Health and safety in the Czech branch of a foreign company: what the inspectorate wants here and how to report it to the parent

The group questionnaire arrives on Friday afternoon, and the second item already has nowhere to land in the Czech system: Bitte benennen Sie Ihre Fachkraft für Arbeitssicherheit und fügen Sie die Bestellurkunde bei. The branch has fourteen people, an office, a small warehouse and one forklift. Nobody here ever issued a Bestellurkunde — Czech law does not recognise such a document. And the form is due on Monday.

From here two bad roads lead onwards. The first: the branch orders a retainer it does not understand, just to have something to attach. The second: it writes “N/A – not applicable under Czech law” in the field, the auditor reads that as an unfilled role, and the matter goes up a level. Yet the Czech system does have a counterpart. It goes by a different name, hangs on a different section of the law, and in one single item it has nothing in common with the German template. Let us go through what the labour inspectorate wants from the branch, what the parent wants, where the two demands overlap, and how to turn all of it into one binder and one page of the report.

Two different readers of the same binder

The oblastní inspektorát práce (regional labour inspectorate) reads the records against Czech law — the zákoník práce (Labour Code), zákon č. 309/2006 Sb. and the rules on operating equipment. The scope of an inspection is set out in § 3 zákona č. 251/2005 Sb., o inspekci práce (the Labour Inspection Act). The group auditor reads the same records against an internal standard derived from ArbSchG, ASiG and the DGUV rules.

The overlap is large: risk assessment, training, health checks, equipment records, accidents. What diverges is the naming, the way deadlines are structured, and two or three items that exist in one jurisdiction and not in the other.

One thing is worth saying out loud right away. The report to the group is not an obligation under Czech law — it is a matter of contract and internal corporate governance. From that follows a rule that cuts both ways: the parent’s standard does not create a Czech obligation, and at the same time the Czech minimum is not an argument you can use to brush off the auditor. The binder is kept for the inspectorate, the report for the parent, and the paperwork is largely shared.

The “Fachkraft” in Czech: OZO, the certificate and the 25-employee threshold

The German Fachkraft für Arbeitssicherheit is appointed by name. The Czech counterpart is the qualified risk-prevention professional — the odborně způsobilá osoba (OZO) under § 9 zákona č. 309/2006 Sb.

That section has a tiering that branches routinely overlook. Under § 9 odst. 3, an employer with no more than 25 employees may handle risk-prevention tasks personally, provided they have the necessary knowledge. With 26 to 500 employees, personally if they hold the qualification, or through one or more qualified persons. Above 500 employees, the law assumes a qualified person in every case.

So a fourteen-person branch cannot derive an obligation to have a contracted OZO from that section. Anyone claiming otherwise is selling something. The catch lies in the words “necessary knowledge” — that is not a formality, and a branch manager who has never dealt with Czech health and safety usually does not have it. And a group audit is a legitimate reason to have an OZO even where the law does not require one, because otherwise there is nowhere to get a name for the questionnaire. It is only honest to say that the reason is corporate, not statutory. What such coverage costs and what tends to hide inside flat-rate packages is covered in our article on the price of an external OZO.

That leaves the Bestellurkunde. Under § 10 zákona č. 309/2006 Sb., the qualification is evidenced by a certificate and the examination is repeated every five years — so the certificate carries both the holder’s identification and a validity period. What goes into the report is the name, the certificate number and the expiry date. Nothing prevents you from issuing a one-page written appointment alongside it that refers to the certificate: Czech law does not prescribe such a document, but neither does it rule one out, and it fills a box for the auditor that would otherwise stay empty.

Translation table: what fills what

The item the German auditor has never heard of: job categorisation

The last row of the table is the source of most misunderstandings — and it is confusing even internally, because the route to classification is not the same for every category. Under § 37 zákona č. 258/2000 Sb., o ochraně veřejného zdraví (the Public Health Protection Act), work is classified into four categories. Work falling into category two is classified by the employer itself, within 30 calendar days from the day the work begins; the employer must then notify the classification without delay to the competent public health authority, i.e. the krajská hygienická stanice (regional public health authority). Classification into category three or four, by contrast, is decided by the hygienická stanice — within the same thirty-day period from the start of the work, the employer submits an application and waits for the decision. Work not classified into category two, three or four falls into category one; that is neither notified nor decided upon.

