Company Doctor Costs: What Employers Must Pay and How Prices Are Structured

Under § 3(1) of the Occupational Health and Safety Act (ASiG), all employers are required to appoint a company doctor. Company doctor costs therefore constitute mandatory expenditure for every organisation, regardless of sector or size. The level of these costs depends on the size of the establishment, the hazard classification under DGUV Regulation 2, and the chosen contractual model.

This article provides a comprehensive overview of the pricing structure for occupational health services: legally prescribed minimum deployment times, common billing models, typical annual cost examples, and selection criteria for external service providers. It also explains which cost components are frequently underestimated and how a structured commissioning process reduces administrative burden.

The obligation to appoint a company doctor applies under § 2 ASiG to all businesses from one employee upwards. There is no exemption for micro-enterprises. What differs is the scope of care: DGUV Regulation 2 provides for the entrepreneur model for businesses with up to 10 employees, provided the entrepreneur can demonstrate the relevant training and no special hazard situations exist. The entrepreneur model must be registered with the competent trade association and requires a certified prevention training course.

Where a special hazard situation exists (e.g. use of hazardous substances, radiation protection, night work, infection risk), the entrepreneur model is excluded and a company doctor must be appointed. These exclusions are exhaustively listed in DGUV Regulation 2 and affect more businesses than is commonly assumed.

From 11 employees onwards, the standard care regime under DGUV Regulation 2 applies: a company doctor and a specialist for occupational safety must jointly ensure basic care. From 50 employees, fixed minimum deployment times apply, derived from Annex 2 of DGUV Regulation 2.

Failure to comply with the obligation to appoint exposes the company to fines under § 25 ASiG and, in the event of a claim, significant personal liability for management. The letter of appointment must exist in writing and be stored in a manner suitable for audit. What a legally compliant company doctor appointment looks like is shown in the CIVAC role overview with a complete documentation structure.

The same applies to the specialist for occupational safety: both mandatory functions can be filled internally or externally, but must work in a documented and coordinated manner. A missing coordination plan between the company doctor and the safety specialist (SiFa) can be assessed as a breach of duty during inspections.

The total costs of company medical care consist of four main components. Those who compare only the hourly rate see at most 40–60% of the actual annual costs:

1. Basic care under DGUV Regulation 2: The mandatory minimum inspections and consultations in accordance with Annex 2 of DGUV Regulation 2. This component is non-negotiable; it is calculated from the number of employees and the hazard group.
2. Company-specific care: Additional services beyond basic care, e.g. individual risk assessments, occupational reintegration management, advice following workplace accidents or in special hazard situations. These hours are flexible and can significantly increase the budget.
3. Mandatory and optional health surveillance under ArbMedVV: Certain activities (display screen work G37, driving and monitoring activities G25, respiratory protection G26) trigger health surveillance obligations that the employer must bear. Per examination, costs range from €80 to €250 per employee, depending on the medical protocol and examination frequency.
4. Travel and expenses: A frequently underestimated item that can account for up to 20% of the annual invoice for remote sites. Some providers charge travel time at the full hourly rate.

A fifth cost block arises for organisations with multiple sites: each site requires its own risk assessment and inspection documentation. When the company doctor covers multiple sites, travel costs multiply accordingly.

For a robust calculation, all components should be explicitly itemised in the provider's offer. Proposals that cite only the hourly rate without addressing the other cost components are not suitable for a reliable price comparison.

Annex 2 of DGUV Regulation 2 divides businesses into three hazard groups and specifies separate minimum deployment times for the company doctor and the safety specialist. For budgeting purposes, the company doctor deployment time is the decisive figure:

• Group I (low hazard): Pure office businesses, administration, IT service providers. Minimum deployment time for company doctor: 0.5 hours per employee per year.
• Group II (medium hazard): Retail, hospitality, light assembly, services with physical demands. Minimum deployment time: 1.0 hours per employee per year.
• Group III (high hazard): Manufacturing, chemicals, construction, healthcare with infection risk. Minimum deployment time: 1.5–2.5 hours per employee per year.

