The HSE’s Proposed Reform and Expansion of RIDDOR: Implications for Dutyholders and their Insurers

In April 2026, the Health and Safety Executive (HSE) launched a public consultation proposing wide-ranging amendments to the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR). One of the most significant proposals is a substantial expansion of the list of reportable occupational diseases, reversing much of the restriction introduced in 2013.

For dutyholders and their insurers, these proposals have the potential to materially affect disease notifications and claims frequencies. Further, the introduction of greater reporting requirements increases the potential for breaches of RIDDOR, which can result in significant fines.

Under the current RIDDOR framework, employers are only required to report six specified occupational diseases:

1. Carpal Tunnel Syndrome
2. Cramp in the hand or forearm
3. Occupational Dermatitis
4. Hand Arm Vibration Syndrome
5. Occupational Asthma
6. Tendonitis/tenosynovitis of hand or forearm

The HSE now proposes expanding this list by reintroducing nine previously removed conditions and adding four new ones:

7. Pneumoconiosis (including silicosis but excluding asbestosis)

8. Decompression illness, pulmonary barotrauma and dysbaric osteonecrosis (DON)

9. Asbestosis

10. Hypersensitivity pneumonitis (e.g. farmers lung)

11. Cadmium related emphysema

12. Beryllium disease (skin and respiratory)

13. Chromium related ulceration

14. Knee and elbow bursitis

15. Oil folliculitis

16. Noise induced hearing loss

17. Bronchiolitis obliterans

18. Occupational allergic rhinitis

19. Occupational contact urticaria

The regulator has acknowledged that the reduction from 47 reportable diseases to six in 2013 improved administrative efficiency but may have resulted in serious work‑related ill health no longer being routinely brought to its attention. The HSE reports that the inclusion of these additional diseases will address emerging risks in the modern workplace.

Work-related stress (WRS) and suicide were considered in the internal review for inclusion however, at this time, is not being proposed. While WRS is a serious workplace issue, its exclusion from RIDDOR is based on wider organisational considerations. It is difficult to define WRS in a way that allows for consistent and reliable reporting across sectors.

For dutyholders and their insurers, the proposed expansion represents a likely increase in RIDDOR notifications, particularly in sectors with historic exposure profiles such as construction, manufacturing, extractive industries and heavy engineering.

In addition, the consultation proposes expanding who may formally diagnose a reportable occupational disease. Currently, diagnosis is limited to doctors registered with and licensed by the General Medical Council (GMC). The HSE proposes allowing diagnosis by other registered health practitioners, including occupational health nurses and physiotherapists.

How will this impact dutyholders and their insurers?

With the proposed changes leading to widening of the reporting net, there is the inevitable consequent risk of inadvertent non-compliance. This is particularly so for occupational disease, where there is often delayed onset of symptoms and causation is far from clear, making it more difficult to determine when the RIDDOR reporting threshold has been crossed.  This has significant implications for dutyholders, where a failure to comply with RIDDOR remains a criminal offence with penalties including significant fines and possible prosecution.

Further, although a RIDDOR report does not establish liability, it is frequently relied upon by claimant solicitors as contemporaneous evidence that an employer accepted a connection between work activities and the alleged disease. In practice, RIDDOR data is often pleaded to support breach of duty, causation, foreseeability and knowledge arguments.

For insurers, the HSE has indicated that the expanded list of reportable diseases is expected to generate a marked rise in disease reporting volumes. In the short to medium term, insurers may see an increase in disease notifications and letters of claim, particularly where RIDDOR reporting coincides with claimant solicitor marketing or union activity. In the longer term, enhanced RIDDOR reporting may assit in stemming frequency and or severity of the diseases reported, enhance disease data may improve trend analysis but is also likely to prompt renewed scrutiny of historic books, excess layers and reinsurance arrangements.

The expansion of those who can diagnose under RIDDOR is particularly significant. Earlier and more frequent diagnosis is likely to shorten the period between symptom onset and formal recognition of disease, increasing the likelihood of earlier claims presentation. It may also lead to an increase in claims where medical causation is less clear‑cut, particularly for low‑level exposure conditions affecting the skin, respiratory system and hearing.

The proposals raise important reserving considerations for insurers. Greater visibility of disease incidence may necessitate a reassessment of incurred but not reported assumptions, particularly for hearing loss, respiratory conditions and dermatitis portfolios.

The consultation closes on 30 June 2026. The HSE is particularly interested in hearing from dutyholders across all industries, self employed workers, health and safety professionals, occupational health and healthcare professionals and industry bodies.