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In hospitals, occupational health and safety (OHS) training is often seen as "a yearly requirement" and is the first thing to be postponed when classroom scheduling gets tight. Yet in 2026 the picture changed in terms of both amounts and procedure: a new training regulation entered into force on April 2, 2026, administrative fines were updated by the revaluation rate, and the attempt to lower hospitals' hazard class came to nothing.
In this article, we summarize what missing training can mean for a hospital in Turkey, the rules introduced by the new regulation, and what to check before an inspection.
Legal framework: the employer's training obligation
Under Article 17 of Law No. 6331 on Occupational Health and Safety, the employer ensures that employees receive OHS training. Training is given in particular before starting work, when the workplace, job or work equipment changes and when new technology is introduced, and it is repeated at regular intervals. Employees who have had a workplace accident or have been away from work for more than six months also receive additional training before returning.
The same article sets two more important rules: the cost of training cannot be passed on to the employee, and time spent in training counts as working time. In other words, a training hour that looks "voluntary" outside the shift still counts toward working hours.
2026 administrative fines
Administrative fines are updated each year by the revaluation rate; for 2026, this rate is 25.49 percent. The main items directly related to training are:
| Breach | Article of the Law | 2026 amount | Note |
|---|---|---|---|
| Failure to comply with the training obligation | Art. 17, penalty Art. 26/1-ğ | TRY 8,980 | Separately for each employee, per breach |
| Failure to inform employees | Art. 16, penalty Art. 26/1-g | TRY 22,194 | For each employee not informed |
| Failure to comply with obligations in regulations based on the Law | Penalty Art. 26/1-n | TRY 22,194 | For each provision not complied with, monthly from the finding |
| Failure to take general OHS measures, including training | Art. 4, penalty Art. 26/1-a | TRY 44,443 | Increased by 200 percent in very hazardous workplaces with 50 or more employees |
Important note: The Ministry of Labor and Social Security's administrative fines page has not published a 2026 table for Law No. 6331. The amounts in the table come from a secondary source (Legalbank); they are arithmetically consistent with updating the 2025 amounts by 25.49 percent, but there is no official confirmation.
For per-employee fines, no increase based on hazard class or number of employees applies; however, the fine is already multiplied by the number of employees. As an example, a single breach in the training of 100 employees comes to 100 × TRY 8,980 = TRY 898,000. Whether clause 26/1-ğ or clause 26/1-n applies to a breach of the new regulation depends on how it is classified at inspection.
This content is for general information only and is not legal advice; check the official source for current amounts.
A fine is not the only consequence
The more serious consequence of missing training may emerge after a workplace accident or patient harm:
- Liability toward the employee: The employer must take every measure necessary for occupational health and safety (Turkish Code of Obligations, Art. 417).
- Employer's liability for staff: The institution can escape liability for harm caused by its employee only if it proves it exercised due care in selecting, instructing and supervising them (Code of Obligations, Art. 66).
- SGK recourse: If a workplace accident results from a breach of OHS legislation, the Social Security Institution (SGK) can reclaim its payments from the employer (Law No. 5510, Art. 21).
In all of these processes, dated and signed training records are the institution's main tool for proving it exercised due care.
The new regulation of April 2, 2026: what changed?
The Regulation on the Procedures and Principles of Employees' Occupational Health and Safety Training was published in Official Gazette (Resmî Gazete) No. 33212 of April 2, 2026, entered into force and repealed the previous 2013 regulation. Training given under the old regulation remains valid; a one-month period from publication was granted for undocumented training.
Induction training
Every employee, including apprentices and interns, receives induction training before actually starting work. This training is face to face and hands-on, lasts at least 2 hours per employee and does not count toward basic training time. It is recorded in minutes and kept in the personnel file.
Basic training and refresher intervals
Basic training is completed within three months of starting work at the latest. One class hour consists of at least 45 minutes of teaching and a 15-minute break.
| Hazard class | Basic training (min.) | Time for topic 4 (min.) | Refresher frequency | Refresher training (min.) |
|---|---|---|---|---|
| Less hazardous | 8 class hours | 2 class hours | Every 3 years | 8 class hours |
| Hazardous | 12 class hours | 3 class hours | Every 2 years | 8 class hours |
| Very hazardous | 16 class hours | 4 class hours | Every year | 8 class hours |
Topic 4 in the regulation covers job- and workplace-specific risks.
