Workplaces are changing over time, though it is advancing the risks have not disappeared, they have evolved with time. In 2026, employers across the UK are navigating hybrid working models, an ageing workforce, increased regulatory scrutiny and growing awareness around long-term occupational health risks. Against this backdrop, health surveillance is no more something an organisation can afford to misunderstand, delay, or treat as an occasional compliance exercise.
Health surveillance sits at the point where legal responsibility, employee well-being, and business risk intersect. It is not about catching people out but about protecting people early, before hard becomes permanent, before absence rises, and before the preventable conditions turn costly claims. For UK employers, understanding your responsibilities around health surveillance in 2026 is essential. Not only to meet legal duties, but to operate responsibly, sustainable, and credibly in a modern workplace.
What is Health Surveillance?
This refers to a system of ongoing checks designed to identify early signs of work-related ill health among employees exposed to specific occupational risks. It should not be confused with the general health check, and it is not the same as optional well-being screening. Health surveillance is required when a risk assessment identifies a health risk that cannot be fully controlled through other measures.
To put it simply: If a job role carries a known health risk, and that risk could lead to long-term harm, employers have duty to monitor the health of employees is exposed to it.
Health Surveillance Under UK Law
UK health and safety legislation places a clear duty on employers to safeguard employee health wherever workplace hazards are present. Health surveillance becomes a legal requirement when exposure to certain risks cannot be fully eliminated through control measures alone and there is a recognised possibility of work-related ill health developing over time.
This applies where employees are exposed to substances, noise, vibration, or working conditions that are known to cause harm, particularly when that exposure is frequent, prolonged, or unavoidable as part of the role. Importantly, the law does not require illness to have already occurred. It is enough that there is a reasonable likelihood of harm arising if exposure continues.
Health surveillance is also only required where reliable and valid methods exist to detect early signs of damage. These methods allow changes in health to be identified at a stage where intervention is still possible, long before conditions become permanent or disabling.
Taken together, this legal framework is designed to prioritise prevention over reaction. By identifying early warning signs and enabling timely action, health surveillance helps protect employees from long-term harm while allowing employers to demonstrate that occupational risks are being managed responsibly and lawfully.
Why Health Surveillance Exists
Health surveillance exists to identify the early signs of work-related ill health before symptoms become severe or irreversible. Many occupational conditions develop gradually, often without obvious warning signs in their early stages, which is why routine monitoring plays such a critical role.
Its purpose is to prevent conditions from worsening or becoming permanent by allowing issues to be recognised early and addressed promptly. This may involve adjusting working practices, improving control measures, or temporarily removing individuals from exposure where necessary.
Health surveillance also enables employers to take timely and proportionate action, rather than responding only after harm has already occurred. Early intervention not only protects employee health but also reduces long-term absence, disruption, and potential liability.
Equally important, health surveillance provides clear evidence that workplace risks are being actively monitored and managed in line with legal requirements. When implemented properly, it protects employees and supports employers in meeting their duties. When ignored or poorly managed, it leaves organisations exposed to avoidable health risks, enforcement action, and long-term consequences.
UK Legal Framework Governing Health Surveillance in 2026
Employer responsibilities for health surveillance are underpinned by several key pieces of UK legislation. These remain highly relevant in 2026 and continue to be actively enforced.
Health and Safety at Work etc. Act 1974
This Act places a general duty of care on employers to ensure, so far as is reasonably practicable, the health, safety, and welfare of their employees.
Health surveillance is one of the mechanisms through which this duty is fulfilled where health risks are present.
Management of Health and Safety at Work Regulations 1999
These regulations require employers to:
- Carry out suitable and sufficient risk assessments
- Identify health risks associated with work activities
- Put appropriate monitoring measures in place
Where risks cannot be eliminated, health surveillance becomes part of the control strategy.
