Reporting obligation in accordance with IAF MD 22
Simplified accident reports (in terms of occupational safety) from 2026
As we start the new year 2026, we would like to wish you all the best and inform you about a significant improvement for ISO 45001 certified customers. The updated regulation on the reporting requirement for serious accidents and violations of employee protection regulations in accordance with IAF MD 22 brings clearer criteria, greater legal certainty, faster action, and less bureaucracy.
Occupational safety management systems have been proven to protect employees and their environment from health hazards – yet accidents and incidents can never be completely avoided. This makes it all the more important to know what to do in an emergency: which events must be reported and how companies must proceed correctly.
We have summarized the answers for you.
What is new?
Previously, occupational accidents only had to be reported if they resulted in at least 24 days of lost work time, as did violations of employee protection regulations.
As of January 1, 2026, the 24-day absence criterion will no longer apply.
Accidents at work from the 2025 calendar year must still be reported in accordance with the previous regulations.
From January 1, 2026, the following will therefore apply:
- Serious incidents must be reported immediately, regardless of the number of days of absence (examples can be found below in the detailed information)
- Violations of employee protection regulations will continue to be reportable
In short:
The reporting obligation remains fundamentally unchanged – only the criterion of 24 days of absence is no longer applicable.
Details on the changes
The regulatory notice from document IAF MD 22 (paragraph G 8.5.3) reads as follows:
“Legally enforceable agreements must ensure that the certified customer immediately informs the certification body of the occurrence of a serious incident or a violation of the regulations as soon as it is necessary to involve the competent supervisory authority.”
Examples of serious incidents
Serious incidents are always based on the respective damage to the health of the person concerned. These can include, for example:
- Fatal or life-threatening injuries
- Permanent loss of vision
- Loss of fertility
- Permanent damage to health, e.g.:
- Amputations, loss of limbs
- Severe burns
- Open or complex fractures
- Injuries to the spine or internal organs
- Opening of body cavities
- Traumatic brain injury
Which authority is responsible?
The reporting obligation referred to here does not involve reporting to the respective accident insurance provider (in Austria, the AUVA). Rather, it refers to reporting to the competent supervisory authority, which in Austria is the labor inspectorate.
This distinction is important, as both reporting channels exist independently of each other and serve different purposes.
Diese Abgrenzung ist wichtig, da beide Meldewege unabhängig voneinander bestehen und unterschiedliche Zwecke erfüllen.
Examples of competent supervisory authorities (selection)
Germany
Occupational safety authorities of the federal states (labor inspectorate)
In Germany, the 16 occupational safety authorities of the federal states are responsible for enforcing employee protection.
https://lasi-info.com/ueber-den-lasi/arbeitsschutzbehoerden-der-laender
Italy
National Labor Inspectorate – Ispettorato Nazionale del Lavoro (INL)
https://www.ispettorato.gov.it/
Responsibilities:
Employee protection in areas including building construction, road construction, tunnel construction, work with compressed air containers and underwater, ionizing radiation, accident prevention in rail transport, as well as employment contract law, social insurance, and collective agreements.
Czechia
State Labor Inspectorate – Státní úřad inspekce práce (SÚIP)
Responsibilities
Occupational safety and health, safe use of work equipment, employment of women and young people, child labor (cultural sector), posting of workers, illegal employment, working time and rest periods.
Slovakia
National Labor Inspectorate – Národný inšpektorát práce
Responsibilities:
Safety at work, industrial accidents, market surveillance of machinery and chemical agents, working time and illegal employment.
Poland
State Labor Inspectorate – Państwowa Inspekcja Pracy (PIP)
Responsibilities:
Employee protection, market surveillance (e.g., machinery, elevators, pressure vessels), REACH and CLP, SEVESO, genetically modified organisms, and illegal employment.
Where and how is this topic anchored in the context of an OHS management system?
The obligation to report incidents is firmly anchored in several elements of an OHS management system (occupational health and safety) and can therefore be systematically verified.
On the one hand, the processes must clearly define how reports are to be made in accordance with IAF MD 22 and how accidents or incidents are to be dealt with.
On the other hand, proper fulfillment of the reporting obligation is one of the legal obligations whose compliance must be regularly assessed.
The circle closes with the incident investigation: it shows whether events are correctly identified, reported, analyzed, and dealt with using effective measures.
These three examples already illustrate how well the topic is integrated into the management system – and whether the system works effectively or has systemic weaknesses that become apparent during an audit at the latest.
How is the review carried out as part of an audit?
The reports received in accordance with IAF MD 22 are reviewed internally and made available to the respective lead auditors. This ensures that targeted samples can be taken during the audit and relevant incidents can be reviewed in a traceable manner.
For multisite organizations, the focus of the review is on the head office, as this is where all reports are collected. In this way, accidents and incidents at sites that are not directly audited in the respective year due to the annual matrix allocation can also be assessed.
This ensures a complete and systematic evaluation of the effectiveness of the OHS management system across all sites.
At Quality Austria, we know that accidents and incidents are special situations. To make reporting as easy as possible, the organization concerned can decide for itself whether to write the description directly into the PDF or attach it as an appendix. Quality Austria will assess the information provided and decide on the further course of action (no action necessary, special audit, withdrawal of certificate) on the basis of a risk analysis.
The writable PDF can be found here:
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