DUERP 2026: France's mandatory workplace risk assessment
The DUERP in 2026: mandatory from the first employee, annual update (11+ staff), 40-year retention, PAPRIPACT and the still-postponed digital filing. The employer guide.
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Quick answer. The single occupational risk assessment document (DUERP) is mandatory for every employer from the first employee (articles L4121-3 and R4121-1 of the Labour Code). It must be updated at least once a year in companies with at least eleven employees, and on every notable change. Each version must be kept for at least forty years. The digital filing on a national online portal, provided for by the law of 2 August 2021, is still not operational in 2026: only internal retention applies for now.
The DUERP is the cornerstone of workplace prevention. Beyond the formal obligation, it is a risk-management tool that engages the employer's liability in the event of an accident. Here is where things stand in 2026.
What the DUERP is and who must keep it#
The DUERP transcribes, in a single document, the results of the assessment of risks to workers' health and safety (article R4121-1). The assessment covers each work unit: post, workshop, trade, situation.
The obligation applies to every employer, from the hiring of the first employee (article L4121-3). It is part of a safety obligation of result: the employer must not only assess but prevent. A missing DUERP, or a purely formal one, weakens the whole prevention chain and aggravates liability in the event of harm.
Update frequency: the 11-employee threshold#
The law of 2 August 2021 introduced a distinction by headcount:
| Headcount | Update obligation |
|---|---|
| At least 11 employees | At least once a year, and on every change |
| Fewer than 11 employees | On any significant change or new information about a risk (no systematic annual obligation) |
In all cases, the DUERP must be updated:
- on any major decision changing health, safety or working conditions;
- when additional information relevant to assessing a risk appears (a new process, a new product, the lessons of an accident).
Retention: at least 40 years#
Since the law of 2 August 2021, each successive version of the DUERP must be kept for at least forty years. The aim is to trace exposures, in particular for deferred risks (chemical, carcinogenic agents). The document, in its successive versions, must be made available to:
- exposed workers and former workers;
- the social and economic committee (CSE);
- the occupational physician and prevention services;
- the labour inspectorate and social security bodies.
Digital filing: provided for, but still postponed#
The 2021 law provided for digital filing of the DUERP on a national online portal, managed by employer organisations, on a staggered timetable (1 July 2023 for companies with at least 150 employees, 1 July 2024 for the others).
In 2026, that portal is still not deployed. The work ran into major difficulties: hosting documents for forty years, access authentication, protection of trade secrets, funding and maintenance. An IGAS report concluded that the cost-benefit balance was unfavourable, and new consultations were launched. In practice, the online filing obligation does not apply today: the employer must keep the successive versions internally, on paper or digitally. It is wise to anticipate a future portal by structuring dated, time-stamped archiving now.
PAPRIPACT and the action list#
The DUERP is not enough on its own: it must lead to prevention measures, whose formalisation depends on company size.
| Headcount | Follow-up document |
|---|---|
| At least 50 employees | Annual programme for the prevention of occupational risks and the improvement of working conditions (PAPRIPACT) |
| Fewer than 50 employees | List of prevention and protection actions, recorded in the DUERP and its updates |
The PAPRIPACT sets, for the coming year, the list of measures, their conditions, resources and a timetable. The DUERP and its updates are also presented to the CSE, which contributes to the assessment. Well-documented prevention also affects the cost of accidents and therefore the AT/MP rating.
Penalties and liability#
A missing or un-updated DUERP is punished by the fine for fifth-class offences (1,500 euros, 3,000 euros on repeat). But the real stake lies elsewhere: in the event of a work accident or occupational illness, a missing or inadequate DUERP is a decisive factor in establishing the employer's inexcusable fault, with an increased annuity and additional compensation at stake. Drafting the DUERP thus connects with handling work accidents and unfitness situations.
