The ArbMedVV obliges German employers to arrange or offer occupational health checks for certain activities - noise, hazardous substances, wet work, screen work and more. The first takes place before the activity starts, the second normally within 12 months, then at most every 36 months. Here is how it works and what to track.
Last updated · ExpiryEdge editorial team
Under the German ArbMedVV, employers must arrange mandatory health checks (Pflichtvorsorge) and offer others (Angebotsvorsorge) for listed activities, before the activity starts and then regularly. Under AMR 2.1, the first takes place within 3 months before starting, the second normally within 12 months, then at most every 36 months. Employers keep a record of when and why each took place.
The three types, the intervals and the employer's record-keeping duty.
| Topic | Rule | Basis |
|---|---|---|
| Mandatory check (Pflichtvorsorge) | Employer must arrange it before the activity and regularly; employee may only do the activity after attending | § 4 ArbMedVV |
| Offered check (Angebotsvorsorge) | Must be offered before the activity and regularly; a refusal does not end the duty to keep offering | § 5 ArbMedVV |
| Check on request (Wunschvorsorge) | Must be made possible on the employee's request where harm cannot be ruled out | § 2 (4) ArbMedVV |
| First check | Within 3 months before the activity starts | AMR 2.1 |
| Second check | Normally within 12 months (6 months for sensitising substances and wet work) | AMR 2.1 |
| Further checks | At most every 36 months; physician may shorten, not extend | AMR 2.1 |
| Health check record (Vorsorgekartei) | That, when and for which reason a check took place - no medical findings; kept until employment ends | § 3 (4) ArbMedVV |
| Fines | Not arranging mandatory or not offering offered checks, or no record: up to €5,000 | § 10 ArbMedVV with § 25 ArbSchG |
Both exist. For mandatory checks the employer must arrange the appointment and the employee may only do the activity after attending. Offered checks must be offered; the employee can decline, but the employer has to keep offering at the intervals. Physical examinations are never carried out against the employee's will.
Not under the ArbMedVV. G 25 (driving, steering and monitoring tasks) is a DGUV recommendation about fitness for work, not a statutory health check, and is not legally binding. It becomes binding only through an employment contract, a works agreement or a special legal provision. If your company has agreed G 25, its repeat dates still need tracking.
A physician entitled to use the title occupational medicine or company medicine (§ 7 ArbMedVV), preferably the appointed company doctor. The employer pays: costs of occupational safety measures may not be passed on to employees (§ 3 (3) ArbSchG). Checks should take place during working time.
A certificate that, when and for which reason a check took place, and when the next check is indicated from a medical point of view (§ 6 (3) ArbMedVV). Findings and diagnoses stay with the doctor. Those dates are what the employer must track.
Track the next date from the certificate - not the diagnosis. The record must never contain medical findings.
The AMR 2.1 sequence and a record per employee with reason, type and next date.
Match each activity against the ArbMedVV annex: mandatory, offered or on request.
Commission a physician with the occupational or company medicine qualification and share the risk assessment results.
Mandatory checks must have taken place before the activity; offered checks must be offered in writing in good time.
Keep the record of that, when and why - and the next date the doctor indicates. Never store findings.
Remind ahead of each next date, and keep offering offered checks even after a refusal.
Hold each reason - noise, wet work, screen work, respiratory protection - as a record per employee with the type, the last check and the next date from the certificate. HR and the employee are reminded ahead of time, and overdue mandatory checks escalate before the employee continues the activity.
Recurring dates per reason
Reminders by email, SMS, WhatsApp or Teams
Overdue mandatory checks flagged
Send the written offer for an offered check as a request the employee confirms or declines with an e-signature, and collect the attendance certificate by upload link. Access is restricted by role, and the record holds only dates and reasons, never findings.
Offer and response with e-signature
Certificate upload without an account
Role-based access to the record
Under AMR 2.1: the first within 3 months before the activity starts, the second normally within 12 months (6 months for sensitising substances and wet work), then at most every 36 months. The company doctor may set shorter intervals but not longer ones.
Mandatory checks (Pflichtvorsorge) must be arranged by the employer and attended before the activity. Offered checks (Angebotsvorsorge) must be offered; the employee may decline. In both cases examinations are not carried out against the employee's will.
No. G 25 is a DGUV recommendation on fitness for driving, steering and monitoring tasks and is not part of the statutory ArbMedVV checks. It becomes binding only through a contract, a works agreement or a special legal rule.
A health check record (Vorsorgekartei) stating that, when and for which reason each check took place, kept until employment ends; on leaving, the employee gets a copy of their entries (§ 3 (4) ArbMedVV). Medical findings do not belong in it.
The employer. Costs of occupational safety measures may not be passed on to employees (§ 3 (3) ArbSchG), and checks should take place during working time.
Yes, as an offered check (Angebotsvorsorge) under the ArbMedVV annex, including an appropriate examination of the eyes and vision.
Hold one record per employee and reason with the type and the next date from the certificate, and remind HR and the employee ahead of time. ExpiryEdge does this without storing medical data and flags overdue mandatory checks.
Import employees and reasons, set reminders, collect certificates by link. Free 14-day trial, no credit card.
