Regulatory Norm 01 brings new obligations for employers (update)

At a glance

• Health and Safety Normative Resolution No 1 (Regulatory Norm No 1) will come into effect in May 2026.
• 'Psycho-social factors' are covered as an area of potential risk.
• Companies have until May 2026 to update their Risk Management Programme. 

Update: 9 July 2026

• On 26 June, Justice André Mendonça of the Brazilian Supreme Federal Court suspended for 90 days the application of fines and other sanctions related to the inclusion of psychosocial risks under Regulatory Norm No 1, with effect for all companies operating in Brazil.
• In his preliminary assessment, the Justice held that the current regulation lacks sufficiently clear criteria regarding employers’ compliance obligations and the consequences of non-compliance. As a result, employers cannot reliably determine what measures are required to meet the standard.
• Importantly, the decision does not relieve employers of the obligation to adapt their PGR to address psychosocial risks. Rather, it temporarily precludes the imposition of administrative sanctions based on these requirements while the suspension remains in force.

Update: 22 June 2026

• The regulation came into force on 26 May 2026. The requirement to update the company’s PGR document applies across all sectors.
• In the event of a labour inspection, auditors may review the PGR to ensure it addresses psychosocial risks associated with work.
• However, in the initial 90-day period, authorities are unlikely to impose administrative fines, recognising that the regulation involves a level of subjectivity and adjustment in practice.
• Auditors are more likely to check whether the PGR has been updated and may issue guidance or recommendations if it is not compliant with Health and Safety Normative Resolution No 1.

26 March 2026

Regulatory Norm No 1 requires companies to implement measures to prevent and manage occupational risks in the workplace through a mandatory health and safety document known as the Risk Management Programme (PGR). 

Among the physical, chemical, biological, ergonomic, and accident risks, psychosocial factors are included. This means that companies must identify possible elements that may affect employees’ mental health, monitor those situations, and mitigate the risks associated with mental illnesses.

Companies have until May 2026 to update their PGRs to comply with this resolution.