The difference between a notification and an application is not a formal detail. For category two, the branch keeps its own notification with the date it was sent; for categories three and four it must also hold the authority’s decision — and that usually arrives later than the thirtieth day.

This single step is what the answer hangs on to a question the group auditor will certainly ask: why the Czech branch does not put its administrative staff through periodic medical examinations at the rhythm they are used to in Germany. In the Czech Republic the occupational health services regime is tied precisely to the work category and to the risks of the specific role. The obligation to have a written contract with an occupational health service provider is governed by § 54 zákona č. 373/2011 Sb.; for an employer whose work all falls into category one with no special fitness requirements, the regime is lighter and examinations may be carried out by the employee’s own registering doctor. The details are set out in vyhláška č. 79/2013 Sb.; its wording has changed since 2023, so an internal procedure written earlier may not match the current version.

What belongs in the report is therefore not an empty box but a single sentence reflecting what the branch actually has: either that all work falls into category one, or the category number and the notification date for category two, or the date the application was filed and the date of the hygienická stanice’s decision for categories three and four — plus a reference to § 37 zákona č. 258/2000 Sb. That ends the discussion.

Electrical installations and lightning protection: same equipment, different logic of intervals

Before comparing intervals, one sentence is needed on where the obligation actually sits. It is not in a ČSN: under § 4 odst. 1 zákona č. 22/1997 Sb., a Czech technical standard is not generally binding. The duty to maintain, check and inspect equipment follows from § 4 zákona č. 309/2006 Sb., and for designated electrical equipment additionally from zákon č. 250/2021 Sb. and nařízení vlády č. 190/2022 Sb. (a government regulation). In § 3 odst. 1 the latter defines what counts as designated equipment — among other things, electrical installations of buildings and technologies, and equipment protecting against atmospheric and static electricity, i.e. lightning protection too — and in § 7 odst. 5 písm. d) it ties the intervals of periodic inspections to its příloha č. 4. The standard is then an accepted way of evidencing compliance, not its source. So both belong in the group table: the section of law as the legal basis, and the standard as the method.

At the same time, the two worlds cannot be thrown into one box. Hand-held electromechanical tools and appliances up to 400 V without a fixed connection, along with extension and detachable leads, are expressly excluded from designated equipment by nařízení vlády č. 190/2022 Sb. in § 3 odst. 2 písm. a) a b). Their checks and inspections are therefore not governed by příloha č. 4 but by the general duty under § 4 zákona č. 309/2006 Sb., the manufacturer’s documentation and the risk assessment; the procedure and the intervals are described in ČSN 33 1600 ed. 2. The fixed installation and the lightning protection run on one regime, the laptop charger and the extension lead on another.

For portable electrical equipment, the German rules work with an indicative interval and allow it to be extended where checks consistently reveal no faults; on construction sites, conversely, the interval is shorter. ČSN 33 1600 ed. 2 builds the interval differently — by the group the appliance falls into based on how and where it is used (from appliances hired out, through construction sites and industry, to office use), and by whether it is hand-held, portable or fixed. The very same extension lead therefore has one interval in the office and another in the warehouse, where it gets dragged across the floor.

The most expensive mistake in the report is promising a German interval. Write “every 6 months” into the group system after DGUV Vorschrift 3 and you have manufactured a non-conformity for the next audit — not against Czech law, but against your own declared standard. What belongs in the box is the Czech interval and a line saying what it follows from.

For lightning protection the technical mapping is easier: the German Blitzschutzprüfung under DIN EN 62305 and the Czech inspection under the ČSN EN 62305 series both derive from the same European standard and differ mainly in how they tie to the protection class and the building documentation. The interval for periodic inspection here, however, does not follow from the standard — lightning protection is designated equipment and the interval is taken from příloha č. 4 nařízení vlády č. 190/2022 Sb.

