graduates in fields such as chemistry, physics, biology, ergonomics or work and organisational psychology
Which support model applies to your company?
What matters is the annual average number of employees. Part-time staff count proportionally: up to 20 hours a week as 0.5, up to 30 hours as 0.75, above that in full. A company with 16 full-time employees and 8 part-time employees working 15 hours a week each thus counts 20 employees and, under the revised version, still falls under support for small companies.
up to 20 employees
Standard supportAnnex 1: support with the risk assessment at fixed intervals and occasion-related support, without fixed service hours
Alternative, if offered by the institutionCompetence centre model (Annex 4): the employer is trained and receives support from a competence centre as needed
more than 20 up to 50 employees
Standard supportAnnex 2: basic support with fixed service hours and company-specific support
Alternative, if offered by the institutionAlternative needs-based support (“employer model”, Annex 3)
more than 50 employees
Standard supportAnnex 2: basic support with fixed service hours and company-specific support
Alternative, if offered by the institutionnone
In support for small companies under Annex 1, the company doctor and safety specialist help to prepare and update the risk assessment. Depending on the support group, this support is repeated after one, three or five years at the latest – and also when working conditions change significantly. In addition, the employer checks on certain occasions whether the company doctor or safety specialist must be called in: for example for new installations, work processes or hazardous substances with increased hazard potential, when employing pregnant women or young people, after accidents or when health problems accumulate.
OHS committee minutes in AMS GoPrepare and record occupational safety committee meetings with the company doctor and occupational safety specialist, turn decisions into actions in the action plan and find all minutes in the archive.Service hours with more than 20 employees
With more than 20 employees, standard support consists of basic support and a company-specific part (Annex 2). Basic support has fixed service hours per employee per year: 2.5 hours in support group I, 1.5 hours in group II and 0.5 hours in group III – for the company doctor and safety specialist together. The group depends on the company's economic sector; the assignment was revised with the new version, so it is worth checking your institution's annex.
Support group I
Basic support per year100 hours
Minimum share per discipline (revised)20 hours
Minimum share per discipline (previous)20 hours
Support group II
Basic support per year60 hours
Minimum share per discipline (revised)12 hours
Minimum share per discipline (previous)12 hours
Support group III
Basic support per year20 hours
Minimum share per discipline (revised)4 hours
Minimum share per discipline (previous)8 hours
The minimum shares ensure that both disciplines actually work in the company; the employer allocates the rest according to need across the task areas – with the involvement of the works council. Travel time does not count as service time. Occupational health checks are not counted towards basic support but belong to the company-specific part.
The employer determines the scope of the company-specific part themselves, advised by the company doctor and safety specialist, and reviews it regularly. Triggers include particular hazards, new machines, alterations or processes, new regulations, occupational health checks under the ArbMedVV or health programmes. There is no fixed formula; the result is agreed with both in writing or electronically.
Appointment, agreement and report: the records you need
During an inspection by the employers' liability insurance association or the labour inspectorate, what counts is what is documented. The following records should be available in the company:
- written appointment of the company doctor and occupational safety specialist or the contract with the external service
- the agreement on tasks and service hours of basic support and the company-specific part
- regular reports by the company doctor and safety specialist on how they performed their tasks, their cooperation and their continuing training (Section 5 of DGUV Regulation 2)
- the documented risk assessment with measures and effectiveness checks
- in the employer model or competence centre model, the certificates of attendance for the training
- information for employees on who provides their occupational health and safety support
Choosing external support
Most small and medium-sized companies use external support – from freelance safety specialists and company doctors or an external service. These questions help with the choice:
- Expertise: does the company doctor hold the specialist title in occupational medicine (Arbeitsmedizin) or the additional title in company medicine (Betriebsmedizin)? Has the safety specialist completed the qualification course including the sector-specific part?
- Sector experience: does the service know companies like yours and their typical hazards?
- Service description: are service hours per task area, inspections and reports agreed specifically instead of a flat quota of hours?
- Digital shares: is it agreed which services are provided online and how on-site presence is ensured?
- Cooperation: do the company doctor and safety specialist work together, for example on joint inspections (Section 10 ASiG)?
Checklist: support under DGUV Regulation 2
- Responsible accident insurance institution and applicable version of DGUV Regulation 2 checked
- Annual average number of employees counted, with part-time staff counted proportionally
- Support group determined based on the economic sector
- Support model chosen: standard support or the institution's alternative model
- Company doctor and safety specialist appointed in writing or external service engaged, works council involved
- Basic support and company-specific part agreed with service hours
- Existing contracts adapted to the revision, proof of continuing training agreed
- Reports available and discussed in the occupational safety committee
Frequently asked questions
When does the new DGUV Regulation 2 apply?
That depends on the accident insurance institution. The BGHM put the revision into force on 1 April 2025, the VBG on 1 December 2025, the BGN on 1 January 2026 and the BGW on 1 June 2026. Your employers' liability insurance association or accident insurance fund will tell you which version applies to your company.
Does a small company need a company doctor and an occupational safety specialist?
Yes, the duty applies from the first employee. Under the revised version, however, companies with up to 20 employees have no fixed service hours: the company doctor and safety specialist support the risk assessment and help on specific occasions. Some institutions also offer a model in which the employer gets trained themselves.
How many hours of support does a company with 50 employees need?
Under standard support, basic support amounts to 125 hours per year in support group I, 75 hours in group II and 25 hours in group III – for the company doctor and safety specialist together, each with a share of at least 20 per cent. Company-specific support comes on top; the company determines its scope itself.
Does the occupational safety specialist have to write a report?
Yes. The employer must oblige the company doctor and safety specialist to report regularly, electronically or in writing, on how they performed their tasks and on their cooperation (Section 5 of DGUV Regulation 2). Under the revised version, the report must also include proof of their continuing training.
Terms from the glossary
This guide gives a general overview of German occupational safety law and does not replace legal advice. The regulations in force and the rules of the statutory accident insurance institutions are authoritative.
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