Staff training obligations and 2026 sanctions
The legal basis for mandatory training in hospitals and clinics in Turkey, who it covers and the sanctions that may apply when it is missing; with links to official sources.
Last checked: October 27, 2026 · amounts are for 2026
This content is for general information only and is not legal advice; check the official source for current amounts.
Where does the training obligation come from?
Mandatory training doesn't come from a single law; each area has its own legal basis, scope and sanctions.
Occupational health and safety training
Induction, basic and refresher training under Law No. 6331 on Occupational Health and Safety; durations, distance training and certification rules under the regulation of April 2, 2026.
Orientation and in-service training records
Training management in SKS Hospital (Turkey's Health Quality Standards): needs analysis, plan, orientation and in-service training, effectiveness measurement and records.
Data security training
Under KVKK (Turkish Personal Data Protection Law), regular training for employees who process health data is one of the Board's safeguards for special-category data.
Field-specific training
Periodic training for medical waste staff, training for radiation workers, continuous in-service training in infection control.
Obligation, legal basis and sanction
Administrative fines are updated each year by the revaluation rate; for 2026 the rate is 25.49%.
| Obligation | Legal basis | Sanction and 2026 amount | Source |
|---|---|---|---|
| OHS training for employees (induction, basic, refresher, change of job or equipment, after an accident, absence of more than 6 months) | Law No. 6331, Art. 17; penalty Art. 26/1-ğ | Administrative fine applied separately for each employee per breach: TRY 8,980 / employee (secondary source; official 2026 table not published) | Law No. 6331 Legalbank 2026 table (secondary) |
| General OHS measures, including training and information | 6331 Art. 4/1-a; penalty Art. 26/1-a | TRY 44,443 (base); applied with a 200% increase in very hazardous workplaces with 50 or more employees (secondary source) | Legalbank 2026 table (secondary) |
| Informing employees | 6331 Art. 16; penalty Art. 26/1-g | TRY 22,194 for each employee not informed (secondary source) | Legalbank 2026 table (secondary) |
| Training procedures: duration, distance training, documentation | Regulation on the Procedures and Principles of Employees' OHS Training (RG 02.04.2026/33212) | Law Art. 26 applies; Art. 26/1-n: TRY 22,194 per month for each provision not complied with (secondary source). Which clause applies depends on how the breach is classified at inspection. | RG 02.04.2026/33212 |
| SKS compliance and self-assessment; training management records | Regulation on Improving and Assessing Quality in Healthcare (RG 29399; amended RG 32202); SKS Hospital S.6.1 | No direct fine; low score and action plan obligation | RG 26.05.2023/32202 SKS Hospital 6.1 |
| Private hospital staffing and service standards (inspection form Annex 2) | Private Hospitals Regulation (RG 30.01.2025/32798; amended RG 29.08.2026/33355); Law No. 3359, Additional Art. 11 | Graduated sanctions. For the Annex 2 question on operating room staff training, first finding: one-thousandth of the previous month's gross service revenue, not less than TRY 180,617; higher fines and suspension of activity on repeat findings | RG 32798 RG 33355 Annex 2 form |
| Patient and staff safety training for all employees | Regulation on Ensuring Patient and Employee Safety (RG 06.04.2011/27897), Art. 8/1-e | No separate fine in the regulation; a minimum score of 80 is required in the assessment | RG 27897 |
| Periodic training for medical waste staff | Regulation on the Control of Medical Waste, Art. 9, 23, 29; Environmental Law No. 2872, Art. 20 | No clause specific to training. Relevant clauses: facilities producing 1 kg of waste or less per day up to TRY 63,802; improper collection, storage and disposal TRY 782,106–3,128,439 (3 times for institutions) | Regulation Environment communiqué 2026/1, annex |
| Training, training plan and records for radiation workers | NDK (Nuclear Regulatory Authority) Authorization Regulation, Art. 13, 28/1-ğ, 33/1-e; Regulation on Radiation Protection Training; Law No. 7381, Art. 25 | Radiation facilities: TRY 874,115–4,070,698; other activities: TRY 25,518–178,648; doubled each time if not remedied in time | Law No. 7381 NDK 2026 communiqué |
| Data security measures; regular training for employees who process health data | KVKK, Law No. 6698, Art. 6, 12, 18/1-b; Board Decision 2018/10 | TRY 256,357–17,092,242; disciplinary provisions in public institutions | Law No. 6698 KVKK 2026 table |
| Continuous in-service training for staff (infection control committee) | Infection Control Regulation for Inpatient Healthcare Facilities, Art. 7/c, 12, 14/ı, 18 | No separate fine in the regulation; action under general provisions | RG 25903 |
| Proving due care in lawsuits: training records | Turkish Code of Obligations, Art. 66, 116, 417; Law No. 5510, Art. 21 | Liability for damages and recourse action by SGK (Social Security Institution); no fixed amount | Code of Obligations No. 6098 Law No. 5510 |
Amounts are taken from sources read as of October 27, 2026. No official table was found for the 2026 amounts under Law No. 6331; these amounts come from a secondary source and are consistent with the 25.49% revaluation rate. RG = Resmî Gazete, the Official Gazette of Turkey (dates in DD.MM.YYYY format).