The practical difficulty usually lies elsewhere than in the standards: nobody in the branch knows how many appliances there actually are. If you do not feel up to compiling the inventory yourselves, our appliance and tool inspections end with an item-by-item list — protection class, interval, date and result — not with a single stamped page. Such a list can be pasted into the group table unchanged; just send a no-obligation enquiry and we will go through what the branch actually has.

What lands on the table first during an inspection

In practice the inspector asks for the records that a branch usually has scattered across three drives and two heads:

• Documentation on the identification and assessment of risks and on the measures adopted under § 102 zákoníku práce — not a translation of the group Gefährdungsbeurteilung, but an assessment of the actual operation in the Czech Republic, including the forklift and the warehouse.
• Training records, with content, frequency and verification of knowledge. Under § 103 odst. 3 zákoníku práce it is the employer who sets the content and frequency — it is the employer’s own decision, which is then evidenced, not a standard imposed from outside.
• The accident book and accident records under § 105 zákoníku práce. Since 1 January 2026 the method of recording, reporting and submitting the record has been governed by nařízení vlády č. 322/2025 Sb., o povinnostech zaměstnavatele při pracovních úrazech, which replaced the earlier nařízení vlády č. 201/2010 Sb. Under its § 6, the accident record is submitted through the authority’s portal within 15 working days. An internal procedure written under the old rules is therefore out of date — it needs rewriting, not just a check of the deadlines.
• The minutes of the annual health and safety review under § 108 odst. 5 zákoníku práce — at least once a year, at all workplaces, with a list of shortcomings and how they are being remedied. What belongs in those minutes is covered in our article on the annual health and safety review.
• The list of personal protective equipment (OOPP) and records of its issue under § 104 zákoníku práce and nařízení vlády č. 390/2021 Sb.
• Equipment records — inspection reports, their intervals, and the qualification of whoever issued them.

The upper limit of the fine for offences in the field of occupational safety under § 30 zákona č. 251/2005 Sb. reaches, for some offences, as high as CZK 2,000,000. That is a ceiling, not a usual rate — the actual amount is decided by the administrative authority according to the circumstances of the case. We write in more detail about how an inspection proceeds in our piece on a labour inspectorate inspection.

Fire protection: a second authority, a second logic

The group standard usually mixes occupational safety and fire protection into a single “HSE” block. In the Czech Republic these are two separate lines and two separate authorities: the labour inspection and the Hasičský záchranný sbor (HZS, the fire and rescue service).

The scope of the duties follows from the category of the activities operated under § 4 zákona č. 133/1985 Sb. — without heightened fire risk, with heightened risk, with high risk. From that follows the scope of the fire protection documentation under vyhláška č. 246/2001 Sb., and whether a preventive fire watch is established under § 13 zákona č. 133/1985 Sb. The German Brandschutzhelfer under ASR A2.2 is therefore only a partial counterpart: it is a different construction, tied to a different trigger. What belongs in the report is the category of activity and the list of documents that follow from it; we have set out the specifics in our article on fire protection documentation.

The one page you send to the group

The report can be handled on a single page, provided it has these lines and a date against each:

• The OZO’s name, certificate number and its validity — that fills the “benannte Fachkraft” box.
• The date of the last risk assessment and the date it was last updated after a change in operations.
• The training matrix: who, what, when, at what frequency — plus a note that the frequency is set by the employer under § 103 odst. 3 zákoníku práce.
• The number of entries in the accident book and the number of accident records involving incapacity for work. That converts into the group indicators without any recalculation.
• The date of the annual review and the status of the shortcomings identified.
• The equipment inventory with the interval, the date of the last inspection, and the name and certificate number of the inspection technician.
• The work category — and, depending on what the branch has: a statement that all work falls into category one, the notification date for category two, or the application date and the date of the hygienická stanice’s decision for categories three and four.
• The occupational health services contract, or a sentence explaining why the regime differs for category one.