Control of Substances Hazardous to Health (COSHH)
Under COSHH, employers must provide health surveillance where employees are exposed to substances that may cause occupational diseases such as asthma, dermatitis, or lung damage. This can include exposure to:
- Dusts, fumes, and vapours
- Chemicals and cleaning agents
- Biological agents
Control of Noise at Work Regulations
Employers must assess noise exposure and provide health surveillance, typically audiometry, where employees are exposed above action levels. Noise-induced hearing loss remains one of the most common occupational diseases in the UK, despite being entirely preventable.
Control of Vibration at Work Regulations
Where employees use vibrating tools, employers are required to manage the risk of Hand-Arm Vibration Syndrome (HAVS) and carry out appropriate health surveillance. Failure to do so can result in irreversible damage and significant legal consequences.
Employer Responsibilities for Health Surveillance in 2026
In 2026, employer responsibilities go beyond simply arranging tests. Health surveillance must be planned, risk-based, and acted upon.
Identifying Roles That Require Health Surveillance
Health surveillance applies to roles, not individuals. Employers must identify job roles where exposure to specific risks occurs. Common examples include:
- Manufacturing and engineering roles
- Construction and building trades
- Healthcare and cleaning environments
- Warehousing and logistics
- Laboratory and chemical handling roles
Office-based roles are not exempt. Poor ergonomics, prolonged DSE use, and repetitive tasks can also create health risks if left unmanaged.
Conducting Suitable and Sufficient Risk Assessments
Risk assessments are the trigger for health surveillance. Without them, surveillance becomes unfocused and ineffective. A suitable risk assessment should:
- Identify hazards clearly
- Assess exposure levels
- Determine whether health surveillance is required
- Inform the type and frequency of monitoring
One of the most common employer mistakes is arranging health surveillance without revisiting the underlying risk assessment.
Providing Appropriate Health Surveillance
Employers must ensure that health surveillance is:
- Relevant to the identified risk
- Carried out by competent professionals
- Conducted at appropriate intervals
- Reviewed and adjusted where necessary
Baseline assessments are essential, particularly for new starters, to establish a reference point for future monitoring.
Acting on Health Surveillance Results
Health surveillance is not a data-collection exercise. Employers have a responsibility to act on findings, which may include:
- Reviewing control measures
- Adjusting job roles or tasks
- Referring employees for further assessment
- Preventing further exposure where necessary
Ignoring results can be as serious as failing to carry out surveillance at all.
Types of Health Surveillance Employers Maybe Required to Provide
The type of health surveillance required depends entirely on the risks present.
- Audiometry (Hearing Tests)
Required where employees are exposed to excessive noise levels. Regular hearing tests help identify early hearing damage before it becomes permanent.
- Lung Function Testing (Spirometry)
Used where employees are exposed to dusts, fumes, or respiratory irritants. Common in construction, manufacturing, and chemical environments.
- Skin Surveillance
Essential where employees handle substances that may cause dermatitis or allergic reactions. Early signs are often subtle and easily missed without monitoring.
- Hand-Arm Vibration Syndrome (HAVS) Monitoring
Required for employees using vibrating tools. HAVS can develop gradually and may be irreversible if not identified early.
- Display Screen Equipment (DSE) and Musculoskeletal Monitoring
Often overlooked, but increasingly relevant in hybrid and office-based roles. Poor posture and prolonged screen use can lead to long-term musculoskeletal issues.
Record Keeping and Data Protection Responsibilities
Health surveillance involves sensitive personal data and must be handled carefully.
What Records Employers Must Keep
Employers must keep health records that include:
- The type of surveillance carried out
- Dates of assessments
- Outcomes relevant to fitness for work
These are not medical records and must be stored securely.
GDPR and Confidentiality
Health data must be processed in line with GDPR requirements.
Employers should only receive information necessary to manage workplace risk, not detailed medical diagnoses.
Employee Rights and Employer Communication Duties
- Employees have the right to understand why health surveillance is being carried out and how it benefits them.
- Clear communication helps build trust and cooperation.
- Employees may refuse surveillance, but employers still retain responsibility for managing workplace risks.
