Germany Mandates Doctor’s Note From First Sick Day, Imposes New Workplace Health Obligations
04.07.2026 - 01:24:00 | boerse-global.de
Record absenteeism is forcing German companies to rethink their approach to employee health. The federal government passed a sweeping reform package in early July that tightens sick-leave rules and expands occupational health requirements—changes that both employers and doctors must now navigate.
The DAK health insurance fund calculated that the average worker missed 19.5 days in 2025, a historic high. Those absences add up: the Federal Institute for Occupational Safety and Health (BAuA) recorded more than 700 million workdays lost annually, costing the economy roughly €85 billion in lost output. Chancellor Merz described the sick rate as a “competitive disadvantage.”
Under the new rules, employees must submit a medical certificate from the very first day they call in sick—a sharp break from the previous threshold, which only required a doctor’s note after the fourth day. The controversial phone-based sick note is being scrapped entirely. Labour-law experts stress that the certificate does not have to land on the employer’s desk on day one, but it should be provided promptly. A retroactive sick note remains possible for up to three days.
Doctors’ associations and health insurers have pushed back, warning that the change risks overwhelming already strained medical practices. The government’s answer: expanded video-consultation options and a new system of partial sick notes, letting workers be certified unfit for 25, 50, or 75 percent of their duties.
These sick-leave measures are only one plank of a 34-point program. The package also simplifies dismissal protection for top earners (monthly income above €15,000) and tightens employer obligations across the board.
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Company doctors from the first hire
Any business that employs at least one person must now appoint a company doctor. The physician’s duties include advising on risk assessments, conducting preventive check-ups, and inspecting workplaces. Costs vary widely: the “entrepreneur model” runs between €150 and €500 a year, while outside occupational health services can charge €600 to €2,500. Ignoring the requirement can trigger fines of up to €25,000.
The occupational health regulation (ArbMedVV) itself is being reorganised into three clear tiers. Mandatory screening applies when workers handle hazardous substances or do wet work for more than four hours daily. Offered screening compels employers to actively propose check-ups for employees who work at screens or on night shifts. Requested screening lets any worker seek a doctor’s appointment if they feel health concerns linked to their job. Violations cost companies up to €5,000 per case. Employers pay all costs and receive only a certificate confirming the check-up took place—medical diagnoses stay private.
Ergonomics and vaccination take centre stage
Physical strain remains a priority beyond the paperwork. For jobs that involve manual pushing and pulling of loads, the BAuA recommends using the “key indicator method” to assess risk. When scores exceed certain thresholds, the load is considered significantly elevated and employers must intervene. Young workers and pregnant employees enjoy stricter limits under the Youth Employment Protection Act and the Maternity Protection Act, respectively.
The Standing Committee on Vaccination (STIKO) has also updated its 2026 recommendations, now including specific vaccine guidance for professions involving animal contact or travel to high-risk regions—a topic increasingly raised during occupational health consultations.
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The reform leaves companies with a clear message: adapt to tighter documentation and preventive care, or face fines that can quickly add up. For employees, the biggest change is the loss of the phone-based sick note and the return to the GP’s waiting room on day one.