And what not to put there: a translation of Czech standards into German ones as if they were the same thing, and intervals taken over from the group standard that you do not keep in the Czech Republic. The first leads to arguments, the second to a non-conformity you have created for yourselves.

When to walk away from the table

Offers of “comprehensive health and safety outsourcing” for a branch have several recurring flaws:

• A tie-in contract with a penalty for training not taken. Training is there to cover the real needs of the workplace, not to fulfil a purchase commitment. A penalty for declining a date is a reason to end the negotiation.
• A flat fee with “inspections included” and no item count and no intervals. Without an equipment inventory nobody knows what is being ordered — and the audit is where it emerges what the price did not cover.
• The claim that the law requires a contracted OZO even for a branch of twelve people. It does not, see § 9 odst. 3 zákona č. 309/2006 Sb. The reason may be a corporate one, and that is a legitimate reason — it just should not be passed off as a statutory one.
• A promise that you will pass the group audit. No supplier can influence the auditor’s verdict. The only thing that can be influenced is whether the records exist, match Czech law and can be translated.

Sources this article draws on

• Appliance and tool inspections – a SOHE service.
• Workplace risk assessment – how to prepare the documentation that both the inspector and the group auditor will ask for.
• Health and safety training for employees – who sets the content and frequency, and what has to stay on paper.
• Health and safety and fire protection legislative updates 2026 – an overview of the changes that have affected the rules mentioned above in recent months.
• Zákon č. 262/2006 Sb. – zákoník práce (Labour Code); § 102 risks, § 103 training, § 104 personal protective equipment, § 105 accidents, § 108 odst. 5 annual review.
• Zákon č. 309/2006 Sb. – further health and safety conditions; § 4 requirements for the operation and checking of machinery and technical equipment, § 9 provision of risk-prevention tasks, § 10 professional qualification.
• Zákon č. 251/2005 Sb. – on labour inspection; § 3 scope of inspection, § 30 offences in the field of occupational safety.
• Zákon č. 258/2000 Sb. – on public health protection; § 37 job categorisation, notification of work classified into category two and application for classification into categories three and four.
• Zákon č. 373/2011 Sb. – on specific health services; § 54 contract on occupational health services.
• Vyhláška č. 79/2013 Sb. – scope and content of occupational medical examinations.
• Nařízení vlády č. 322/2025 Sb. – on the employer’s duties in the event of occupational accidents; effective from 1 January 2026, repealed nařízení vlády č. 201/2010 Sb.; § 6 submission of the accident record through the authority’s portal.
• Nařízení vlády č. 390/2021 Sb. – provision of personal protective equipment.
• Zákon č. 250/2021 Sb. – occupational safety in relation to designated technical equipment; qualification of inspection technicians.
• Nařízení vlády č. 190/2022 Sb. – designated technical electrical equipment; § 3 odst. 1 definition including protection against atmospheric electricity, § 3 odst. 2 exemptions (hand-held tools, appliances up to 400 V without a fixed connection, extension leads), § 7 odst. 5 písm. d) and příloha č. 4 intervals of periodic inspections.
• Nařízení vlády č. 194/2022 Sb. – requirements for the qualification to work on electrical equipment.
• Zákon č. 22/1997 Sb. – § 4 odst. 1: a Czech technical standard is not generally binding.
• Zákon č. 133/1985 Sb. – on fire protection; § 4 categories of activities, § 13 preventive fire watches.
• Vyhláška č. 246/2001 Sb. – on fire prevention; scope of fire protection documentation.

This text is for information only and does not replace legal advice. The specific health and safety regime, intervals and records in a given branch need to be set according to the actual operation, the manufacturer’s documentation, the environment of use and the risk assessment.

Do you need someone to walk through your branch and leave you with records that stand up both to the inspectorate and to the group report? Get in touch at info@sohe.cz or send a no-obligation enquiry — we leave the site visit with an inventory of equipment and intervals, which feeds straight into appliance and tool inspections. We will also tell you outright what you do not need to order.