Can employees refuse a mandatory check-up?

Only the examinations, not the medical consultation. Taking part in the consultation is a condition for doing the work. Under § 2 (1) and § 6 ArbMedVV, physical and clinical examinations must not be carried out against the employee's will. Without a check-up, the activity must not be carried out.

Does the employer learn the result?

No. The employer receives the check-up certificate with occasion, date and next appointment. Only if the protective measures in the company are not sufficient does the doctor report this and propose measures.

Can every check-up take place as a video appointment?

No. Under AMR 3.4, the first mandatory or offered check-up in the company is an in-person appointment, as is the first check-up after a change of occupational physician. Later appointments can take place by telemedicine if that is medically justifiable. Employees can always ask for an in-person appointment.

Is a check-up that took place with a previous employer enough?

Yes, if the check-up concerns the same occasion and the deadline has not expired. A check-up certificate is tied to the activity, not to the employer, and can be taken into account by the new employer. The risk assessment of the new company and the AMR 3.4 rules on a change of occupational physician decide.

Mandatory, offered, requested check-ups

Three types of check-up

Occupational health check-ups under the Ordinance on Occupational Health Care (ArbMedVV) serve, under § 2 (1), to assess the interaction between work and health and to detect work-related health disorders early. They consist of a medical consultation with medical history, including work history, and, where needed for the consultation, examinations that the employee can decline. They do not include proof of fitness for duty.

TypeEmployer's dutyConsequence for employeesExamples from the Annex to the ArbMedVV Mandatory check-upArrange itAttendance is a condition for doing the workNoise at or above the upper action values (85 dB(A) or 137 dB(C)), wet work of regularly four hours or more a day, certain hazardous substances and biological agents, respiratory protective equipment of groups 2 and 3 Offered check-upOffer it and document the offerAttendance is voluntaryScreen work, noise above the lower action values (80 dB(A) or 135 dB(C)), wet work of regularly more than two hours a day, natural UV radiation from one hour a day, respiratory protective equipment of group 1 Check-up on requestMake it possible on requestAttendance is voluntaryAny activity where damage to health cannot be ruled out, § 5a ArbMedVV

For the noise values, the measured quantity matters: the daily noise exposure level and the peak sound pressure level respectively. The attenuating effect of hearing protection is not taken into account when applying the action values. An offered check-up is a duty of the employer. The offer must be made and documented, even if nobody accepts it. For screen work, this includes an examination of the eyes and vision. If the result shows that special eyewear for screen work is required and normal eyewear is not suitable, the employer must provide it.

Occasions from the Annex and the 2026 amendment

Which check-up applies to an activity follows from the risk assessment under § 5 of the Occupational Safety and Health Act (ArbSchG) and from the Annex to the ArbMedVV. The Annex was amended by the ordinance of 11 May 2026. The amendment mainly affects the hazardous-substance provisions in Part 1 of the Annex. Check-up plans drawn up before this amendment must be compared with the current version of the Annex for activities involving hazardous substances. The types of check-up themselves and the occasions noise, wet work, screen work and respiratory protection are unchanged. How the assignment works in a company is described in the article Determining check-up occasions in the company.

Deadlines under AMR 2.1

The occupational medicine rule AMR 2.1 sets maximum deadlines. The first check-up must be arranged or offered within three months before the activity starts. The second check-up follows at the latest after twelve months. For activities with substances that sensitise the airways or skin, with sensitising or toxic biological agents, and for wet work, it follows after six months. For activities in the tropics and subtropics, it follows after 24 months. Each further check-up is due at the latest 36 months after the previous one. Shorter deadlines are permitted and are required where medically necessary. The doctor notes the next appointment on the certificate. Where there are several occasions, the shortest deadline applies.

Check-up certificate and check-up register

Under § 6 (3) ArbMedVV, employees and employer receive a check-up certificate. It states that a check-up took place, when and on what occasion, and when the next one is advisable from a medical point of view. The employer learns nothing more. Findings and diagnoses are covered by medical confidentiality. If the check-up indicates that protective measures in the company are not sufficient, the doctor must inform the employer and propose measures. A change of activity for health reasons is only reported with the employee's consent.

Under § 3 (4) ArbMedVV, the employer keeps a check-up register stating that check-ups took place, when and on what occasions. It may be kept electronically, must be kept until the end of employment and must be shown to the authority on request. Employees receive an extract with their data when they leave. For certain carcinogenic hazardous substances, check-ups continue beyond the end of employment. The article Post-employment occupational health check-ups for hazardous substances describes this.

Telemedical check-ups under AMR 3.4

AMR 3.4 (occupational medicine rule) “Occupational health check-ups: digital applications and telemedical check-ups” was published on 27 January 2026 and amended on 28 July 2026. Under it, the first mandatory or offered check-up of employees in the company must be carried out as an in-person appointment. The same applies to every check-up occasion triggered for the first time in the company, and to the first check-up after a change of occupational physician. Further check-up appointments, especially advisory consultations without a need for examination, can take place by telemedicine if that is medically justifiable in the individual case. A first check-up on request can take place by telemedicine.

Employees must be informed in advance about the particulars and can ask for an in-person appointment at any time, which the employer must make possible. A general telemedical check-up for all employees without examining the individual case is not permitted. If it emerges during a telemedical appointment that an examination is needed, an in-person appointment must be made up. The certificate is issued only afterwards. The digital elements of care under DGUV Regulation 2 must be considered separately.

Distinction from the fitness-for-duty assessment

Under § 2 (1) ArbMedVV, check-ups do not include proof of fitness for duty. Fitness-for-duty assessments, for example for driving, control and monitoring activities, need their own basis and, under § 3 (3) ArbMedVV, should not be combined with check-ups. If operational reasons require a combination, the doctor must make the different purposes clear. Details are in the article Fitness-for-duty assessment and check-ups.

At the start of care, we assign each activity in the company to the occasions in the Annex and draw up the check-up plan from that. Under § 3 (3) ArbMedVV, check-ups take place during working hours. We combine several occasions in one appointment. We offer appointments at your company in the Ingolstadt, Munich and Upper Bavaria area. Telemedical appointments are offered only within the limits of AMR 3.4.

Mandatory, offered and on-request check-ups under the ArbMedVV