Headcount Thresholds: 5 Bands That Change Your Duties Worldwide
Growth is the most common cause of non-compliance in international groups, and it is entirely undramatic.
An entity hires. It crosses a number. A duty attaches. Nobody is notified, because thresholds do not announce themselves, and the people who would recognise the significance are usually in another country looking at a different framework.
This article sets out the five bands where obligations most commonly change, drawing on the jurisdictions covered across this series. The specific figures differ by country and by activity classification, so treat what follows as a map of where to look rather than a substitute for local confirmation.
One general observation first: British instincts are a poor guide here. Great Britain sets very few numerical thresholds and mostly requires proportionate judgement. A great many other countries do the opposite.
Band 1: from your first employee
The band foreign parents most consistently underestimate, because in Britain almost nothing attaches here.
Elsewhere, a great deal does. Belgium requires an internal prevention service from the first employee, alongside affiliation to an external one. Bulgaria requires a contract with a registered occupational medicine service once the entity has any employed person. Slovakia requires both preventive and protective services, safety technical and occupational health, from the first employee. Greece requires every employer to use the services of a safety technician, with no threshold at all. Peru applies its framework to every employer regardless of size. Turkey extended its specialist and physician requirements to small low-hazard workplaces from January 2025.
The practical implication is direct. A three-person representative office in several of these countries carries appointment obligations that a three-person office in Britain does not, and nothing about establishing that office is likely to have surfaced them.
Band 2: five to twenty
The band where Britain finally appears, and where several other systems make their first move.
Great Britain requires a written health and safety policy and recording of significant risk assessment findings at five or more employees, under section 2 of the Health and Safety at Work etc. Act 1974 and regulation 3 of the Management Regulations. The underlying duties apply from the first employee; what changes at five is the obligation to write things down.
Malaysia requires a safety and health coordinator at five or more employees. Cyprus requires a safety committee from ten. Peru requires a joint committee at twenty, with a safety supervisor appointed by the workers below that. Kenya requires a safety and health committee where twenty or more are employed.
This band catches a specific organisational type: the representative office or early delivery centre that has grown past its founding shape without anyone revisiting its governance.
Band 3: fifty
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The single most consequential number in international health and safety, and the one to build a review around.
France attaches significant obligations at fifty. Morocco requires both an occupational medical service and a safety and hygiene committee at fifty. Japan requires named appointments including an industrial physician and a monthly committee at fifty workers per site, alongside the annual stress check programme. Greece requires an occupational physician in addition to the safety technician at fifty. Bulgaria requires a working conditions committee above fifty. Thailand requires a safety committee at fifty. Several other European systems cluster obligations at or near the same figure.
If a group installs only one threshold alarm, it should be this one. Fifty is where a delivery centre or a growing professional office typically acquires a committee, an occupational physician, or both, in a meaningful proportion of the countries it operates in.
Band 4: one hundred
Less universal than fifty, and significant where it applies.
Indonesia makes its formal, externally audited safety management system mandatory at one hundred workers, or below that where the operation is high hazard. Slovakia operates its occupational safety and health commission above a defined size in this range. Qatar has been reported to require a full-time nurse above a threshold in this band for larger operations.
The characteristic of this band is that obligations stop being appointments and start being systems. What is required is no longer a person and a committee but a documented, auditable management framework, which is a different order of undertaking and needs planning well before the threshold arrives.
Band 5: two hundred and above
The largest band, relevant to shared services operations and delivery centres at scale.
Thailand requires a safety department in the workplace at two hundred employees for the relevant business categories, with a provision worth noting: once established, the department must be maintained if headcount subsequently falls below two hundred but remains above one hundred. Growth into that obligation is not fully reversible.
Argentina requires qualified nursing provision above defined numbers of workers per shift. Several jurisdictions scale the required hours of professional safety and occupational medicine support with headcount, most explicitly Austria, which prescribes minimum prevention hours per employee per year, and Argentina, which prescribes monthly professional hours calculated from equivalent workers and activity risk.
The five bands at a glance
| Band | What typically attaches | Examples |
|---|---|---|
| First employee | Appointments and service contracts | Belgium, Bulgaria, Slovakia, Greece, Peru |
| Five to twenty | Written policy, recording, coordinator, committee | Great Britain, Malaysia, Cyprus, Peru, Kenya |
| Fifty | Committee and occupational physician | France, Morocco, Japan, Greece, Bulgaria, Thailand |
| One hundred | Formal management system, audited | Indonesia, Slovakia |
| Two hundred plus | Dedicated department, scaled professional hours | Thailand, Argentina, Austria |
Two cautions about this table. The figures are illustrative of where obligations cluster, not a reference you should rely on, because several countries set thresholds by activity classification rather than by headcount alone, and figures are amended. And a threshold crossed in one country tells you nothing about another.
What to actually do about it
Three practical steps, and none is expensive.
Know your real headcount per entity, per site. Several frameworks count by workplace rather than by legal entity, and some use a calculated figure rather than a simple headcount. Argentina's equivalent worker concept and the activity-classification systems in Slovakia and Thailand are examples.
Set alarms rather than schedules. An annual compliance review will find a threshold crossed eleven months ago. A trigger in your HR system when an entity approaches a relevant number finds it in advance, which is when the appointment, the training and the committee election can be arranged calmly.
Plan for the ratchet. Some obligations do not release when headcount falls, and some require qualified people with training lead times measured in months. Crossing a threshold is not an administrative event you can complete on the day it happens.
All of the European examples above derive from the same EU Framework Directive 89/391/EEC, implemented nationally with entirely different machinery, and the ILO publishes the international standards that sit behind many of the others.
Holding headcount, thresholds and appointment status for every entity in one register, rather than discovering them during an inspection, is where health and safety consultants and software are worth more together than either alone. Periodic health and safety audits are how most groups discover which thresholds they have already crossed.
Where Arinite fits
Arinite maps obligations against the entities a group actually has, which is how thresholds get found before they are breached rather than after. We support 1,500+ businesses across 50+ countries and protect 100,000+ employees, with 95%+ client retention over 15+ years. Our health and safety consultants work extensively with finance and banking, IT and software and professional services organisations, where growth is fast and governance follows at a distance.
Our global health and safety consultants establish which thresholds apply to each of your entities and what attaches at each, and our international health and safety consultants keep that current as you hire. HSE's introduction to managing health and safety covers the British baseline the other bands should be read against.
If you could not say which of your entities is closest to crossing a threshold, a free gap analysis is the right place to start.
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Arinite Health & Safety Consultants
Health & Safety Expert at Arinite