Requirements for distance and blended training
The most discussed part of the new regulation is its provisions on distance training:
- General, health and technical topics (topics 1–3) can be delivered remotely, face to face or in a blended format in all workplaces.
- Job- and workplace-specific risks (topic 4) are delivered face to face in hazardous and very hazardous workplaces.
- In distance training, employees' log-ins and log-outs, completion rates and assessment results are recorded, monitored and reported.
- The system must prevent fast-forwarding, skipping and closing the window, and support active participation with short questions or pop-ups at regular intervals.
In short, an "all OHS training online" approach is not possible in hospitals; induction training and topic 4 remain face to face.
Assessment and certification
A score of at least 60 out of 100 on the exam is a pass. Those who fail can retake the exam up to two more times; if they still fail, they repeat the basic training. Certificates can be signed with an electronic signature and archived electronically.
Who can deliver the training?
Article 10 of the regulation lists who may deliver basic training: the workplace's OHS specialist and occupational physician, the Labor and Social Security Training and Research Center (ÇASGEM), universities and the training units of public institutions, professional organizations with public-institution status, workers', employers' and public servants' organizations and their foundations, and foundations providing free training for the public benefit. Distance basic training content is also prepared by these people and institutions. Using a software platform therefore doesn't change the question of who delivers the training.
The debate over hospitals' hazard class
As set out in a parliamentary question to the Turkish Grand National Assembly (TBMM) dated January 13, 2026, which refers to the list of workplace hazard classes, inpatient hospital services are in the "very hazardous" class under codes 86.10.04 and 86.10.05 for the public sector and 86.10.12 and 86.10.13 for the private sector. On January 2, 2026, the Ministry of Health applied to the Hazard Classes Commission, asking for the class to be lowered to "hazardous". Following procedural objections from the Turkish Medical Association and TMMOB (Union of Chambers of Turkish Engineers and Architects), the meeting was postponed from January 13 to February 17.
According to a parliamentary question submitted to TBMM on February 23, 2026, the request was rejected in the commission by 6 votes to 5, and hospitals remained in the "very hazardous" class. The commission's official minutes have not been published; this information is based on that parliamentary question. The April 1, 2026 amendment to the hazard classes communiqué also left the rows under code 86.10 unchanged.
The practical result: in hospitals, basic training remains at least 16 class hours, refreshers remain yearly, and topic 4 is still delivered face to face.
Checklist for hospitals
- Is every new employee's face-to-face induction training before starting work, including apprentices and interns, recorded in minutes?
- Is basic training completed within three months of starting work?
- Are the dates of yearly refresher training tracked for each employee?
- Is topic 4 planned face to face?
- Does the distance training system record log-in/log-out, completion and exam results, and does it prevent fast-forwarding?
- Are retakes and repeat training tracked for those who fail the exam?
- Are certificates issued in line with the Annex 2 template and archived?
- Is the training delivered by the people or institutions listed in Article 10 of the regulation?
Sources
- Law No. 6331 on Occupational Health and Safety (Legislation Information System)
- Regulation on the Procedures and Principles of Employees' Occupational Health and Safety Training (Official Gazette, 02.04.2026, No. 33212)
- Fines applicable under Law No. 6331 (Legalbank, secondary source)
- Amendment to the Communiqué on Workplace Hazard Classes (Official Gazette, 01.04.2026, No. 33211)
- TBMM written parliamentary question No. 39291 (13.01.2026)
- TBMM written parliamentary question No. 41092 (23.02.2026)
- Objection to lowering hospitals' hazard class (Diken, 16.02.2026)
- Turkish Code of Obligations No. 6098 and Social Insurance and General Health Insurance Law No. 5510
How does ATP MedAI help in this process?
ATP MedAI is not an OHS training provider; OHS training is delivered by your hospital's OHS specialist and occupational physician. For the distance and blended parts of the content they prepare, the platform provides infrastructure that meets the regulation's record-keeping and monitoring requirements: fast-forward lock, in-lesson questions, log-in/log-out, active time and completion records, exam scores, e-signed attendance certificates and reporting. Training is assigned automatically by role and department, staff whose refresher date is approaching receive reminders, and completion status by department can be monitored from the manager dashboard. Sections that must be delivered face to face continue to be delivered face to face.
This article is for general information only and is not legal advice; check official sources for current amounts and provisions.
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ATP MedAI Editorial Team
This article was prepared for general information. If you spot an error or omission, let us know and we'll correct it.