HSE Lauches Public Consultation on RIDDOR Reforms

On 7 April 2026, the Health and Safety Executive (‘HSE’) launched a public consultation on proposed reforms to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (‘RIDDOR’ or ‘the Regulations’).

RIDDOR is the legislative framework governing how workplace injuries, diseases, and specified Dangerous Occurrences are reported to the HSE. The objectives of the consultation are primarily to support HSE’s work to tackle ill health by expanding the data available, to simplify the reporting process to reduce administrative burdens, improve compliance, and reduce under-reporting. Businesses, employers, health practitioners and industry stakeholders have until 30 June 2026 to comment on the proposals.

Proposed Reforms

Proposal 1: Clarification of Definitions

HSE proposes providing further clarification and examples of ‘work-related’ incidents within guidance, and the addition of a definition of ‘injury’ within RIDDOR regulation 2.  The present position is that the definition of ‘work-related’ as ‘an accident arising out of or in connection with work’ is, according to HSE, widely misunderstood by duty holders, and ‘injury’ is undefined.

Understanding these terms is essential if duty holders are to fulfil their obligations under the Regulations. Confusion and an abundance of caution may prompt duty holders to report incidents that do not meet the threshold for RIDDOR reporting. In 2024 / 25, 7,742 (8.2%) of all RIDDOR reports did not qualify as reportable,¹ wasting valuable time and resources for duty holders and unnecessarily putting them on HSE’s radar. Conversely, misinterpretation can result in the under-reporting of incidents, exposing businesses to the risk of enforcement action. At face value, the disparity in 2024 / 25 work-related non-fatal injury statistics from the Labour Force Survey (680,000 of which 18% (122,400) resulted in over 7 days’ absence from work) and RIDDOR (59,219) offers some support for under reporting.

Proposal 2: Revise the List of Occupational Diseases

RIDDOR requires cases of certain specified diseases to be reported. 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 highlighted the need to broaden reporting in circumstances where regulatory action can provide meaningful benefits, where:

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

HSE proposes to expand the list of reportable occupational diseases from six to nineteen. Nine conditions previously removed would be reintroduced, including asbestosis and pneumoconiosis. The number of cases of asbestosis, for example, has increased substantially from 132 in 1978 to 905 in 2019.² Four new conditions would also be added, including noise-induced hearing loss and bronchiolitis. The expansion of the list would mean a substantial increase in reporting obligations, particularly for sectors like construction and manufacturing where the proposed additions are most prevalent. 

Of note is that work-related stress is not included in the expanded list of reportable occupational diseases. This exclusion is surprising considering HSE’s strategic objective of ‘reducing work-related ill health, with a specific focus on mental health and stress’, as set out in the ‘Protecting People and Places’, HSE’s ten year-strategy from 2022 to 2032. It appears at odds for HSE to set its focus on reducing work-related mental health issues but decline to require reporting by duty holders. The HSE has said that the exclusion of work-related stress from the expanded list of reportable occupational diseases is based on ‘wider organisational considerations’, with work-related stress being ‘difficult to define … in a way that allows for consistent and reliable reporting across sectors.’³  A diagnosis from a medical practitioner would surely provide a benchmark for work-related stress that would be consistent across sectors. 

Proposal 3: Broaden the Scope of Practitioners Who Can Diagnose Reportable Occupational Diseases

Currently, a report of a listed occupational disease is only required if a diagnosis is made in writing by a ‘medical practitioner’, i.e. a registered and licensed doctor. The consultation proposes broadening the pool of practitioners who can diagnose such diseases to include registered nurses and physiotherapists. This would make reporting more responsive and aligned with real world practice and reduce the practical barriers to affected individuals receiving a diagnosis from overstretched GPs.

Proposal 4: Revise the List of Dangerous Occurrences

Certain specified Dangerous Occurrences (incidents with a high potential to cause death or serious injury), must be reported. Examples include accidental contact between a vehicle and an overhead line and a structural collapse. The HSE proposes adding four new categories of dangerous occurrences that will be most relevant to the construction and demolition sectors. These new categories encompass:

• the falling of objects from structures under demolition or construction;
• the overturning of construction plant;
• the uncoiling and projection of material; and
• tunnelling activities.

As with the expansion of the list of reportable occupational diseases, the addition would result in a greater number of RIDDOR reports being submitted by duty holders.

Amendments would also be made to the existing list of Dangerous Occurrences to clarify and modernise existing provisions. For example, the HSE proposes to clarify that a ‘structural collapse’ includes the collapse of any roof, ceiling, temporary works and trench collapses. The definition of an ‘offshore installation’ would be amended so the provision applies to offshore marine and wind farms, while the definition of ‘wells’ would be broadened to include those exploited for geothermal energy, modernising and expanding the scope of reportable dangerous occurrences.

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

Taken together, the proposals would expand the RIDDOR reporting net. Duty holders should prepare for 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 – and should anticipate completing a greater volume of RIDDOR reports. However, these 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 duty holders in respect of increasing confidence in meeting their obligations and avoiding costly disputes with enforcement authorities.

Stakeholders are encouraged to participate in the consultation which closes on 30 June 2026. Comments can be provided by filling out the online survey on the HSE’s website here.

It is surprising that the HSE is not using RIDDOR reform as an opportunity to enhance its strategic objective of focusing on metal health and stress, by including work-related stress in the expanded list of reportable occupational diseases. If the HSE is serious about realising this objective, it would be sensible to require the reporting of incidences of work-related stress to allow the issue to be better monitored and addressed.

[1] HSE ‘Consultation on Proposals for The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013’,  p.25

[2] HSE ‘Asbestos-Related Disease Statistics, Great Britain 2025’, p.11

[3] HSE ‘Consultation on Proposals for The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013’, p.35