How should OHS training be delivered in hospitals?
Inpatient hospital services are in the “very hazardous” class; the Ministry of Health's request to lower the class was rejected by the commission in February 2026.
The Regulation on the Procedures and Principles of Employees' OHS Training entered into force on April 2, 2026, repealing the 2013 regulation. Induction training is given hands-on and face to face before the employee actually starts work, including apprentices and interns; it lasts at least 2 hours and does not count toward basic training time.
Basic training is completed within 3 months at the latest. Job- and workplace-specific risks (topic 4) are delivered face to face for at least 4 class hours in very hazardous workplaces. General, health and technical topics can be delivered remotely.
In distance training, log-in/log-out, completion rate and assessment results are recorded, monitored and reported. The system must prevent fast-forwarding, skipping or closing the window, and support active participation with short questions. A pass requires at least 60 out of 100; certificates can be e-signed and archived electronically.
Who can deliver it: Basic training is delivered by the workplace's OHS specialist and occupational physician and by the institutions listed in the regulation; distance training content is also prepared by these people and institutions. ATP MedAI does not deliver OHS training; it provides infrastructure that meets the record-keeping requirements for training prepared by your hospital's OHS professionals.
| Hazard class | Basic training (min.) | Refresher |
|---|---|---|
| Less hazardous | 8 class hours | Every 3 years |
| Hazardous | 12 class hours | Every 2 years |
| Very hazardous (inpatient hospitals) | 16 class hours | At least once a year |
- One class hour consists of at least 45 minutes of teaching and a 15-minute break.
- Refresher training is at least 8 class hours.
- Training delivered under the previous regulation remains valid.
- The hazard class decision is based on parliamentary questions in the Turkish Grand National Assembly (TBMM) and press sources; the commission's official minutes could not be read.
SKS and the Healthcare Quality Regulation
Institutions organize their work in line with SKS, enter their self-assessment results into the Ministry's system and prepare action plans for unmet standards. The Training Management section of SKS Hospital 6.1 covers training needs analysis, the training plan, general and department orientation for every new employee, in-service training and measuring training effectiveness.
Training delivered must be recorded and kept in the personnel file, and training records must be accessible from the personnel file. The quality regulation sets no fines; a low score, however, creates an action plan obligation.
Private Hospitals Regulation
Inspections use the Annex 2 inspection, inquiry and administrative sanctions form; the form was renewed by the amendment of 29.08.2026. Question 129 on the form asks whether a specialist has been assigned responsibility for managing and training operating room staff.
The sanction for this question is graduated: on the first finding, an administrative fine of one-thousandth of the previous month's gross service revenue, not less than TRY 180,617, and 30 days to comply; on the second finding, the fine is doubled; on the third, outpatient clinic activity is suspended for 5 days.
Patient and staff safety, infection control
The Regulation on Ensuring Patient and Employee Safety requires secondary and tertiary care institutions to provide patient and staff safety training to all employees; the institution's most senior manager is responsible for implementation. The Infection Control Regulation for Inpatient Healthcare Facilities tasks the infection control committee with ensuring continuous in-service training for staff.
Neither regulation sets a separate fine; gaps surface through quality assessments and general inspection mechanisms.
Medical waste and radiation safety
Healthcare facilities must periodically train staff involved in medical waste management and employ staff holding a Vocational Qualification Certificate in the relevant field. Radiation workers and staff likely to be in radiation areas are trained at regular intervals; the radiation protection program includes a training plan, and training records are kept.
