Law 5239/2025 introduced, among other amendments, changes to Articles 504 and 507 of Presidential Decree 62/2025 concerning the instructions issued by the Occupational Physician and the Technical Safety Officer.
Under the new framework, both the Technical Safety Officer and the Occupational Physician are required to record their written instructions in a special book maintained by the undertaking. This book is now kept electronically through the Integrated Information System of the Labour Inspectorate (OPS-SEPE). Accordingly, the relevant instructions are no longer recorded in a special physical book maintained at the undertaking, which was previously required to be page-numbered and certified by the Labour Inspectorate. The employer is required to formally declare that they have taken note of the instructions recorded in the electronic book.
The procedure and method for the electronic maintenance of the Book of Instructions of the Technical Safety Officer and the Occupational Physician through the Integrated Information System (OPS) of the Labour Inspectorate, as well as any other matter relating to the implementation of Articles 504 and 507 of the Labour Code (Presidential Decree 62/2025), have been laid down by the recently issued Ministerial Decision No. 25548 (Government Gazette, Series II, No. 5833/28.09.2026).
For each undertaking (establishment/vessel), an electronic special Book of Instructions is created and maintained through the electronic service entitled «Book of Instructions of the Technical Safety Officer and Occupational Physician» available on the OPS of the Labour Inspectorate. The electronic book is maintained separately for each category of person making the entry (Technical Safety Officer or Occupational Physician) and contains a chronological list of entries (instructions).Each entry is associated with the following information, a) the person making the entry (Technical Safety Officer or Occupational Physician), b) the External Prevention and Protection Services Provider (EXYPP), where the services of the Technical Safety Officer and/or Occupational Physician are provided through an EXYPP, c) the date of the visit of the Technical Safety Officer and/or Occupational Physician to the undertaking, d) the date on which the instructions were recorded, e) the category or categories of instructions, where applicable and f) the date and time on which the employer acknowledged receipt and took note of the instructions.
The Technical Safety Officer or Occupational Physician records each instruction through their personal account on the electronic services of the OPS of the Labour Inspectorate.
Where the services of the Technical Safety Officer and Occupational Physician are provided by an EXYPP or ESYPP, the instructions are issued by the Technical Safety Officer or Occupational Physician on behalf of the respective EXYPP or ESYPP.
The employer is notified of each recorded instruction through a notification in their account on the electronic services of the OPS of the Labour Inspectorate, accompanied by a corresponding email notification.
Once an instruction has been finally submitted and recorded, its content may neither be amended nor deleted. Where an instruction requires correction or supplementation, the Technical Safety Officer or Occupational Physician who has an active assignment of duties, either with the same or with a cooperating EXYPP, creates a new entry/record of the type «clarification/supplementation», which expressly refers to the relevant original instruction.
The employer then proceeds to «Acknowledgement of receipt». Both the original and the new entry remain available in the electronic record and history.
In the event of a violation of the provisions of the recent Ministerial Decision, both administrative and criminal sanctions may apply.