An occupational physician is mandatory for every employer, including in a pure office business and regardless of headcount (section 2 ASiG). They are the second pillar alongside the occupational safety specialist, and neither role replaces the other. Despite what the name suggests, this is not about treatment or sick notes but about prevention and advice.
The obligation has no lower threshold
The Occupational Safety Act requires employers in section 2 to appoint occupational physicians and in section 5 to appoint occupational safety specialists. Neither section sets a minimum headcount. An office business with four employees therefore needs both, simply on a smaller scale.
How much support is required follows DGUV Regulation 2. Office and administrative businesses sit in support group III with 0.5 hours of basic support per employee and year, shared between the specialist and the physician. Since the revision on 1 January 2026 a minimum share must fall to each side; shifting the whole allowance to one side is ruled out. The support-hours calculator works out the split for your business.
For up to 50 employees, support can be organised on a needs basis through the Unternehmermodell. Even then the obligation remains; it is simply met differently, with the physician brought in when a specific occasion arises rather than permanently appointed.
What the occupational physician actually does in an office
The tasks are set out in section 3 ASiG and are consistently preventive. In an administrative business they fall into five areas:
- Occupational health screening under the ArbMedVV, in an office primarily the offered screening for screen work, including an examination of eyesight.
- Advice on ergonomics and the working environment: posture, monitor distance, lighting, indoor climate, noise in open-plan areas. Practical detail in Setting up a screen workstation correctly.
- Contributing to the risk assessment, particularly on health aspects and on mental stress, where the occupational-medicine perspective is hard to replace.
- Advice on specific groups of employees: pregnant and breastfeeding employees, employees with disabilities, return to work after a long illness.
- Participation in the occupational safety committee, quarterly above 20 employees.
The three types of occupational health screening
This is where most misunderstandings arise, because the terms sound similar but carry different legal consequences. The ArbMedVV distinguishes:
- Mandatory screening. The employer must arrange it, and the activity may not be carried out without it. It barely arises in a classic office business; it applies to activities with particular hazards.
- Offered screening. The employer must offer it; employees decide whether to take part. The most important case in an office is screen work, including an examination of eyesight. Important: the offer must actually be made and documented. An offer that was never made is a genuine gap, regardless of whether anyone would have accepted it.
- Optional screening. Employees can request it themselves where damage to health cannot be ruled out. The employer must make it possible.
In all three cases the employer bears the cost, and screening generally takes place during working hours.
Confidentiality: what the employer learns and what they do not
The occupational physician is bound by medical confidentiality. This is not a formality but the basis on which employees speak openly.
The employer receives a certificate that screening took place and when. They receive no diagnoses, no findings and no information about what was discussed. Where screening reveals a need for action in the business, the physician communicates this in anonymised or general form, for example as a note about a recurring ergonomic problem at certain workstations.
In practice that means: the certificates belong in the occupational safety documentation, the contents never do. Filing screening results in personnel records creates a data protection problem.
Who can act as occupational physician
Not every doctor can act as occupational physician. Occupational-medicine expertise is required, as a rule a specialist qualification in occupational medicine or the additional designation in company medicine. The owner's family doctor does not meet this requirement, however well they know the business.
For small and medium-sized office businesses the usual route is an external occupational health service. Employing someone directly only pays off with very large workforces, because the hours required in support group III are small.
When you actively need the occupational physician
Between routine appointments there are occasions when the physician should be brought in, even if nobody asks. The most important ones in an office business:
- An employee reports a pregnancy. An occasion-based assessment of the working conditions is then required, and the physician advises on protective measures and permissible activities.
- Return after a long illness. The physician can advise on which adjustments will support reintegration, without disclosing any diagnosis.
- A cluster of complaints at particular workstations, such as headaches in a poorly ventilated room or eye strain after a monitor change.
- Relocation or re-equipping. Advice before purchasing is considerably cheaper than retrofitting 40 workstations.
- Introducing remote work or desk sharing. Both change the pattern of strain and the ergonomic conditions.
- Signals around mental stress, such as high turnover or findings from an employee survey.
How the collaboration is organised in practice
In small and medium-sized office businesses, occupational health support rarely fails on willingness and almost always on organisation. Three points make the difference.
First, bundling appointments. A physician travelling in for two screening appointments is expensive. It makes sense to collect screening offers and combine them with a walkthrough or a committee meeting.
Second, announcing it internally. A screening offer that only appears on the intranet reaches almost nobody. Direct communication works better, with a concrete date and a clear statement that participation is voluntary and that the employer learns no results.
Third, documenting the offer, not only the uptake. What must be evidenced is that an offer was made. A list of who was offered what and when does this in a few lines, and it is exactly the record requested during an inspection.
Physician and specialist: two perspectives, one support system
The occupational safety specialist and the occupational physician look at the same workstation from different directions. The specialist asks about technology and organisation: is the escape route clear, has the equipment been inspected, has the training taken place. The physician asks about the effect on people: what strain arises, who is particularly affected, which screening is indicated.
A concrete example makes the difference clear. In an open-plan office with noise complaints, the specialist examines the structural and organisational options: acoustic elements, zoning, rules for phone calls. The physician looks at the health side: how sustained exposure works, where it connects to mental stress, which employees need screening. Only both perspectives together produce a measure that holds.
That is exactly why DGUV Regulation 2 prescribes a minimum share of the support hours for each side. Putting the entire effort into one role loses the other perspective, and that gets noticed during an inspection.
What you must be able to evidence
When the employers' liability insurance association asks about the occupational health side, these points are regularly requested:
- The written appointment of the occupational physician with the tasks assigned.
- The support record covering the hours actually delivered.
- The documentation of screening offers, particularly for screen work: who was offered what, and when.
- The screening certificates, without medical content.
- The contribution to the risk assessment, visible in the document itself.
A missing appointment is the same shortcoming as a missing specialist. In practice the physician is forgotten far more often, because the benefit seems less obvious in an office than that of the specialist.
Safety Club ensures both sides for office and administrative businesses and bundles them with the documentation into one contract, with an occupational safety specialist on site. What that costs depends mainly on headcount; more on this in What does an occupational safety specialist cost?.
This article is general guidance and does not replace legal advice on your individual case. What governs is the current version of the ASiG, DGUV Regulation 2 and ArbMedVV, together with how your employers' liability insurance association (Berufsgenossenschaft, BG) interprets it.