Common Employer Mistakes That Lead to Non-Compliance
Despite clear legal guidance, a number of common mistakes continue to place employers at risk of non-compliance in 2026. One of the most frequent issues is treating health surveillance as a one-off exercise rather than an ongoing process. Health risks change over time as roles evolve, equipment is updated, or exposure levels increase, and surveillance programmes must reflect this.
Another concern is the use of providers who lack the appropriate competence or occupational health expertise. Health surveillance must be carried out by suitably trained professionals using recognised methods, inadequate assessments can offer false reassurance and fail to identify genuine risks. Employers also commonly fail to review health surveillance programmes regularly, without periodic review, monitoring can become outdated, misaligned with current risks, or insufficient for the level of exposure present.
Poor record keeping remains a significant issue, incomplete or inconsistent documentation makes it difficult to demonstrate compliance and undermines the value of health surveillance should concerns or inspections arise. Finally, there is a persistent assumption that small businesses are exempt from health surveillance requirements. In reality, legal duties apply regardless of organisation size, what matters is the level of risk, not the number of employees. For health surveillance to be effective and compliant, it must be ongoing, proportionate to the risks involved, and reviewed regularly as workplace conditions change.
How Health Surveillance Protects Businesses, Not Just Employees
When done properly, health surveillance delivers tangible benefits:
- Improved productivity
- Reduced sickness absence
- Stronger employer credibility
- Lower long-term compensation risk
- Evidence of compliance during inspections
Employee health and business performance are not separate issues.
Preparing Your Organisation for Health Surveillance in 2026
Employers should regularly review their health surveillance arrangements to ensure they remain appropriate, effective, and aligned with current workplace risks. Health surveillance is not a static requirement, and what was suitable at one point may no longer reflect how work is actually carried out. This review process should include revisiting risk assessments to confirm that identified hazards are still accurate and that no new risks have emerged. Exposure levels should also be reviewed, particularly where working practices, equipment, or staffing arrangements have changed.
Surveillance programmes may need updating to reflect these changes, whether that means adjusting the type of monitoring provided, the frequency of assessments, or the groups of employees included. Employers should also ensure that health surveillance continues to be delivered by competent providers with the appropriate qualifications, experience, and understanding of current guidance. Workplaces evolve over time. Health surveillance must evolve with them to remain meaningful, compliant, and protective of employee health.
How Healthscreen UK Supports Employers with Health Surveillance
Healthscreen UK supports organisations in delivering compliant, risk-based health surveillance that aligns with current UK legislation and workplace realities. By focusing on early intervention, professional standards, and practical employer support, HSCR helps organisations protect employee health while meeting their legal responsibilities. In 2026, health surveillance is not simply about compliance. It is about responsibility.
Employers who take health surveillance seriously protect their people, strengthen their organisations, and reduce long-term risk. Those who treat it as an afterthought expose themselves to avoidable harm both human and financial. Understanding your responsibilities is the first step. Acting on them is what makes the difference.
FAQs
Is health surveillance legally mandatory?
Yes. Health surveillance is legally required where risk assessments identify health risks that cannot be fully controlled through other measures. If employees are exposed to hazards that may cause work-related ill health and reliable methods exist to detect early signs of harm, employers have a duty to put appropriate health surveillance in place.
Who pays for health surveillance?
The employer is responsible for covering the full cost of any required health surveillance. Employees should not be asked to contribute financially, as health surveillance forms part of the employer’s legal duty of care.
How often should health surveillance be carried out?
The frequency of health surveillance depends on the type of hazard, the level of exposure, and individual risk factors. Some forms of surveillance may be required annually, while others may be needed more or less frequently. Programmes should be reviewed regularly to ensure they remain appropriate.
Can small businesses be fined for non-compliance?
Yes. There is no exemption from health surveillance requirements based on the size of the business. Legal duties apply to all employers where workplace risks exist, regardless of how many people they employ.
Is health surveillance the same as a medical examination?
No. Health surveillance is specifically focused on monitoring the effects of work-related risks on health. It does not usually involve full medical examinations and is designed to identify early signs of occupational ill health rather than diagnose unrelated medical conditions.
