OHS Obligations for Workplaces with Fewer than 50 Employees, the Complete Guide after 2025

The obligation under Occupational Health and Safety Law No. 6331 to assign an occupational physician and an occupational safety specialist was postponed five times for public institutions and low hazard workplaces with fewer than 50 employees. The final postponement, under Law No. 7491, ran until December 31, 2024. That date has passed and no new postponement followed. Since January 1, 2025 the obligation has applied to every workplace, regardless of headcount or hazard class.

What did the Constitutional Court ruling change?

In its decision of July 22, 2025 (E.2024/54, K.2025/163), the Constitutional Court unanimously annulled the provision of Law No. 7491 that introduced the last postponement. The decision was published in the Official Gazette No. 33102 of December 9, 2025. The Court held that postponing the obligation for the fifth time was incompatible with the state's duty to ensure a safe and healthy working environment, and that the obligation does not place an excessive burden on small workplaces.

Following the decision, the law no longer contains a postponement date for these workplaces. Annulment decisions do not apply retroactively, so 2024 is assessed under the rules in force at the time. Since January 1, 2025 the obligation has applied to all workplaces.

In practice this means a three-person accounting office and a forty-person store both need OHS services now. This guide answers the questions small businesses ask most often.

What exactly does the obligation cover?

Under Article 6 of the law, the employer must assign an occupational physician and an occupational safety specialist, either from among employees or through an external provider. The external service may come from a joint health and safety unit (OSGB) authorized by the Ministry or from an occupational health centre (ÇASMER), an option added by Law No. 7538. In practice the common route is a contract with an OSGB. Workplaces in the very hazardous class with 10 or more employees must also assign other health personnel.

Which duties can the employer take on?

The law gives small businesses one form of relief. In low hazard workplaces with fewer than 50 employees, the employer or their representative can carry out part of the OHS services after completing the training announced by the Ministry. The procedure is set out in the Regulation on OHS Services Carried Out by the Employer or Employer Representative.

• What the employer can take on: basic OHS duties such as taking part in the risk assessment, informing employees and organizing emergency arrangements.
• What the employer cannot take on: pre-employment and periodic health examinations and the tests behind them. These always require a physician and medical infrastructure.
• If the training requirement is not practical or the workload is unwanted, the full service can be obtained from an OSGB.

How much do the minimum hours add up to?

In the low hazard class the minimum monthly time per employee is 5 minutes for the occupational physician and 10 minutes for the safety specialist. For a twenty-person business that is roughly 100 minutes of physician time and 200 minutes of specialist time per month. The cost is lower than most businesses expect and negligible next to the administrative fine issued in an inspection.

A three-step roadmap

• Confirm your workplace hazard class from your NACE code. The class determines both the minimum hours and the specialist class.
• Agree the scope with an authorized OSGB. Gather the physician, the specialist, the risk assessment, the emergency action plan and the trainings in a single contract.
• Complete the İSG-KATİP approvals and put the annual work plan on your calendar.

If you want the minimum-hour calculation and a scope proposal for your business, just send your headcount through the quote form. We reply in writing the same business day.