Occupational safety and health records are not a formality — they are the evidence that the obligations have actually been met. During an inspection, the question "does the employer keep records in accordance with the law" is a separate item on the official checklist, and failing to keep them is a standalone offence. The obligations come from two different acts and are easily confused, so what each requires is separated out below.
Two acts, two sets of records
The Occupational Safety and Health Act (Official Gazette of RM no. 92/07 as subsequently amended, most recently in Official Gazette of RNM no. 74/25) prescribes in Article 37 the records relating to safety itself — training, inspections, measurements, health and injuries.
The Act on Records in the Field of Labour (Official Gazette of RM nos. 16/2004, 102/2008, 17/11, 166/12 and 147/15, and Official Gazette of RNM nos. 18/20 and 86/25) prescribes the employment-relationship records — employees, wages, staffing needs, strikes, and separately the workplace injury register.
A workplace injury is the point where the two acts meet: it is reported under the OSH Act within 48 hours, and entered into the register under the Act on Records in the Field of Labour.
Records under Article 37 of the OSH Act
The employer must keep records of:
- Specialist training and competence of employees for safe work — the training programme, lists of trained persons, minutes of the theoretical and practical assessment, and the three-yearly competence checks for workplaces with increased danger.
- Inspections carried out on work equipment — reports from inspections and testing of machines, appliances and tools, with findings on their condition.
- Testing performed on physical, chemical and biological hazards and on microclimate in the working and ancillary premises, or at the workplaces. This includes microclimate measurements from both the summer and the winter period.
- Pre-employment and periodic health examinations of employees — referrals and reports from the authorised health institution.
- Occupational diseases, work-related illnesses, workplace injuries and fatalities at work.
Under Article 37(2), the records also contain all technical documents, instruments, reports, findings and opinions. That means the records folder is not merely a table of signatures — it is the body of source documents proving the position: certificates, measurement reports, minutes, expert opinions.
The manner of keeping the records is prescribed by the minister in a rulebook (Article 37(3)); under the amendment published in Official Gazette of RNM no. 74/25 that power, and the adoption of OSH secondary legislation generally, passed to the Minister of Economy and Labour (the amended Article 47).
The substance of the obligation does not depend on that rulebook — it is set by Article 37 itself, and that is the yardstick during an inspection. The question on the State Labour Inspectorate's checklist reads "Does the employer keep records in accordance with the law": what is checked is whether the five records exist and whether they lead to the source documents, not the appearance of the form, which the employer designs through its safety professional.
Records under the Act on Records in the Field of Labour
| Record | Basis | Who keeps it |
|---|---|---|
| Register of employed workers | Article 7 | the employer |
| Register of staffing needs | Article 12 | the employer |
| Wages register | Article 20 | the employer |
| Register of workplace injuries to workers | Articles 23 and 24 | the employer |
| Strike register | Article 28 | the employer, with submission to the union and the State Statistical Office |
| Register of beneficiaries of disability insurance rights | Article 49 | the employer |
For the injury register the Act distinguishes two offences: failing to enter the required data in the register (Article 23) and failing to keep the register or failing to make entries within the prescribed deadline (Article 24). The second is penalised separately.
Who keeps and who holds the documentation
The employer bears the obligation. Engaging an authorised legal or natural person does not transfer liability — this is expressly stated in Article 6(4) of the OSH Act.
The occupational safety professional prepares the data: they draw up the technical basis for the safety statement, carry out regular and follow-up inspections, monitor and analyse injuries and prepare reports for the employer with proposed safety measures (Article 19).
The authorised health institution keeps separate records and collects data on employee health under health-sector regulations (Article 20). There is an important data-protection detail here: under the Decree on the type, manner, scope and price list of health examinations (Official Gazette of RM no. 60/2013), the examination report is drawn up in three copies, and the copy going to the employer does not contain the sections with the opinion on the state of health and the recommendations for the employee. The employer receives information on fitness for work, not a medical diagnosis.
The employee representative has the right of access to the safety assessment statements, to the reports and to other documents relating to the planning and organisation of OSH (Article 30). The records under Article 37 must be presented to employees and their representatives (Article 27(2)).
