Screen-Work Checkups Are Voluntary for Employees—But German Employers Face Tight New Rules
02.07.2026 - 09:59:11 | boerse-global.de
A coalition of Germany’s 9,000 company doctors is pushing back against planned digital health legislation, demanding that they be granted opt-out access to the electronic patient record (ePA) rather than the opt-in procedure currently proposed. The move is part of a wider effort to align occupational physicians with other specialist groups under the country’s data and digital innovation in healthcare law (GeDIG), which came under scrutiny from professional associations in late June.
The DGAUM (German Society for Occupational Medicine) and VDBW (Association of German Company and Plant Doctors) jointly called for amendments to the draft bill, arguing that the current three-day access window is far too short. They want it extended to 90 days, and they also insist that occupational health data—not just ePA records—be included. Their goal: to elevate the quality of preventive advice for employees, including those who spend all day staring at a screen.
That screening workplace for visual strain and ergonomic risk is legally classified as “provisionary care” (Angebotsvorsorge), not mandatory screening. Under the Occupational Medical Care Ordinance (ArbMedVV) and the associated technical rule AMR 14.3, employers must identify the trigger for the examination, actively offer it, and document that offer. Workers are free to accept or decline. That voluntary character sets screen-work checks apart from compulsory exams tied to specific hazards like noise or chemicals.
Every such offer must rest on a proper risk assessment (Gefährdungsbeurteilung) under Section 5 of the Occupational Health and Safety Act. This assessment is compulsory for all employers, regardless of company size. The documentation duty, however, only kicks in when a firm has at least ten employees. Since 2013, that assessment must also include psychological stress factors. The process follows a structured seven-step model: from identifying hazards all the way to implementing measures, testing their effectiveness, and updating the evaluation.
Speaking of keeping risk assessments current—many employers underestimate the gaps in their workplace safety documentation. A free Risk Assessment Toolkit provides 41 ready-to-use templates and checklists covering everything from fire safety to lone working, helping you stay compliant and protect your team. Download the free Risk Assessment Toolkit
Technical checks are tied into the same framework. Inspection intervals for electrical equipment (DGUV V3), for instance, depend on the risk assessment. In most office environments, that translates to checks every 24 months.
Meanwhile, occupational medicine is quietly digitizing. A recent overview of digital information and communication technologies in the field notes that rules such as AMR 3.4 and guidelines from the German Statutory Accident Insurance (DGUV) now define the boundaries for telemedicine. Video consultations and digital triage are possible, but face-to-face care remains the gold standard. Data privacy, medical confidentiality, and the personal doctor–patient relationship take priority over purely digital solutions, according to current professional standards.
The political debate over ePA access is the sharpest front. Company doctors argue they are being treated as second-class practitioners. Without seamless access to patient records, they say, preventive consultations on workplace health—including screen-related vision problems—lose much of their value. The DGAUM and VDBW are now lobbying the health ministry to level the playing field before the GeDIG bill moves to its next reading.
