The Occupational Health And Safety Training Regulation Has Been Amended! What Innovations Does The 2026 Regulation Introduce?

1. NEW DEFINITION: CLASS PERIOD (LESSON HOUR)
 

Whereas in the former Regulation the duration of education was determined in terms of "hours," the new Regulation introduces the concept of a "class period (lesson hour)." Accordingly, a class period is defined as a unit of time consisting of at least forty-five minutes of instruction and a fifteen-minute recess break, thereby providing significant clarity for practical implementation.
 

2. RECOGNITION OF TRAINING TIME AS OVERTIME

The principle that training time counts as working time is preserved; however, the new Regulation explicitly clarifies that periods exceeding weekly working hours shall be considered overtime.
 

• Former Regulation (Art. 8/1): "Time spent in training is considered working time."

• New Regulation (Art. 5/6): "Time spent in occupational health and safety training shall be deemed working time. Where such training exceeds weekly working hours, it shall be considered as overtime or work exceeding normal working hours."
   

3. EMPLOYEE OBLIGATIONS HAVE BEEN EXPANDED
 

Under the new regulation, employees' obligations regarding occupational health and safety training have been broadened and are defined as follows: to participate in the training program, to attend regularly, to exercise due care and diligence, to take part in assessment and evaluation processes, and to apply the knowledge acquired in workplace practices.
 

4. INDUCTION TRAINING: A REQUIREMENT FOR IN-PERSON AND PRACTICAL DELIVERY HAS BEEN INTRODUCED AND ITS SCOPE HAS BEEN EXPANDED
 

While the former Regulation allowed a degree of flexibility regarding the method of induction training, the new Regulation establishes "face-to-face" delivery as a strict requirement.
 

• Former Regulation (Art. 6/2): "Induction training ... shall be provided in a practical manner. Induction training shall be organized for a minimum of two hours for each employee."
   

• New Regulation (Art. 7/3): "Induction training shall be delivered face-to-face and in a practical manner, in such a way as to ensure the employee's protection against hazards and risks."
   

The "face-to-face" requirement introduced by the new Regulation aims to prevent training from remaining merely formal or on paper.
 

Furthermore, under the new regulatory framework, the scope of induction training has been expanded, and the phrase "risks arising from the working environment" has been expressly incorporated in order to broaden the scope.
 

5. DEFINITE TIME LIMIT FOR COMPLETION OF BASIC TRAINING
 

While the former Regulation did not provide clarity regarding the time frame for completion of basic training, the new Regulation introduces a definitive time limit of three months in order to eliminate uncertainties in practice.
 

• Former Regulation (Art. 6/1): "The employer shall ensure that occupational health and safety training is provided to employees, covering at least the subjects specified in Annex-1."
   

• New Regulation (Art. 8/1): "The employer shall ensure that all basic training is completed as soon as possible after the employee commences work... However, in any case, this period shall not exceed three months from the date the employee starts work."
   

This definitive time limit eliminates debates in practice regarding what constitutes a "reasonable period" and establishes an objective, verifiable, and legally certain criterion for determining whether the employer has fulfilled its training obligations in a timely manner.
 

6. LIMITATION OF THE DURATION OF REFRESHER TRAINING
 

Under the former regulation, there was no time limitation for refresher training; however, under the new regulation, it has been set at eight hours.

• New Regulation (Art. 14/2):"The repetition of basic training shall be arranged for a minimum of eight lesson hours for all workplaces classified as less hazardous, hazardous, and highly hazardous. In such training, the fourth topic specified in Annex-1 shall be delivered in accordance with the training method set out in Article 12, paragraph three, and within the durations specified in Article 13, paragraph three."
   

7. SPECIFICATION OF SUBJECT MATTERS, CONTENT, AND REQUIREMENT OF CONCRETE DATA FOR BASIC TRAINING
 

Unlike the former Regulation, the new Regulation introduces a separate provision governing the subject matters of basic training and, in particular, mandates that, for hazardous and very hazardous workplaces, the training content must be based on the workplace's own risk documentation rather than on general information.
 

• Former Regulation (Art. 11/2): "The distribution of training durations... shall be determined on the basis of the activities carried out in the workplace."
   

• New Regulation (Art. 9/4, 5):(4) "For workplaces classified as hazardous and very hazardous, the content of the fourth subject heading set out in Annex-1 shall be prepared in a manner specific to the job and workplace, taking into account the workplace's risk assessment document, emergency plan, explosion protection document (if any), and other documents prepared within the scope of occupational health and safety legislation."
   

(5) "For workplaces classified as less hazardous, the content of the fourth subject heading set out in Annex-1 shall be prepared to include the general hazards and risks of the activity (such as working at height, falling from height, working in confined spaces, fire, and working with equipment involving special risks). In this case, the employer's obligation to inform employees about potential health and safety risks in the workplace and the related protective and preventive measures shall remain reserved."
 