In radiation protection training, the certificate of achievement is valid for 5 years. Breaches bring administrative fines under Laws No. 2872 and 7381; the 2026 amounts are in the summary table.
KVKK
Health data is special-category personal data. Decision 2018/10 of the Personal Data Protection Board lists regular training on the Law and data security for employees involved in processing such data among the adequate measures. For breaches of Art. 12, administrative fines of TRY 256,357–17,092,242 apply in 2026.
Training records in lawsuits
A private hospital is liable for the acts of its physicians and staff: in contract, for its auxiliaries; in tort, as their employer. To escape liability, it must prove it exercised the necessary care. If a workplace accident results from a breach of OHS legislation, SGK recovers its payments from the employer.
Signed and dated training records are important evidence in meeting this burden of proof; such records must be kept anyway under the OHS training regulation and SKS.
How much risk does missing OHS training carry?
Under Art. 26/1-ğ of Law No. 6331, the fine applies separately for each employee whose training is missing. Enter a number to see the estimated amount.
The calculation is number of employees × TRY 8,980 for a single breach. According to the note in the secondary source, the increase based on hazard class and number of employees does not apply to this per-employee fine. The sanction in a specific case depends on the inspecting authority's assessment.
Source: Law No. 6331, Art. 17 and 26/1-ğ; 2026 amount from Legalbank (secondary source; official table not published). Last checked: October 27, 2026.
This content is for general information only and is not legal advice; check the official source for current amounts.
Plan, deliver, record
ATP MedAI is a tool that helps plan and record statutory training obligations; the employer remains responsible for the training's regulatory compliance.
Planning and assignment
Annual training plan, a refresher schedule matched to the hazard class and automatic assignment by role.
Distance-training record requirements
Fast-forward lock, quick checks, log-in/log-out, completion rate and exam records; reporting.
Certificates and archive
E-signed attendance certificates and an electronic archive; records accessible for each staff member.
Audit-ready reports
Completion, exam and certificate status by department and staff member; PDF and Excel.
Sources
- Law No. 6331 on Occupational Health and Safety
- Regulation on the Procedures and Principles of Employees' OHS Training (RG 02.04.2026/33212)
- Legalbank: 2026 administrative fines under Law No. 6331 · secondary source
- TBMM parliamentary question (13.01.2026): hospitals' hazard class
- TBMM parliamentary question (23.02.2026): rejection of the reclassification request
- Diken (16.02.2026): objection over the hazard class · press
- Evrensel (24.02.2026): “Bir başvuru, bir niyet” (An application, an intention) · press
- Amendment to the hazard classes (RG 01.04.2026/33211)
- Amendment to the Healthcare Quality Regulation (RG 26.05.2023/32202)
- SKS Hospital Set Version 6.1
- SKS Hospital versions
- Private Hospitals Regulation (RG 30.01.2025/32798)
- Amendment to the Private Hospitals Regulation (RG 29.08.2026/33355) and Annex 2
- Basic Law on Health Services No. 3359
- Regulation on Ensuring Patient and Employee Safety (RG 06.04.2011/27897)
- Regulation on the Control of Medical Waste
- Environmental Law No. 2872
- Ministry of Environment communiqué 2026/1, annex
- Nuclear Regulatory Law No. 7381
- NDK communiqué on 2026 administrative fines
- Regulation on Authorizations for Radiation Facilities and Applications (RG 28.10.2023/32353)
- Regulation on Radiation Protection Training (RG 19.02.2025/32818)
- Personal Data Protection Law No. 6698 (KVKK)
- KVKK 2026 administrative fines table
- Personal Data Protection Board Decision 2018/10 (RG 07.03.2018/30353)
- Infection Control Regulation for Inpatient Healthcare Facilities (RG 11.08.2005/25903)
- Turkish Code of Obligations No. 6098
- Social Insurance and General Health Insurance Law No. 5510
Legal notice: The information on this page was prepared for general information on the basis of legislation and publicly available sources published as of October 27, 2026, and does not constitute legal advice. Administrative fine amounts are updated each year by the revaluation rate; the sanction applied in a specific case may vary depending on your organization's type, hazard class, number of employees and the inspecting authority's assessment. For obligations specific to your organization, consult your occupational health and safety professional and your legal counsel. ATP MedAI is a tool that helps plan and record statutory training obligations; the employer remains responsible for the training's regulatory compliance.
This content is for general information only and is not legal advice; check the official source for current amounts.
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