NEW OCCUPATIONAL HEALTH AND SAFETY TRAINING REGULATION: KEY INNOVATIONS AND CHANGES COMPARED TO THE PREVIOUS REGULATION

The Regulation on the Procedures and Principles of Occupational Health and Safety Training of Employees (the “Regulation”) published in the Official Gazette dated 2 April 2026 and numbered 33212, together with the “Guide on Occupational Health and Safety Training of Employees” (the “Guide”), introduces significant changes regarding the structure, scope, duration and implementation of occupational health and safety trainings. The new framework aims to eliminate uncertainties encountered in practice and to establish a clearer and more enforceable system, particularly in relation to training obligations, documentation requirements and the legal consequences of such trainings.

One of the most notable changes is the establishment of induction training (in Turkish, “İşe başlama eğitimi”) as a separate and explicit obligation. Accordingly, all employees, including apprentices and interns, must receive induction training before commencing work. This training must be delivered face-to-face, include workplace-related risks and be properly documented through signed records retained in the employee’s personnel file.

Employers are also required to complete basic occupational health and safety trainings within three months following the employee’s commencement of work, introducing a clear timeline.

Another key development is the introduction of the concept of a “lesson hour” (in Turkish, “Ders saati”), defined as at least 45 minutes of training followed by a 15-minute break.

The Regulation further clarifies that time spent in occupational health and safety trainings shall be considered as working time and may qualify as overtime if it exceeds weekly working hours.

With respect to refresher trainings (in Turkish, “Yenileme eğitimi”), a minimum duration of eight lesson hours has been introduced for all hazard classes. Employees who have been absent from work for more than six months are required to receive training before returning to work, within a limited scope.

The Regulation also requires that training content be tailored to the specific characteristics of the workplace, thereby restricting the use of standardized training materials.

The rules governing remote training (in Turkish, “Uzaktan Eğitim”) have been clarified. Certain trainings may be delivered remotely, face-to-face or in hybrid form, whereas others must be conducted exclusively face-to-face in hazardous and very hazardous workplaces. In addition, remote training systems must ensure active participation and prevent the fast-forwarding of training content.

Another significant change concerns the assessment system. Employees must achieve a minimum score of 60 out of 100 in post-training examinations. In case of repeated failure, the training must be retaken, reflecting a shift to a success-based model.

Employee obligations have also been expanded. Employees are required not only to attend trainings but also to actively follow them, participate in assessment processes and apply the knowledge acquired in practice.

The Regulation further introduces additional requirements, including accessibility standards for trainings provided to disabled employeesand the obligation for employers to prepare annual training programs.

The Regulation introduces a clearer, more structured and traceable framework for documentation processes. In this respect, it is explicitly stipulated that, for face-to-face basic trainings, records must be prepared including the location, date, duration, subject matters covered, as well as the details of participants and trainers. For remote trainings, participation is required to be electronically monitored and recorded through the relevant systems. Furthermore, it is mandatory to issue certificates for employees who successfully complete the basic training and to retain such certificates in the employees’ personnel files.

Finally, the Regulation introduces provisions on electronic signatures and digital archiving, allowing training-related documents to be signed and stored electronically.

In light of the above, employers are required to review their training practices, align their systems with the new framework and ensure compliance.

Our Law Firm remains at your disposal for any further clarifications you may need.

Copyright © 2026 Cailliau&Colakel Attorney Partnership, All rights reserved.