These times apply as combined totals for the company doctor and safety specialist. The internal allocation is to be agreed on a company-specific basis; in practice, the company doctor accounts for 40–60% of total time depending on the sector.

In addition, there is the company-specific care time, which arises from current operational needs: e.g. increased advisory input following a series of workplace accidents, introduction of new work equipment, or the emergence of occupational diseases. This time is not included in the Annex 2 figures and increases the annual budget variably.

For businesses with multiple hazard groups (e.g. office and warehousing), the relevant group applies to each area. A blanket classification of the entire business as Group I, while part of the workforce carries out Group II activities, is impermissible and can be challenged during inspections. The competent trade association may demand retrospective compliance with the required care time in the event of incorrect classification.

The following overview shows indicative annual costs based on a net hourly rate of €120, excluding health surveillance examinations and travel costs. Actual costs are regularly higher:

If mandatory health surveillance examinations are included (e.g. G37 for all display screen workplaces with 80 employees: approx. 50 examinations at €120 each), the budget for the trading company increases to approximately €15,600. For a manufacturing plant with obligations under G25, G26, and G37, health surveillance costs can add a further €30,000 to €60,000 per year.

For the IT start-up, the gap between theory and practice is small: few employees, low hazard, and G37 for pure display screen work is only optional health surveillance, not mandatory. For industrial and healthcare businesses, however, actual annual costs can exceed the nominal hourly allocation by 50 to 100%.

These figures illustrate that a company's occupational health costs cannot be derived from the hourly rate alone. What matters is the complete service matrix across all four cost drivers.

External company doctors offer essentially three contractual models, which differ according to business size, planning requirements, and workforce stability:

1. Hourly billing: Invoiced on the basis of hours actually worked. Flexible, but without cost control. Recommended for businesses with fewer than 20 employees, low hazard, and infrequent care needs. Disadvantage: annual costs cannot be calculated in advance.
2. Annual flat fee with quota: Fixed price for an agreed annual hour quota, payable in monthly instalments. Provides planning certainty and typically a 10–15% discount on the list price. Suitable for businesses from 20–50 employees. Important: unused hours generally lapse; a well-dimensioned quota is therefore critical.
3. Per-capita model: Fixed amount per employee per year (€30–80 depending on hazard group). Enables straightforward provider comparison and adjusts automatically to workforce changes. Suitable for growing businesses with fluctuating headcount.

A fourth model, found primarily with larger services, is the site flat fee: a fixed monthly fee per site regardless of headcount, with a defined service package. Advantage: maximum cost transparency. Disadvantage: often uneconomical for very small sites.

For businesses with multiple sites, a nationwide provider with its own medical network is worth considering to reduce travel costs. Pay attention to quality assurance. On the CIVAC FAQ page, answers to frequently asked questions on company doctor obligations, contract contents, and documentation requirements can be found.

A thorough comparison of offers for occupational health care goes beyond the hourly rate. Assess seven criteria systematically:

1. Qualification: Specialist in occupational medicine or a doctor with an additional occupational medicine qualification? The former has completed five years of specialist training and is authorised for all mandatory health surveillance.
2. Scope of services: Are site inspections, advisory consultations, documentation preparation, and expert reports included in the hourly rate?
3. Health surveillance examinations: Are ArbMedVV examinations billed as a flat fee or per hour? Are list prices available for the most common medical protocols?
4. Travel costs: From what distance are travel costs charged? Is travel time treated as compensable working time?
5. Substitute arrangement: What happens if the company doctor is ill or on leave? A provider without a regulated substitute arrangement means that statutory compliance is effectively not guaranteed during those periods.
6. Documentation: How are inspection reports, health surveillance records, and the letter of appointment delivered and archived? A digital solution with export functionality is significantly more advantageous for audit situations than e-mail attachments.
7. Notice periods and price adjustment clauses: Are duration and price adjustment transparently regulated? Multi-year contracts without an index clause are rare; verify which reference index is used.

