What the amendment to the OSH Act introduces and how it will affect your company
In 2026, employers face two major workplace safety changes that should not be underestimated. Both stem from zákon č. 318/2025 Sb., whose provisions are entering into force gradually. This article summarizes verified legislative updates only, without speculation or client statistics. If your company employs even a single worker under an HPP employment contract or a DPP work agreement, the changes directly affect you—and penalties for non-compliance may be substantial.
Electronic injury notification and records from 1 January 2026
The most visible change, taking effect on 1 January 2026, is the requirement to notify an occupational injury and to send the injury record to the competent regional labour inspectorate or the competent district mining authority electronically through the portal of the Státní úřad inspekce práce (SÚIP); this follows from § 4 nařízení vlády č. 322/2025 Sb. The injury log itself is kept by the employer electronically or on paper under § 3 odst. 1 of the same regulation, so a paper injury log remains a fully valid option after 1 January 2026. Any update to an injury record already sent is also submitted through the authority’s portal (§ 9 odst. 1).
What this means in practice:
- Registration and access: Every employer, whether a legal entity or an individual, must arrange access to the SÚIP electronic system. It is best to do this well in advance, avoid the rush in January, and determine who will be responsible for entering the records.
- Deadlines: A serious or fatal occupational injury must be notified by the employer without undue delay (§ 5 odst. 1 nařízení vlády č. 322/2025 Sb.); a serious injury includes, among others, one where hospitalization lasts more than five consecutive calendar days, or where such a period can be expected given the nature of the injury (§ 2 písm. b)). The injury record is sent through the authority’s portal no later than 15 working days from the day the employer learned of the injury, except for an injury that caused no temporary incapacity for work or an incapacity of no more than three calendar days (§ 6 odst. 1 read with § 2 písm. d)). The earlier nařízení vlády č. 201/2010 Sb. required the record for the previous calendar month to be sent by the fifth day of the following month; it was repealed as of 31 December 2025, but duties relating to injuries that occurred before 1 January 2026 continue to be governed by it under the transitional § 10 nařízení vlády č. 322/2025 Sb.
- OSH documentation: This change necessarily affects the company’s internal policies and emergency medical response plan. Injury-reporting procedures must be updated to reflect the electronic process. If you use external OSH services for businesses, consult your provider about updating the documentation in good time.
Zákoník práce (zákon č. 262/2006 Sb., § 105) requires employers to keep injury records in all cases. The amendment č. 318/2025 Sb. itself, however, prescribed no particular format: its part three (čl. IV) merely restated the enabling clause in § 105 odst. 7 of the Labour Code, under which the government sets out by regulation the classification of occupational injuries, the manner and particulars of injury records, the manner and particulars of injury notification, the manner and particulars of sending the injury record, and the bodies and institutions to which an occupational injury is notified and the record sent. The actual rules were laid down only by nařízení vlády č. 322/2025 Sb., effective from 1 January 2026, which repealed nařízení vlády č. 201/2010 Sb. Ignoring the record-keeping duty carries the risk of a penalty which, when combined with other OSH shortcomings, may reach up to CZK 2,000,000.
Construction-site OSH coordinator and OZO—changes from 1 November 2025
Part one of the amendment, already effective from 1 November 2025, clarifies the role and duties of the construction-site OSH coordinator (§ 14 zákona č. 309/2006 Sb.) and the odborně způsobilá osoba (OZO), or professionally qualified person, responsible for risk prevention. For companies acting as project owners or contracting authorities, it introduces several important clarifications:
- Broader range of construction projects: An OSH coordinator must be appointed whenever more than one contractor operates on a construction site, regardless of whether the project requires a building permit or notification. The amendment explicitly confirms this requirement and strengthens oversight.
- Construction-site OSH plan: The documentation must be up to date, signed, and reflect the actual conditions on site. A purely formal plan prepared only for filing away will not withstand an inspection.
- OZO in risk prevention: The odborně způsobilá osoba (formerly referred to as a “safety technician”) must meet the qualification requirements under zákon č. 309/2006 Sb. The amendment emphasizes their responsibility for identifying and assessing risks. If your company does not have its own qualified employee, outsourcing OSH services is a practical solution.
The indicative cost of outsourced OSH services on a monthly retainer starts at CZK 1,500, depending on the number of employees and the nature of the operation. An exact price can only be determined after assessing the specific scope of work—use our no-obligation enquiry to request an assessment.
Impact on OSH and fire safety documentation
Every legislative change must be reflected in company documentation. In the case of novela 318/2025 Sb., this applies primarily to the following documents:
- Emergency medical response plan and injury-reporting policy: Update the procedure so that it matches electronic injury notification and the sending of the injury record through the SÚIP portal.
- Risk assessment and work categorization: If work activities or conditions have changed, the categorization must be reassessed under zákon č. 258/2000 Sb. and reflected in the risk register.
- Fire safety documentation: The OSH amendment affects fire safety only indirectly, but updating internal policies is also a good opportunity to check compliance with zákon č. 133/1985 Sb. and vyhláška č. 246/2001 Sb.—particularly the classification by fire-hazard category, training intervals for managers (once every three years), and professional training for preventive fire patrols.
Practical advice: if you already work with an external OSH and fire safety provider, ask them to review your documentation with the 2026 requirements in mind. If not, now is the time to address the situation.
What to prepare for during an inspection in 2026
During inspections in 2026, labour inspectorates and fire and rescue services will focus primarily on:
- Working access to the SÚIP system and the presence of records, even if no injuries have been recorded.
- Updated OSH documentation reflecting novela 318/2025 Sb.
- Valid professional qualification certificates—for electrical inspections, for example, an inspection technician’s certificate under § 11 odst. 3 zákona č. 250/2021 Sb. is valid for five years. A certificate of a passed examination of electrotechnical competence is valid for three years under § 19 odst. 2 písm. b) zákona č. 250/2021 Sb.; it is sometimes mistakenly claimed that this period ceased to exist when vyhláška č. 50/1978 Sb. was repealed. If your company operates designated electrical equipment, remember to arrange electrical installation inspections within the statutory intervals specified by NV č. 190/2022 Sb. and the applicable ČSN.
Summary and recommended steps
The changes are not revolutionary, but they require timely preparation. We recommend that you:
- Arrange access to the SÚIP electronic system before the end of 2025.
- Review and update your emergency medical response plan and OSH policies.
- Verify the validity of professional certificates held by inspection technicians, OZO professionals, and fire prevention personnel.
- For construction projects, check that the OSH coordinator has been appointed in accordance with the amendment.
Are you looking for a partner to handle your OSH, fire safety, and electrical inspection requirements? Get in touch—we will take care of the work as if we were doing it for ourselves. Email info@sohe.cz, call +420 724 689 762, or submit a no-obligation enquiry.