Two legal areas

For video appointments, two services must be distinguished. The first is occupational health care under the Occupational Safety Act (ASiG) and DGUV Regulation 2: advice, workplace inspections, help with the risk assessment and taking part in the occupational safety committee (ASA). The second is the occupational health check-up under the ArbMedVV. § 6 of DGUV Regulation 2 applies to the first, the occupational medicine rule AMR 3.4 to the second. Whether a digital share of advice is permitted in the care contract says nothing about whether a check-up appointment may take place by video.

Digital parts of care

§ 6 para. 1 of the model text of DGUV Regulation 2 requires care to be provided in person as a rule, personally by the occupational physician and the occupational safety specialist; it cannot be digital if there are factual reasons that require presence in the company. In standard care under Annexes 1 and 2, up to one third of services can be digital under § 6 para. 2 if the company is known from an initial site inspection and the conditions are met; the accident insurance institution may allow a higher share of up to 50 percent. In alternative care, the business owner decides on the basis of their risk assessment. Digital services must be documented in the report. Advice, meetings and taking part in the occupational safety committee are suitable for video; workplace inspections are not.

Telemedicine check-ups under AMR 3.4

AMR 3.4 was published on 27 January 2026 and amended on 28 July 2026. It provides the following. The first mandatory or offered check-up for employees in the company is an in-person appointment. The same applies to every further reason for a check-up that is triggered in the company for the first time, and to the first check-up after a change of occupational physician. Further check-up appointments, especially advisory conversations without a need for examination, can take place by telemedicine (video) if this is medically justifiable in the individual case. A first check-up on request (Wunschvorsorge) can take place by telemedicine.

Requirements and employees’ rights

Before a telemedicine check-up, the employee must be informed about its particularities, including that they can ask for an in-person appointment; this request must be met. Employer and occupational physician agree whether the conditions in the company are met: undisturbed, confidential rooms on both sides, suitable means of communication, and information about the workplace conditions. Examinations such as a hearing test or lung function test can be delegated to qualified non-medical staff on site; medical responsibility remains. If a need for examination arises during the appointment, an in-person appointment is held later; the certificate is issued only after that. A general telemedicine check-up for all employees without an individual assessment is not permitted.

Data protection and records

Medical confidentiality applies regardless of the means of communication. The media used must ensure confidential transmission; AMR 3.4 refers to the requirements of the National Association of Statutory Health Insurance Physicians (Kassenärztliche Bundesvereinigung) for telemedicine services and to the guidance of the German Medical Association (Bundesärztekammer). The decision for a telemedicine appointment and its reasons are documented.

Decision for each service

For every enquiry, we clarify whether it concerns advice, a risk assessment, a workplace inspection, a check-up or a fitness-for-duty assessment. We carry out advice, surveys and training nationwide by video. Workplace inspections, fitness-for-duty assessments and the first mandatory or offered check-up take place in the company; follow-up check-ups are possible by video only within the limits of AMR 3.4. An overview of the rules for check-up appointments is in the article Mandatory check-ups, offered check-ups and check-ups on request.