Public consultation on reforms to RIDDOR regime: what does it mean for the construction sector?

On 7 April 2026, the Health and Safety Executive (HSE) put out for consultation proposals to reform the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR). Whilst RIDDOR is a long‑established statutory reporting regime, the HSE has been clear that the consultation is intended to test whether the current legislative framework is still operating effectively in modern, high‑risk sectors.

Since the last major overhaul of the RIDDOR regime, in 2013, working practices - and therefore workplace risks - have evolved significantly. New technologies have changed the way work we work and a greater understanding of occupational ill health has developed.

The current RIDDOR framework has not kept pace with this changing landscape and the proposals which form part of the consultation signal a clear intention to resolve this disconnect. The consultation indicates a clear focus to bring the RIDDOR regime in line with current working practices and the HSE’s regulatory priorities.

While the consultation applies across all sectors, the issues under review are likely to be felt acutely in construction, with the proposed expansion of reporting requirements aimed squarely at activity within this sector.

In Great Britain, the construction sector has historically attracted sustained regulatory attention because of its risk profile. The sector consistently ranks as the highest for work-related deaths and non-fatal injuries. In 2024/25, 35 construction workers were killed in work‑related accidents, accounting for around 28% of all worker fatalities. Over the 3-year period 2022/2023 to 2024/2025, around 50,000 construction workers sustained non-fatal injuries.

RIDDOR reporting plays a central role in the regulatory scrutiny of sites, plant and occupational health. For organisations operating in the construction sector, the consultation is therefore less about abstract policy reform and more about how reporting duties apply to everyday site activity.

What are the proposals?

The HSE is seeking views on both legislative and non‑legislative changes to RIDDOR.

Legislative changes

Dangerous Occurrences

The HSE has identified inconsistency in the way dangerous occurrences are interpreted and reported, particularly in complex construction environments involving plant, temporary works and demolition activity. For those operating in the construction sector, the HSE’s proposed expansion of the list of reportable dangerous occurrences which have the potential to result in injury or death, will be a key area of interest.

The consultation seeks views on expanding the reporting requirements to the following:

• Tunnels and tunnelling activities including the excavation, boring or maintenance of any tunnel 1.2 metres in diameter or greater
• The unintentional fall or dropping of any object from a building or structure under demolition or construction which could cause a specified injury to, or the death of, any person.
• The overturning of construction plant, including the overturn of any excavator, mobile plant, drill rig or pilling rig which could cause a specified injury to, or the death of, any person.
• The uncoiling and projection of material (including any pipework, hosing or material which could cause a specified injury to, or the death of, any person)

In addition, in relation to structural collapse, the proposals seek to clarify that this includes the collapse of any roof, ceiling, temporary works and trench collapses.

With a clear focus on construction activity, any such expansion of the reporting requirements would be felt keenly in the sector. As one of the HSE’s intentions for the proposed changes is to reduce the administrative burden on businesses, questions may reasonably be asked about the practical result of such changes on the construction sector where many more incidents will be brought within the scope of the requirements for reporting.

Acknowledging this possibility, the HSE is proposing to qualify certain new dangerous occurrence categories, including the dropping of objects and the overturning of plant, by reference to whether the incident “could cause the death of a person”. This suggests an intention to focus reporting on genuinely high‑risk events, rather than low‑level site incidents, while still ensuring that serious near misses are brought to the regulator’s attention.

Occupational Health

Another central focus of the consultation is on whether the current reporting requirements regarding occupational ill-health remain fit for purpose. With the current regime requiring the reporting of 6 occupational diseases (such as Carpal Tunnel Syndrome, Hand Arm Vibration Syndrome and Occupational Asthma), the consultation seeks views on the inclusion of an additional 13 conditions.

These include various lung conditions which have historically arisen from workplace exposure to hazardous substances, including asbestos and silica dust. With these conditions remaining prevalent in construction, this signals a clear intention on the part of the HSE to continue to target interventions in the sector.

In addition, the HSE are proposing to include noise induced hearing loss in the list of reportable conditions, reinforcing the HSE’s recent drive in this area. With this too being a key risk in construction, any expansion to include such a condition would also put a spotlight on the sector.

The proposed expansion of the reportable conditions reflects the HSE’s current priority of reducing work -related ill health. That said, given that the HSE’s work in this area has in large part focussed on improving work-related stress, it is notable that work-related stress and suicide have been specifically excluded from the proposals. Instead, the HSE has indicated it will continue to monitor work-related stress through ‘other regulatory and policy tools’ – proactive inspection being one of the most common.

The reason given by the HSE for the exclusion of this condition from the proposals is the ongoing difficulty in defining work-related stress in a consistent and reliable way for reporting purposes. Whilst that may be a fair observation, it raises wider questions on the HSE’s ability to identify trends and enforce in this area more generally.

Aside from expanding the number of reportable conditions, the HSE is also proposing to expand who can formally diagnose a reportable occupational disease. At present, a diagnosis must be made by a doctor registered with and holding a licence to practise from the General Medical Council. The proposal would allow diagnoses by other registered health practitioners, such as registered nurses and physiotherapists. This would reflect modern occupational health practice and the wider range of professionals involved in managing work‑related illness.

Definitions

More generally, the HSE is consulting on proposals to clarify certain definitions within the Regulations where terms such as “work‑related”, “injury” and “routine work” have been identified as unclear or open to differing interpretation. According to the HSE, this ambiguity has resulted in both over and under-reporting under RIDDOR, both of which represent a significant challenge to the HSE in carrying out its regulatory activities.

The HSE propose to provide further clarification and associated guidance to address these ambiguities, with a view to improving the accuracy of the data reported and assisting those dealing with borderline reporting decisions. In a sector dealing with high volumes of RIDDOR reporting, any such clarification would undoubtedly be welcomed by those responsible for submitting such reports within construction.

Non‑legislative proposals – Online Reporting Process

Alongside potential legislative changes, a key proposal is the simplification of the online RIDDOR reporting process, including the reporting form itself. The HSE has identified that improved usability and clearer prompts could improve consistency and data quality while reducing unnecessary administrative burden on duty holders.

Again, for those responsible for high volumes of RIDDOR reports within the construction sector, it is expected that any simplification would be welcomed.

Who should engage with the consultation?

Given the potential impact of the proposed changes on the construction sector, those operating within the sector may wish to consider engaging with the consultation, particularly where they have experience of reporting challenges arising from complex site operations or specialist activities.

Responses can be submitted via an online survey, by email or on paper. The consultation opened on 7 April 2026 and will close on 30 June 2026. Further details are available on the HSE’s consultation website here: https://consultations.hse.gov.uk/hse/proposals-riddor-2013/

What is next?

Following the consultation, any major updates to the RIDDOR regime will require legislative change and are likely to take effect from 2028. Brodies’ Health and Safety team will monitor the outcome of the consultation and provide further updates when they become available.

In the meantime, organisations should ensure that internal systems for identifying and escalating incidents and work related ill‑health are robust, responsibility for RIDDOR decisions is clearly allocated, and reporting decisions are carefully documented.

If you would like to discuss the RIDDOR consultation or any other aspect of Health and Safety, please get in touch with Brodies’ Health and Safety team or your usual Brodies contact.