Recommendation: request at least three comparable offers and create a decision matrix based on these seven criteria. The cheapest hourly rate alone is not a reliable selection indicator.

An internally employed specialist in occupational medicine costs typically €90,000 to €150,000 per year (full-time), including employer social security contributions, continuing education costs, examination rooms, and medical equipment. This investment only becomes worthwhile from a business size of approximately 700 to 1,000 employees with a full-time care requirement, or in sectors with particularly intensive occupational health demands such as hospitals or chemical plants.

For mid-sized businesses of up to 500 employees, the structural advantages of the external model prevail:

• No HR risk: staff turnover, illness, and resignation rest with the service provider.
• Broader range of expertise: external services can draw on specialists within their own network for specific questions, such as toxicologists or occupational psychologists.
• No capital expenditure on examination rooms and medical equipment (ECG, hearing tests, vision testing equipment).
• Immediate availability without a recruitment process, which for occupational medicine specialists can take several months due to the shortage of qualified professionals.

The decision logic is: below 100 employees, almost always external. 100 to 500 employees: comparison worthwhile, external generally cheaper. Over 700 employees with high hazard: an in-house service can become economically viable if full-time utilisation is assured.

For organisations that need to fill several appointed officer roles simultaneously, a platform-based solution is particularly attractive: company doctor and specialist for occupational safety can be commissioned in combination and managed on a shared documentation platform. This saves both coordination effort and costs compared to two independent contracts.

Company doctor costs are fully deductible as business expenses (§ 4(4) EStG). The prerequisite is demonstrable business relevance, documented through the service contract and the agreed scope of services. A clear separation of costs between basic care and health surveillance examinations simplifies accounting and avoids queries from the tax authorities.

Several levers are available for cost optimisation:

• Correctly determine the hazard group: Incorrect classification into a higher group generates unnecessary additional costs. The risk assessment under § 5 ArbSchG is the starting point and should be kept up to date.
• Multi-year framework agreements: With a stable headcount, multi-year contracts reduce the hourly rate by a further 5–10%.
• Leverage synergies with the safety specialist: When the company doctor and safety specialist are provided by the same supplier, efficiencies arise during inspections that may be reflected in a more favourable combined offer.
• Digital documentation: Platform-based report preparation reduces the company doctor's administrative time and thereby lowers the billable number of hours.
• Optimise health surveillance frequency: Optional health surveillance (not mandatory, but to be offered at the employee's request) need not be offered annually; a documented review of the offer frequency in accordance with DGUV recommendations can reduce costs.

Note: the costs of mandatory health surveillance examinations are borne exclusively by the employer; employee contributions are expressly prohibited under § 3 ArbMedVV. Voluntary health surveillance is also free of charge for employees. Contractual provisions that shift costs onto employees are unenforceable.

Businesses that have not yet fulfilled their obligation to appoint under § 3 ASiG, or that wish to update an existing contract, should proceed in a structured manner: determine the hazard group under DGUV Regulation 2 Annex 2, calculate the minimum hours, compare offers using the seven-criteria matrix, and document the letter of appointment in a manner suitable for audit. Anyone who goes through this process once will save considerable time at the next contract renewal and will always have a benchmark for new offers.

CIVAC offers company doctors as Officer-as-a-Service: within two working days, a certified occupational physician is formally appointed, the letter is stored digitally in the CIVAC workspace, and the ongoing reporting line is structured. Audit-ready, documented, and compliant with § 3 ASiG. The platform today covers 25 officer roles that can be managed together through a single workspace.

Anyone wishing to fill the company doctor function internally, or to equip an existing officer with a better tool, can use the CIVAC workspace as a tool licence: 490 audit templates, a training module with certificate, and an AI assistant with source references are available from day one. Others manage compliance like a filing cabinet. We manage it like software. Licence the workspace for your internal officers or appoint our officers.

Turn reading into action: write to info@civac.de. The initial conversation clarifies business size, hazard group, and the appropriate contractual model – with no obligation, in a single appointment.