Mandatory Health Screenings and Safety Services in Portugal: What Every Employer Has to Provide

Hiring even one employee in Portugal brings an obligation that catches a lot of foreign employers off guard: the employer must organize an occupational safety and health service, and must put every worker through a medical examination, starting before the worker begins work. This is not a rule reserved for factories and construction sites. A software company with ten people in an office in Lisbon is covered by it just as much as a construction firm. The labour authority (the ACT) enforces this obligation, which applies from a worker's first day and is a real recurring cost of employing people in Portugal. Let me walk through the legal basis, the ways an employer can meet the requirement, the health screenings themselves, what they cost, and how the rules are enforced.

The legal basis

The framework comes from Lei 102/2009, the law that governs the promotion of safety and health at work (segurança e saúde no trabalho, usually shortened to SST). The core duty it places on every employer is to provide a service covering two connected areas: workplace safety, meaning the identification and control of risks, and occupational health, meaning the medical surveillance of the workers exposed to those risks. Portugal treats this as a baseline condition of employing anyone, not as a feature of hazardous industries, and the labour authority, the ACT (Autoridade para as Condições do Trabalho), inspects and enforces it.

One clarification worth making early, because it confuses newcomers. This SST obligation is separate from workers' compensation insurance. The insurance, governed by a different law, is the private policy every employer must buy to cover work accidents. The SST service under Lei 102/2009 is a separate prevention-and-screening regime. An employer needs both, and they are two distinct costs.

Three ways to provide the service

Lei 102/2009 lets an employer meet the SST duty in one of three ways, and the right choice depends mostly on size and risk.

The first is an internal service (serviço interno), where the company runs its own SST function with its own staff. The law requires this for larger or higher-risk operations, broadly for an establishment with 400 or more workers, or one with 30 or more workers engaged in high-risk activities. The second is a common service (serviço comum), where several companies, often in the same group or sharing a site, set up a shared SST service between them. The third, and the one most small and mid-sized employers use, is an external service (serviço externo): the employer outsources SST to a licensed provider that specializes in it, authorized by the health and labour authorities to deliver these services.

Whichever route an employer takes, the service must staff both areas, workplace safety and occupational health, with properly qualified professionals. Safety requires a certified safety technician (técnico superior de segurança no trabalho), who conducts the risk assessments and advises on prevention. Health requires a qualified occupational physician (médico do trabalho), who runs the medical surveillance. For most companies the practical answer is a contract with an external provider that supplies both, and the required physician hours scale with the size of the workforce.

The health screenings themselves

The part employees actually experience is the medical examination, and Portugal mandates a defined schedule of them (exames de vigilância da saúde), each producing a fitness decision rather than a shared medical file.

The first is the admission exam. A worker must be examined before starting work, or, where urgency justifies it, within the first 15 days of employment. In practice many employers schedule the exam in the first two weeks by default, but the legal default is before the worker starts. After that come the periodic exams, on a schedule set by age: every year for workers under 18 and for workers over 50, and every two years for everyone in between. On top of those, occasional exams are required when circumstances change, for example when a worker returns from a long absence or moves to a materially different role.

The occupational physician does not hand the employer a diagnosis. What the employer receives is a fitness certificate, the ficha de aptidão, which records only whether the worker is fit, fit with conditions, or unfit for the specific job, and keeps the clinical detail confidential. That certificate matters operationally, because assigning a worker to a role without a valid fitness decision is itself a breach.

What it costs

An employer faces two separate costs here, created by two different laws, and they should be budgeted as two lines rather than treated as one. The SST service itself, for an employer using an external provider, is typically billed as an annual fee per worker, and the amount varies with the sector's risk level, the region, and the provider, running from a modest per-head figure for low-risk office work to considerably more for high-risk activities. The external market is competitive, with specialist occupational-health and safety firms offering combined packages that supply both the safety technician and the occupational physician. The medical exams are generally included in or billed alongside that fee. With an internal or common service there is no per-worker fee, but the employer pays instead to employ the safety technician and occupational physician itself, which usually only makes sense for a large workforce.

The second cost is workers' compensation insurance, a different obligation entirely and priced differently: a premium set as a percentage of insured payroll, averaging around 1.75 percent across the market but ranging widely by sector, from well under 1 percent for office work to double digits for construction. When an employer models the true cost of a Portuguese hire, both belong in the model: the SST service fee under Lei 102/2009, and the accident-insurance premium under the separate insurance law. Treating one as if it covered the other understates the cost.

Enforcement by the ACT, and the fitness-certificate gate

The ACT (Autoridade para as Condições do Trabalho) is Portugal's labour inspectorate, the government body that inspects workplaces and enforces employment and safety law, and it treats SST as a priority. Failing to organize an SST service, or failing to conduct the mandatory health exams, is an administrative offence that can bring significant fines, and the exposure rises with the size of the company and the seriousness of the lapse. The fitness certificate adds a second layer: because a worker needs a valid ficha de aptidão for their role, a missing or expired exam is not just a paperwork gap, it can mean a worker is legally not cleared to be doing the job they are doing.

What employers must put in place, and budget for

From the first hire, an employer must have an SST service in place, and for most companies that means a contract with a licensed external provider that supplies both a safety technician and an occupational physician. Every worker needs an admission exam before or right at the start of employment, then periodic exams on the age-based schedule, every year for the under-18s and over-50s and every two years for everyone else, with the physician issuing a fitness certificate the employer keeps on file. Budget the SST service as a recurring per-worker cost, and budget the workers' compensation premium separately, because they are two different legal obligations that people routinely conflate. The piece of timing that matters most is the admission exam, which is legally due before a new employee starts work, so the SST contract and that first exam should be arranged ahead of the start date rather than after it. Once a worker is in the system, the periodic exams simply follow the fixed age-based schedule.