This provision renders the "workplace-specific nature" of training a legal obligation. In judicial proceedings following a workplace accident, whether the training provided covered the hazards identified in the existing "Risk Assessment" will be subject to expert examination in accordance with this provision.
 

8. TECHNICAL CRITERIA AND RESTRICTIONS IN REMOTE TRAINING
 

The new Regulation has restricted remote training in hazardous occupations and introduced technical requirements designed to prevent practices-such as fast-forwarding, skipping between sections, or closing the training window-that could adversely affect the effectiveness of the system.
 

• Former Regulation (Art. 15/A): Remote training was provided as a general option, with more flexible technical criteria.
   

• New Regulation (Art. 12/3): "In workplaces classified as hazardous and very hazardous, [the fourth subject heading covering job-specific risks] shall be delivered face-to-face."
   

• New Regulation (Art. 12/5): "It shall be mandatory for the system to prevent practices that may negatively affect the effectiveness of the training, such as fast-forwarding, switching tabs, or closing windows, and to support the active participation of the employee through pop-up windows."
   

The obligation to incorporate pop-up features and to prevent fast-forwarding reflects the digital equivalent of the requirement for "active engagement" in training.
 

9. SIGNIFICANT LIMITATIONS REGARDING TOPICS IN BASIC TRAINING DURATIONS
 

The fourth topic title in the table of training subjects, arranged as Annex-1 under the new regulation, has been determined at the minimum level in terms of hazard class.
 

• New Regulation (Art. 13/3):"The time allocated to the fourth topic set out in Annex-1 shall not be less than two lesson hours for workplaces classified as less hazardous, three lesson hours for those classified as hazardous, and four lesson hours for those classified as highly hazardous, within the total duration of basic training."
   

10. NARROWING OF THE SCOPE OF REFRESHER TRAINING
 

For employees who have been absent from work for more than six months, the training obligation has been eased by focusing solely on job-specific risks.
 

• Former Regulation (Art. 6/6): "Employees who have been absent from work for more than six months... shall be provided with refresher training."
   

• New Regulation (Art. 18/1): "Employees who have been absent from work for more than six months... shall be provided with refresher training limited to the fourth subject heading of Annex-1 (relating to job-specific risks).
   

11. INTRODUCTION OF THE "60-POINT THRESHOLD" AND "THREE ATTEMPTS RULE" IN ASSESSMENT AND EVALUATION
 

While the former Regulation left the success criteria to the employer's discretion, the new Regulation introduces a concrete threshold for successful completion.
 

• Former Regulation (Art. 12/6): "At the end of the training, measurement and evaluation shall be carried out. Based on the evaluation results, it shall be determined whether the training has been effective; if necessary, changes shall be made to the training program or trainers, or the training shall be repeated."
   

• New Regulation (Art. 16/3): "Participants who score at least sixty out of one hundred in the examinations shall be deemed successful. Participants who fail the first examination may take the relevant examination up to two additional times. Those who fail these examinations shall be required to attend the basic training again."
   

12. EXPRESS IMPOSING OF THE RESPONSIBILITY TO PROVIDE TRAINING TO APPRENTICES AND INTERNS ON THE EMPLOYER
 

While the former Regulation did not contain an explicit provision on this matter, the new Regulation clearly stipulates that the obligation to provide training to apprentices and interns rests with the employer at the workplace where practical training is carried out. However, it also provides that, subject to the employer's acceptance, occupational health and safety courses or trainings completed by apprentices and interns at their educational institutions may be deemed to substitute for basic training.
 

• New Regulation (Art. 21): "The employer of the workplace where practical training is carried out shall be responsible for the training and information of apprentices and interns. However, subject to the employer's acceptance, occupational health and safety courses or trainings completed by apprentices and interns at the educational institution they attend shall be deemed to substitute for basic training."
   

13. ACCESSIBILITY AND DIGITALISATION (E-SIGNATURE)
 

The new Regulation introduces provisions aligned with modern standards regarding accessibility for employees with disabilities and digital record-keeping.
 

• Accessibility (Art. 20/1): "Training for employees with disabilities shall be provided in accordance with accessibility standards and shall include alternative formats that meet the needs of such employees."
   

• Electronic Signature and Archiving (Art. 26/1): "Documents prepared within the scope of this Regulation may be signed in accordance with the Electronic Signature Law No. 5070 and may be prepared and archived in electronic environments."
   

Allegations that training documents are prepared retrospectively are frequently encountered in practice. The use of electronic signatures and digital archiving will facilitate the employer's burden of proof by ensuring the authenticity and time-stamping of such documents.
 

CONCLUSION AND ASSESSMENT
 

The new Regulation dated 2026 aims to transform occupational health and safety training from a mere "document completion" exercise into a "measurable safety culture." In the new era, establishing the proper balance between digitalisation and face-to-face training will be of critical importance in determining the allocation of liability in potential workplace accidents and occupational diseases.