Which risks to document: from psychosocial to chemical#
The assessment is not limited to visible risks (falls, machinery). It must cover all the risk families present in the company:
- physical risks (handling, noise, falls from height or on the level);
- chemical risks and exposure to carcinogenic, mutagenic or reprotoxic agents;
- musculoskeletal disorders, the leading cause of occupational illness;
- psychosocial risks (workload, tensions, harassment);
- organisational risks (atypical hours, lone working).
Six of these factors give rise, above certain thresholds, to entitlements under the occupational prevention account (C2P): the exposed employee accrues points usable for training, a move to part-time work or early retirement. Documenting exposures precisely in the DUERP is therefore also a matter of individual traceability.
The role of the CSE and prevention services#
The DUERP and its updates are made available to the social and economic committee, which takes part in analysing risks. In companies with at least three hundred employees, a health, safety and working-conditions committee (CSSCT) is set up within the CSE and is delegated the examination of these issues.
The employer also relies on its occupational health and prevention service, which contributes to the assessment, carries out employees' medical monitoring and may propose prevention measures. For very small businesses, the INRS provides sector tools to assist assessment (the OiRA approach), which structure hazard identification without prior expertise.
DUERP and inexcusable fault: the liability stake#
The legal weight of the DUERP shows above all in the event of harm. When a work accident or occupational illness occurs and the risk had been neither assessed nor prevented, the employer risks a finding of inexcusable fault: the victim then obtains an increased annuity and compensation for additional losses, borne by the employer. Conversely, a serious, up-to-date DUERP followed by an action plan evidences the employer's diligence and is a central piece of its defence. The document is thus not an administrative formality: it is an instrument for controlling risk and protecting the business.
A five-step practical method#
- Break the company into coherent work units.
- Identify, for each unit, the hazards and exposure situations.
- Rate each risk (severity and frequency) to prioritise them.
- Define an action plan (PAPRIPACT or action list) and schedule it.
- Date each version, archive it for forty years and present it to the CSE.
Frequently asked questions
From how many employees is the DUERP mandatory?+
From the first employee. The obligation applies to every employer, whatever the company's size.
Must the DUERP be updated every year?+
Yes in companies with at least eleven employees. Below that, the update happens on a major change or new information about a risk, with no imposed annual frequency.
How long must the DUERP be kept?+
At least forty years, each successive version, available to exposed workers and supervisory bodies.
Is online filing of the DUERP mandatory in 2026?+
No. The national online portal provided for by the 2021 law is not deployed. Only internal retention applies today.
What penalty applies for a missing DUERP?+
A fifth-class fine (1,500 euros, 3,000 euros on repeat), and above all aggravated employer liability in the event of an accident (inexcusable fault).
Key takeaways#
- DUERP mandatory from the first employee (articles L4121-3 and R4121-1).
- Annual update from 11 employees; on every change below that.
- Retention of at least 40 years for each version.
- Digital filing provided for but not deployed in 2026: internal retention only.
- PAPRIPACT from 50 employees; action list below that.
Official sources#
- Légifrance — Articles L4121-3 and R4121-1 of the Labour Code.
- Légifrance — Law no. 2021-1018 of 2 August 2021 to strengthen occupational health prevention.
- travail-emploi.gouv.fr — The single occupational risk assessment document (DUERP).
- service-public.fr — Single occupational risk assessment document.

Article written by Samuel HAYOT
Chartered Accountant, registered with the Institute of Chartered Accountants.
Regulated French accounting and audit firm based in Paris 8, built to support companies across France with a digital and decision-oriented approach.
Sources
Official and operational sources cited for this page.
- Legifrance - Article L4121-3 du Code du travail (evaluation des risques)
- Legifrance - Article R4121-1 du Code du travail (document unique)
- travail-emploi.gouv.fr - Le document unique d'evaluation des risques professionnels (DUERP)
- service-public.fr - Document unique d'evaluation des risques professionnels
- Legifrance - Loi n. 2021-1018 du 2 aout 2021 (sante au travail)
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