Retention periods
The Occupational Safety and Health Act sets no general retention period for the records under Article 37. The only express period in the Act concerns the authority rather than the employer: personal data in the register of issued offence and fixed-penalty orders is kept for five years from the date of entry (Article 54-а(3)).
In practice the following rule applies: documentation is retained at least for as long as the risk it relates to persists. A workplace measurement report is relevant until a new measurement is taken; evidence of training — for as long as the employee works at that workplace.
Where the regulation intended an express period, it is a long one. The Rulebook on minimum safety and health requirements for employees exposed to risks from asbestos at work requires the register of exposed employees and the individual files to be kept for at least 40 years after exposure ends; if the employer ceases to exist, the documents are handed to the competent authority (Article 20).
The same logic applies in pension insurance: documentation for the master records at the Pension and Disability Insurance Fund is kept for at least 30 years, and for persons who did not acquire a right — at least 40 years (Article 211 of the Pension and Disability Insurance Act). This is why evidence of a workplace injury is not discarded.
Otherwise the framework is archival — the Archival Materials Act and the Decree on office and archival operations (Official Gazette of RM no. 1/14, amended in Official Gazette of RNM no. 252/23), which expressly recognises an electronic document certified with an electronic signature. Records may therefore be kept electronically.
What the 2020 and 2025 amendments changed
The 2020 amendment (Official Gazette of RNM no. 18/20) completely reworked the offence provisions of the Act on Records in the Field of Labour and changed the logic of how an inspector proceeds:
- fines were graded by the size of the employer — for failing to keep the basic records, EUR 200 to 400 for a micro and small employer, EUR 300 to 600 for a medium one and EUR 600 to 1,000 for a large one;
- an obligation was introduced for the inspector to issue a warning first, with a deadline for remedy, and only if the irregularities are not remedied by that deadline — to issue an order by decision;
- the State Labour Inspectorate was designated as the competent supervisory authority, with a duty to issue an offence payment order before offence proceedings; if the fine is paid within eight days, half the amount is payable;
- Article 58 of that act was deleted.
The 2025 amendment (Official Gazette of RNM no. 86/25) is institutional, but it matters in practice for where you turn: the competences held by the state administration body responsible for labour affairs passed to the Ministry of Economy and Labour (Articles 50, 53, 54 and 55), and the names were aligned with the institutions' new names — the Health Insurance Fund of the Republic of North Macedonia and the Pension and Disability Insurance Fund of North Macedonia.
The same shift in competence was brought by the amendment to the Occupational Safety and Health Act (Official Gazette of RNM no. 74/25), under which OSH secondary legislation is adopted by the Minister of Economy and Labour.
Penalties for incomplete records
| Offence | Micro and small | Medium | Large |
|---|---|---|---|
| Failing to keep records under Article 37 of the OSH Act (category I) | €200 – 300 | €300 – 400 | €400 – 600 |
| Failing to keep basic records under the Act on Records in the Field of Labour | €200 – 400 | €300 – 600 | €600 – 1,000 |
| Failing to keep the injury register or to make entries on time | €150 – 200 | €250 – 400 | €600 – 800 |
All amounts are in euro in denar equivalent. The responsible person within the legal entity is fined separately.
A practical minimum for a company
A map of the documents you should have ordered and available during an inspection:
- a safety statement with a risk assessment for every workplace, with an opinion from the union or the representative;
- the act appointing an OSH professional and their certificate;
- the training programme and minutes of the OSH training delivered;
- reports from workplace environment measurements and from testing of equipment and machinery;
- an evacuation plan and records of the drills;
- referrals and reports from health examinations;
- the workplace injury register and copies of the notifications to the Inspectorate;
- internal OSH rulebooks setting the intervals for inspections and testing.
How we can help
We set up the entire records framework — from the safety statement to the forms for each of the five records under Article 37 — and keep it current through the regular measurements, testing and training. If you are not sure what you are missing, request a quote and we will review the documentation you already have.
This article is informational and does not replace professional advice. Regulations change — last updated: August 2026.
This article is informational and does not replace professional advice.
