Businesses with up to and including 50 employees do not have to appoint an occupational safety specialist permanently. For them, Annex 3 of DGUV Regulation 2 allows a simplified route: the Unternehmermodell, officially alternative needs-based support. Company management qualifies itself and brings in expertise only when a specific occasion arises. There is no lower limit: this applies to a business with three employees just as much as to one with fifty.
How the Unternehmermodell works
The model has two components, and both must be satisfied. One alone is not enough.
- Motivation and information measures. Owners attend training on the core duties in occupational safety: risk assessment, safety training, first aid, organisation and documentation. The courses are run by the responsible employers' liability insurance association, for office businesses usually the VBG. Attendance must be repeated; the cycle is set by the association.
- Needs-based support. The occupational safety specialist and the occupational physician are not permanently appointed but brought in when a specific occasion arises. Occasions include a relocation, setting up new workstations, procuring new work equipment, an accident at work, or indications of health impairment.
The important point about this construction: the obligation does not disappear, it moves. What an external specialist would otherwise handle as a matter of routine, you do yourself, and you must recognise for yourself when an occasion for external expertise has arisen.
The limits: up to 50 employees
The Unternehmermodell applies to businesses with up to 50 employees. There is no lower limit: an office with three or with fifteen employees can choose it just as well, and no occupational safety specialist has to be formally appointed for it. The upper limit is unambiguous: up to and including 50 employees. From 51 the business falls under standard support per Annex 2, with a specialist and a physician appointed in writing and a defined number of hours.
Within the permitted range, one organisational duty applies that the Unternehmermodell does not remove:
- Above 20 employees, an occupational safety committee must be set up and meet quarterly (section 11 ASiG). See Occupational safety committee (ASA): from when?. The specialist also sits on that committee, which makes the model more demanding in practice at this size.
Safety officers in the office under section 22 SGB VII, by contrast, are added in a classic office only from 50 employees (since 29 May 2026; between 20 and 49 only where there is a special hazard). A business with 35 employees under the Unternehmermodell therefore has to run a committee but usually does not yet have to appoint safety officers. The duties quick-check shows which obligations apply at your headcount.
What you take on yourself under this model
The item most often missing from the calculation: the tasks do not disappear, they stay with you. Specifically:
- Producing, documenting and updating the risk assessment, including mental stress under section 5 paragraph 3 ArbSchG.
- Planning, delivering and evidencing safety training, at least annually and whenever something changes. The training-interval calculator works the deadlines out.
- Building and maintaining the first-aid organisation: naming first aiders and refreshing their training every two years, providing supplies, setting the reporting chain.
- Keeping track of test intervals for electrical equipment and documenting them.
- Keeping the whole documentation in a state where it can be produced during an inspection.
- Recognising when an occasion for external expertise has arisen, and bringing it in on time.
What the training covers and what it does not replace
The motivation and information measures are not a short briefing but a structured programme run by the employers' liability insurance association. The content covers the duties that subsequently sit with you: the legal basis of occupational safety, building and updating the risk assessment, delivering safety training, organising first aid, and how to recognise that an occasion for external expertise has arisen.
What the training expressly does not do: it does not make you an occupational safety specialist. Training as a specialist under section 7 ASiG runs to many times the hours and ends with an examination. That is precisely why the Unternehmermodell assumes you will bring in someone with that qualification whenever a specific occasion arises. Treating the course as a substitute for expertise misreads the model.
The documentation that still has to exist
A widespread misunderstanding is that the Unternehmermodell also simplifies documentation duties. It does not. What is simplified is solely how support is organised, not occupational safety itself. These records must be available during an inspection just as they would be under standard support:
- Attendance records for the motivation and information measures, including the refreshers.
- The risk assessment with measures, owners, deadlines and a documented effectiveness review (section 6 ArbSchG).
- Training records with date, content and signatures.
- Evidence of needs-based support: when which expertise was brought in, for what occasion, and with what result. This is the record most often missing in practice, because the advice was given by phone and nobody wrote it down.
- First-aid organisation and inspection records for electrical equipment.
That last point is the critical one: without evidence of expertise being brought in, the second component of the model cannot be demonstrated. Formally only the training remains, and the model counts as not fully implemented.
A realistic cost comparison
On paper the model saves money because no ongoing support is paid for. An honest calculation sets the actual items on both sides against each other. We deliberately give no figures here, because course fees and hourly rates vary considerably by region; put in your own numbers.
- Unternehmermodell: course fee plus your working time for the training, then ongoing time for the risk assessment, training sessions and documentation, plus a fee for needs-based advice on every occasion. On top of that, refresher training on the prescribed cycle.
- Standard support: support hours under support group III, meaning 0.5 hours per employee and year for specialist and physician combined, plus business-specific support and the initial effort in year one. Your own time is limited to appointments and approvals.
For a business with 30 employees that works out at 15.0 hours of basic support per year under standard support. Anyone choosing the Unternehmermodell has to estimate honestly whether they can handle the equivalent workload in less than that time, including getting to grips with the regulations. Your own figures come from the support-hours calculator; the cost logic is explained in What does an occupational safety specialist cost?.
When the model holds up and when it does not
There are situations in which the model works well, and others in which it regularly fails.
- Holds up well: a manageable business at the lower end of the range, stable premises and activities, one person in management who genuinely takes the topic on and has the time for it, little staff turnover.
- Holds up badly: growth towards the 20 or 50 threshold, frequent relocations or refurbishments, distributed sites, extensive remote work, high turnover, or a management calendar that experience shows will push the topic back.
The most common failure in practice is not a deliberate decision against occupational safety but a lack of time: the training was attended, the risk assessment never updated, the training session in year two forgotten. When a letter from the employers' liability insurance association then arrives, the underlying evidence is missing, and the model becomes expensive in retrospect.
Three common misconceptions
- "Under the Unternehmermodell I do not need an occupational physician." Wrong. Occupational health support does not disappear, it is simply organised on a needs basis. Occupational health screening remains mandatory wherever it is prescribed.
- "The training is valid indefinitely." Wrong. Attendance must be refreshed at regular intervals. Miss the cycle and you no longer formally satisfy the first component of the model.
- "Below 50 employees not much applies anyway." Wrong. The occupational safety committee already applies above 20 employees, regardless of the support model (safety officers in a classic office only from 50).
Switching to standard support
The transition does not happen by itself. When your business crosses 50, you have to act: appoint the specialist and the physician in writing, define and document the scope of support, and hand over the records you kept yourself.
Two habits stop you missing the switch. Check your headcount against the thresholds of 20 and 50 deliberately once a year. And where growth is foreseeable, switch early rather than crossing the line and then carrying a gap in the documentation that cannot be closed retrospectively.
Safety Club takes this work off your hands, including for small offices: an occupational safety specialist on site plus digital, audit-proof documentation in a single contract. How getting started works is set out in the four-step process.
This article is general guidance and does not replace legal advice on your individual case. What governs is the current version of the ASiG and DGUV Regulation 2, together with how your employers' liability insurance association (Berufsgenossenschaft, BG) interprets it.
