A letter from the employers' liability insurance association, for office businesses usually the VBG, is in the vast majority of cases not a sanction but a request for information: the association wants to see evidence that your occupational safety is organised. Note the deadline, gather the records requested and reply factually, and the matter is usually settled quickly.
What the association is entitled to do
Under the Seventh Book of the German Social Code, the associations have a statutory mandate for supervision and advice (sections 17 to 20 SGB VII). Specific powers follow from that:
- Inspecting businesses. Inspectors may enter and inspect business premises, and they generally do so without notice.
- Requesting information and records. Businesses are obliged to provide information. That includes the documents with which you evidence your safety organisation.
- Issuing orders. Where an inspector identifies shortcomings, they can order which measures must be taken and by when.
- Initiating fines. Failing to comply with an order or refusing information is a regulatory offence and can be penalised with a fine (section 209 SGB VII).
Important for context: the sequence is almost always advice, then a deadline, then an order, and only finally a sanction. A first letter is therefore not an accusation but the start of a process that a good reply will usually end.
Why the letter arrives at all
The triggers are rarely random. In office businesses these are usually behind it:
- Routine inspection. The association works through member businesses systematically, regardless of any particular trigger.
- New registration or change. A newly founded business, a relocation or a marked increase in headcount often prompts contact.
- A reported accident at work. After an accident report the association regularly examines the circumstances. What gets asked is covered in Accidents at work in the office.
- A tip-off from inside the business. Complaints from employees or the works council are followed up.
- A sample check on a focus topic, such as risk assessment of mental stress or screen work.
The BG visit forecast gives a rough read on how likely contact is in your situation. It is not a guarantee, but it helps with context.
Which records are typically requested
These documents cover almost every request for information in an office business. Anyone who has them together is able to reply:
- The written appointment of the occupational safety specialist and the occupational physician. Alternatively, proof of participation in the Unternehmermodell.
- A current risk assessment including mental stress, documented under section 6 ArbSchG, with measures, owners and deadlines.
- Training records under section 12 ArbSchG with date, content and signatures.
- First-aid organisation: named first aiders and their training status, first-aid supplies, the notice, the reporting chain. See First aid in the office.
- A support record covering the hours actually delivered.
- Above 20 employees: the minutes of the occupational safety committee; from 50 additionally the appointment of safety officers.
- Inspection records for portable electrical equipment.
Whether anything is missing on your side can be checked in advance with the BG risk check. That is considerably more pleasant than discovering the gap while drafting your reply.
Responding correctly in five steps
- Note the deadline, immediately. The most common avoidable mistake is not the missing document but the missed deadline. Enter the date before you do anything else.
- Read carefully what is being asked. Is this a request for written information, notice of an inspection, or a demand for specific documents? Answer the question asked, not the one you assume.
- Gather the records you have. Pull everything that already exists into one folder. There is often more available than expected; it is simply scattered.
- Name and close the gaps. If the appointment of a specialist or the risk assessment is missing, organise it now. If it will not be complete by the deadline, send an interim update with a realistic date for supplying the rest.
- Reply factually and completely. No justifications, no blame, no commitments you cannot keep. Keep the entire correspondence; from now on it is part of your documentation.
Berufsgenossenschaft or state authority: who is writing to you?
Occupational safety in Germany has two supervisory strands running in parallel. Who writes determines what the request is based on.
The Berufsgenossenschaft is the statutory accident insurance provider. It supervises on the basis of SGB VII and the accident prevention regulations, such as DGUV Regulation 1 and DGUV Regulation 2. Membership is mandatory and follows from your contribution notice; for office businesses it is usually the VBG.
The state occupational safety authority, depending on the federal state a trade supervisory office, occupational safety office or regional council, supervises on the basis of the Occupational Health and Safety Act, the Workplace Ordinance and the other state regulations.
Both can act independently of each other, and both may request records. In practice that means two things: replying to one does not settle a request from the other, and the records they ask for overlap heavily. Anyone who has the documents from the section above together is able to answer both strands.
How an inspection typically runs
If the letter announces an inspection visit, it helps to know what to expect. In office businesses the sequence is usually similar:
- Opening discussion. The inspector explains the reason for the visit and asks about the basics: headcount, activities, sites, who is responsible for occupational safety, and which support model was chosen.
- Review of records. The documents from the section above are examined. The question is about the current state, not about a folder full of history.
- Walkthrough. A tour of the premises: traffic routes, escape routes and whether they are kept clear, signage, first-aid supplies, screen workstations, storage, kitchen, archive.
- Closing discussion. The inspector states the findings and, where necessary, deadlines for remedying them.
What almost always gets noticed, and can be fixed beforehand in minutes: blocked escape routes, boxes on traffic routes, a first-aid kit with expired contents, a missing or outdated first-aid notice. You can produce a current notice in a few minutes with the first-aid notice generator.
After the visit: working through the findings
The matter does not end with the walkthrough. A written result with findings and deadlines usually follows. Three things matter afterwards.
First, work through the points within the deadline set and confirm completion in writing, even where no reply is expressly requested. Second, transfer the findings into your risk assessment rather than keeping them as a separate list. That is exactly what the instrument is for, and at the next contact the update is evidenced. Third, treat the result as a checklist for the coming years. Whatever was noticed once will be noticed again at the next inspection if it was not solved structurally.
Also record who in the business owns the reply. Where correspondence runs through several people, experience shows it is precisely the deadline nobody explicitly took on that gets missed.
What not to do
- Ignore it. A request for information becomes an order, and an order becomes fine proceedings.
- Backdate records. A training session retrospectively dated earlier is worthless at best and a problem in its own right at worst.
- Promise more than necessary. Answer what is asked. Volunteering further gaps widens the scope of the review.
- Treat the inspector as an opponent. The statutory mandate expressly includes advice. A factual question about what exactly is expected is usually the fastest route to clarity.
Why being able to prove it decides everything
When it matters, what counts is not that you "actually do all of this" but that you can evidence it. This is exactly where office businesses regularly come unstuck: the training took place, but without an attendance list. The risk assessment exists, but is three relocations old. The first aiders are named, but the two-year refresher was overlooked.
Safety Club makes sure that for office and administrative businesses these records are bundled and ready to produce at any time, supported by an occupational safety specialist on site. Is a letter sitting on your desk? Get a short consultation before the deadline runs out.
This article is general guidance and does not replace legal advice on your individual case. What governs is the current version of the regulations mentioned, together with how your employers' liability insurance association (Berufsgenossenschaft, BG) interprets it.
