An overview of HSE’s RIDDOR consultation

Introduction

The HSE has launched a consultation seeking stakeholder views on the legislative and non-legislative proposals for The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR) summarised below:

Legislative

• Clarify definitions in Regulation 2 of RIDDOR and associated guidance, where certain terms such as “work-related”, “injury” and “routine work” have been identified as unclear or ambiguous.  
• Revise the list of occupational diseases in Regulation 8 of RIDDOR by reintroducing some diseases that were previously on the list and adding new diseases to ensure serious instances of ill-health are captured.
• Broaden the scope of accepted “diagnosis” in Regulation 2 of RIDDOR to allow the diagnosis of an occupational disease by other types of registered health practitioners, not just doctors who are registered and hold a license to practice with the General Medical Council (GMC).
• Revise the list of dangerous occurrences in Schedule 2 of RIDDOR by adding new categories and amending existing ones to reflect modern risks.

Non-legislative

• Improve the RIDDOR reporting process by simplifying the online form to reduce both under-reporting and over-reporting and improve overall usability. 

The objectives of the consultation are primarily to support HSE’s work to tackle ill health by expanding the data available to HSE, and to simply the reporting process to reduce the administrative burden on duty holders, improve compliance, and reduce under-reporting.

Proposal 1: Clarification of definitions in Regulation 2 of RIDDOR and associated guidance

HSE acknowledges that inconsistent reporting typically arises from varied interpretations of key terms and suggests this may result in over or under reporting. HSE points to a not insignificant 7,742 (8.2%) of all RIDDOR reports in 2024/25 that did not qualify as reportable. At face value, the disparity in 2024/25 work-related non-fatal injury statistics from the Labour Force Survey (680,000) and RIDDOR (59,219) offers support for under reporting. 

The consultation document identifies nine terms or issues that HSE proposes to address. The first, and arguably most important, is the term ‘work-related’. HSE reports that stakeholders consistently reported confusion about whether incidents qualify as work-related. 

Further clarification and examples within HSE guidance are proposed to remedy this confusion. 

Proposal 2: Revise the list of occupational diseases in Regulation 8 of RIDDOR

HSE considers the current list of occupational diseases does not adequately reflect modern workplace health risks and omits conditions where regulatory intervention could deliver meaningful benefits.

Following the Löfstedt Review in 2011, the list of reportable occupational diseases was significantly reduced from 47 to 6. Stakeholders have raised concerns that serious cases of occupational ill health are no longer consistently visible to regulators.

Evidence gathered through the 2018 and 2023 RIDDOR Post Implementation Reviews (PIRs) highlighted the need to broaden reporting in circumstances where regulatory action can provide meaningful benefits, where:

(a) there is a known risk/causal link arising between the diagnosed medical condition and a specific work activity or activities; 
(b) there are clear benchmark standards to prevent, control or mitigate that risk outlined in HSE or industry guidance;
(c) regulatory intervention may be required to ensure risk is adequately controlled. 

HSE therefore proposes to:

• Update the existing 6 reportable diseases; these diseases will continue to be reportable.
• Re-introduce 9 conditions that were reportable under RIDDOR 1995 but removed following the Löfstedt review. These re-introduced diseases are being brought back based on evidence that they remain prevalent and relevant. Non-compliance persists in certain sectors and the HSE position is that by re-establishing these diseases as reportable, it will create a more accurate baseline for occupational ill-health which can in turn enable better targeting of interventions.
• Add four diseases to the list where intervention can add strategic value. The list is set out in Table 2 of the Consultation paper. The diseases reflect emerging and modern risks, particularly those associated with new technologies and evolving industrial processes. 

While increased reporting is expected, HSE anticipates that improved national data quality will support better prevention strategies and long term health outcomes.

Proposal 3: Broaden the scope of accepted “diagnosis” for RIDDOR reporting purposes in Regulation 2 of RIDDOR

Currently under RIDDOR, only doctors holding a license to practice with the General Medical Council (GMC) can provide a diagnosis of an occupational disease. The consultation proposes broadening the pool of recognised professionals to include registered nurses and physiotherapists to make reporting more responsive and aligned with real world practice. 

Proposal 4: Updating the List of Dangerous Occurrences

HSE considers that the current list is outdated and does not adequately reflect emerging risk industries, as it is geared heavily towards traditional high-risk sectors. HSE therefore proposes to:

• Add new categories to the list; and
• Update existing categories to reflect modern technologies and risks.

This is intended to ensure the system captures emerging hazards in contemporary workplaces, especially as stakeholders’ informal engagement supported the view that important intelligence is being missed. 

The full list of proposed definitions can be found at Table 5 of the consultation.

Proposal 5: Improving the Reporting Process

The final proposal focuses on improving the RIDDOR submission process itself. HSE found that there are persistent and recurring issues surrounding RIDDOR submissions, ranging from the use of incorrect forms, misclassification of incidents, and submissions from individuals who are not responsible persons under the regulations.

HSE acknowledges that simplification is required to reduce errors, increase confidence in the system, and improve overall compliance.

Overall Impact

The proposals widen the net for reporting but aim to create a more modern, proportionate, and effective reporting framework. 

While there may be modest transitional costs – HSE estimates it would take businesses one hour to familiarise themselves with the changes to RIDDOR at a cost of £31 per business – costs are expected to be outweighed by long-term benefits such as clearer obligations, improved data quality, and enhanced prevention of workplace harm. 

Reforms intended to clarify and simplify reporting requirements will undoubtedly be welcomed by dutyholders in respects of increasing confidence in meeting their obligations and avoiding costly disputes with enforcement authorities that get it wrong.

Stakeholders are encouraged to participate in the consultation which closes on 30 June 2026. You can access the consultation via the HSE’s website here.