A new German office can look straightforward on paper: desks, laptops and a small team. Then an accident insurance institution (Berufsgenossenschaft, or BG) asks who your company doctor is, and whether occupational health support has been arranged. For many international employers, the company doctor requirement is the point at which Germany’s health and safety system becomes very real.
The good news is that this is a manageable duty when you treat it as part of your wider workplace safety structure, rather than as a one-off medical appointment. The right support protects your people, gives managers practical advice and creates the evidence you may need during an inspection.
Is a company doctor required in Germany?
In most cases, yes. Employers in Germany must appoint a company doctor (Betriebsarzt) and an occupational safety specialist (Fachkraft für Arbeitssicherheit, or SiFa). This duty comes from the German Act on Company Doctors, Safety Engineers and Other Occupational Safety Specialists (ASiG), with the practical scale of support set out in DGUV V2.
This does not mean every business needs a doctor on site each day, or that every employee must have a routine medical examination. The requirement is for suitable occupational medical advice and support that matches your workplace, workforce and hazards. An external appointment is common, particularly for start-ups, small and medium-sized businesses, or companies entering the German market.
The time and type of support depend on several factors. Your sector, employee numbers, accident risks, work equipment, shift patterns, hazardous substances and previous incidents all matter. A low-risk professional services office will normally need a different level of support from a warehouse with forklift traffic, manual handling and racking.
Your applicable accident insurance institution also influences the DGUV V2 model and the expected basic and workplace-specific support. That is why copying a solution from a business in another sector can leave important gaps.
What the company doctor actually does
A company doctor is not there to replace an employee’s GP or to diagnose general illness for the employer. Their role is occupational health: helping you identify, prevent and manage health risks arising from work.
They advise on the health aspects of your risk assessment (Gefährdungsbeurteilung), workplace design, working time, screen-based work, ergonomics, protective equipment and the safe use of substances. In higher-risk settings, they may also advise on noise, respiratory protection, biological agents, night work, manual handling and emergency arrangements.
The doctor can help you decide where occupational medical precaution is required under ArbMedVV. Depending on the exposure, this may be mandatory, offered by the employer, or requested by an employee. For example, specific precautions may be needed where staff use respiratory protective equipment, work with certain hazardous substances or carry out night work.
Medical confidentiality remains firmly in place. You do not receive employees’ diagnoses or clinical records. You receive the information needed to manage work safely, such as recommended workplace measures or whether a role has restrictions that must be considered. This separation matters. It helps employees trust the process and allows the doctor to provide independent professional advice.
The company doctor requirement is not just a name on a document
An appointment letter alone rarely demonstrates a functioning arrangement. Authorities and accident insurance institutions will usually expect the company doctor to be integrated into your actual safety management.
That means the doctor should understand your premises and work activities, contribute where their medical expertise is relevant, and be able to advise employees. Their involvement should be recorded in a proportionate way. Useful evidence can include appointment documentation, planned support hours, reports of visits, advice provided, occupational medical precaution arrangements and actions arising from findings.
The company doctor should also work alongside your occupational safety specialist. The safety specialist focuses on technical and organisational prevention, while the doctor focuses on health impacts. In a logistics operation, for instance, the safety specialist may assess vehicle routes, loading procedures and racking safety. The company doctor may consider physical strain, fatigue, fitness for tasks and appropriate health precautions. Together, they give you a more complete view of risk.
If you have more than 20 employees, you will generally also need an occupational health and safety committee (Arbeitsschutzausschuss, or ASA). The company doctor and safety specialist have roles in these meetings. The committee provides a practical forum for reviewing incidents, recurring concerns, inspections and preventive actions.
Common situations that change what you need
The duty to appoint a company doctor is ongoing, but the level and focus of support should change when your business changes. Opening a warehouse, introducing shifts, moving to a larger site or hiring staff into operational roles can all alter the risk profile.
Pay particular attention when you:
- open a German site, warehouse, retail location or workshop
- increase headcount or introduce new teams and work activities
- start using hazardous substances, respiratory protection or new work equipment
- receive a deficiency notice or inspection request from a BG
- have a reportable workplace accident, near miss or recurring health complaint
- introduce night work, regular driving, physically demanding work or lone working
These events do not automatically dictate the same solution for every employer. They do, however, create a clear reason to review your risk assessment and occupational health arrangements. Waiting until an inspection notice arrives can make corrective action harder to organise and document.
A practical three-step route to compliance
A sensible arrangement starts with understanding your operation, not with buying an arbitrary number of support hours.
1. Inspect the work and identify health risks
Review each site, work activity and employee group. Look at physical, chemical, ergonomic and psychological risks, as well as existing accident data and sickness patterns where appropriate. Your risk assessment should identify where company doctor input is necessary and which occupational medical precautions may apply.
For a small office, the priorities may include display screen work, ergonomic set-up, mental workload and first-aid arrangements. For a warehouse, add vehicle movements, lifting, noise, temperature, shift work and hazardous substances. The assessment must reflect the work people actually do, not a generic template.
2. Appoint qualified support and set the scope
Arrange a qualified company doctor and occupational safety specialist under a model appropriate to your BG and business. Confirm responsibilities, planned service levels, site coverage and how employees can access occupational health advice.
The arrangement should include both the basic support required by DGUV V2 and the workplace-specific support revealed by your risk assessment. If employees work across several German locations, make sure each site is properly considered. A nationwide external provider can coordinate this without forcing you to build a full internal health and safety function.
3. Record, act and review
Turn advice into operational action. That might mean adapting workstations, improving lifting procedures, arranging occupational medical precautions, updating training or changing shift arrangements. Keep records of decisions and completed measures, then review them at least annually and whenever work changes significantly.
This is the part that often distinguishes a paper exercise from a useful prevention system. A company doctor’s recommendation only reduces risk when managers can act on it and employees understand the change.
Mistakes that create unnecessary exposure
The most common mistake is assuming that a small or office-based business has no company doctor duty. Lower risk may affect the amount of support required, but it does not usually remove the employer’s obligation to arrange it.
Another is treating medical checks as the whole service. Occupational medical precaution is only one part of occupational health. Advice on work design, health risks and prevention is equally important.
Employers also run into difficulty when their company doctor, safety specialist and risk assessment operate separately. A medical provider who has never seen the site cannot give informed workplace advice. Equally, an otherwise strong risk assessment can miss health issues if no occupational medical expertise informed it.
Finally, do not wait for a BG letter to find the relevant documents. If an inspector asks about appointments, risk assessments, training or corrective actions, you should be able to show a clear and current system.
Frequently asked questions about the company doctor requirement
Does every employee need a medical examination?
No. Whether a medical precaution is mandatory, offered or available on request depends on the specific work exposure and ArbMedVV. Routine examinations without a work-related reason are not the purpose of the requirement.
Can we use an external company doctor?
Yes. External occupational health support is widely used and can be suitable for businesses of all sizes, provided the doctor is appropriately qualified and the arrangement meets your statutory duties and workplace needs.
Does remote work remove the requirement?
No. Remote work changes the risks you need to assess, particularly workstation ergonomics, working time, isolation and mental strain. It does not automatically remove the need for occupational health and safety support.
What happens after a workplace accident?
A reportable accident may trigger reporting duties and follow-up questions from the accident insurance institution. Review the event promptly with your safety specialist and company doctor where health factors are relevant. Corrective actions should be documented and communicated to the affected teams.
Occupational health does not need to be a compliance headache. With a site-based assessment, properly appointed experts and a clear action plan, you can give your people better protection while keeping your German operation ready for scrutiny. Captain Safety can help you put that structure in place and carry it forward as your business grows.