How to Keep OHS Training Certificates and Records

An OHS training certificate is not a single sheet of paper

When asked in an inspection "has training been given?", most businesses answer by showing a folder full of OHS training certificates. Yet what the inspector looks for is not just the existence of the certificate but the chain behind it: did the employee receive training before starting work, was basic training completed within three months, did they really attend, did they pass the exam, who signed the certificate?

The Regulation on the Procedures and Principles of Occupational Health and Safety Training for Employees (Official Gazette 02.04.2026, No. 33212) bases this chain on four records. The employer prepares the training programme, records attendance with a training attendance record, and issues the necessary certificates for those who complete the training (Art. 5/2). This article explains how to keep these records and how to store them in the personnel file. For the content and duration of training, see our article on the new OHS training regulation.

Record	When is it created?	Who signs?	Basis
Induction training record	Before the employee actually starts work	The trainer, the employee, the employer or their representative	Art. 7/6
Training attendance record	At every face-to-face basic and refresher training session	Participants and trainer	Arts. 5/2-c, 17/1
Remote training system records	For every module delivered remotely	System record	Arts. 12/4, 17/2
Assessment result	At the end of basic training	Trainer; the result is the basis for the certificate	Art. 16
Basic training certificate (Annex 2)	To the employee who successfully completes it	Trainers and the employer or their representative	Art. 17/3
Other training certificates	Refresher, additional training and training arising from other legislation	Employee and employer	Art. 24

The induction training record: the first record

The most notable innovation of the 2026 Regulation is that induction training is documented with a separate record. Every employee, including apprentices and interns, receives training of at least 2 hours, practical and face to face, before actually starting work. Completed training is recorded with the signatures of the trainer, the employee and the employer or their representative (Art. 7/6).

This record does not replace the basic training certificate; induction training does not count towards basic training hours either. There are three points to watch from a record-keeping perspective:

Date and time. The date on the record must not fall on a day after the employee's start date; otherwise it appears the employee worked without training. A record without start and end times does not prove the "at least 2 hours" requirement.
Content. The training covers the work the employee will do, the work equipment they will use, the risks arising from the working environment and workplace-specific measures (Art. 7/2). Each of these headings should appear as a separate line on the record.
The trainer. Induction training may be delivered by the specialist and physician or by a knowledgeable and experienced employee appointed by the employer (Art. 7/4). If an employee was appointed, also put the appointment letter in the file.

We gave an example of the fields of the record and the minute-by-minute flow of the 2-hour programme in our article on the induction training programme.

Attendance list or attendance record?

The document commonly called a "training attendance list" is named the training attendance record in the Regulation. For face-to-face basic training, the record contains the following information (Art. 17/1):

The place and date where the training was held,
The duration of the training and the topic headings,
The name, surname and signature of the participants,
The name, surname and signature of the trainer.

When basic training is split over different days, keep a separate record for each session. Writing "12 hours" on a single record and collecting one signature underneath does not show on which day which topic was taught. We explained how to plan split training in shift workplaces in our article on OHS training, working hours and shifts.

In remote training, the system record replaces the signature. Employees' log-ins and log-outs, training completion rates and assessment results are recorded, monitored and reported (Arts. 12/4, 17/2). Download this report from the platform per employee and archive it; records becoming inaccessible when the platform contract ends is a common problem. In hazardous and very hazardous workplaces, you need to show with a separate attendance record for that section that the job- and workplace-specific risks topic was delivered face to face.

The exam paper: the condition for the certificate

Assessment is carried out at the end of basic training. Those who score at least 60 out of 100 pass; those who fail the first exam may take it up to two more times, and if they still fail, they retake basic training (Art. 16). The basic training certificate is issued only to employees who successfully complete the training (Art. 17/3).

The Regulation does not say how long the exam paper should be kept. However, the legal basis of the certificate is the exam result; we therefore recommend the following:

For paper exams, keep the answer sheet or score sheet together with the certificate.
For remote or blended exams, add the result report taken from the system to the employee's record.
Record each attempt of an employee retaking the exam with a separate date. For an employee who fails the third attempt as well, open a new training plan; this employee must not be left without a certificate.

What the basic training certificate must contain

The certificate is issued in line with the sample in Annex 2 of the Regulation. The sample has the following fields on its front and back:

Front	Back
Employee's name, surname and title	Topic headings in Annex 1: general, health, technical topics
The person, institution or organisation delivering the training and the date of training	Topic 4: option (a) for the hazardous and very hazardous classes, option (b) for the less hazardous class
Date of issue and duration of training	Duration next to each topic heading
Type of training: basic training given for the first time or as a refresher	Any additional topics added by the employer
Method of training: remote or face to face, for which headings
Trainers' names, surnames, titles and signatures
Name of the employee's workplace; name, surname and signature of the employer or their representative

The footnote of the form is important: the employer ticks the option appropriate to the workplace's hazard class under topic 4 and adds any additional topics. The trainers' titles also appear on the certificate (Art. 17/5); instead of simply writing "trainer", state the title clearly, such as OHS specialist or workplace physician. We detailed who may deliver training in our article on who can deliver OHS training.

Ready-made templates circulating as an OHS training certification with the workplace name, type of training and topic durations left blank do not meet these requirements. Reissue the certificate in line with Annex 2.

Training record retention: the personnel file and electronic archive

Basic training certificates are kept in the employee's personnel file (Art. 17/3). Other training within the scope of the Regulation, such as refresher and additional training, is also documented and kept in the personnel file. Training arising from other legislation, such as hygiene or vocational training, is signed by the employee and the employer with its content stated, and is also placed in the personnel file (Art. 24).

A practical personnel file structure can be set up as follows:

Open an OHS training tab and arrange the documents in date order: induction record, basic training certificate, exam result, refresher training.
Keep the originals of attendance records by session in the training folder, and put a copy of the page bearing the employee's signature in the personnel file.
Keep additional training under a separate heading: additional training after an accident or occupational disease, refresher training after an absence of more than six months, training on a change of job or equipment.
Write the refresher date on the front cover of the file and track it with the OHS calendar: every year in very hazardous, every two years in hazardous and every three years in less hazardous workplaces.

Documents prepared under the Regulation may be signed electronically in line with Electronic Signature Law No. 5070; training certificates may be prepared and archived electronically (Art. 26). A scanned wet-signed document and an electronically signed document are not the same thing. If you archive by scanning, also keep the wet-signed originals.

How long should they be kept? The Regulation does not set a retention period for training records. A work accident or occupational disease dispute may arise years after the employee leaves, and the burden of proving that training was given falls on the employer. Set the retention period in a written policy together with your legal adviser, and do not destroy the files of employees who have left during this period.

Record-keeping errors commonly found in inspections

When reviewing training files at businesses in Bursa and the surrounding provinces, we most often encounter these gaps:

There is no induction record; the basic training certificate alone is presented as proof of training before starting work.
The type and method of training are not ticked on the certificate; topics delivered remotely are shown as face to face.
An option not matching the hazard class is ticked under topic 4.
The attendance record has the employee's signature but not the trainer's.
The signature of the employer or their representative is missing from the certificate; only the trainer has signed.
A certificate was also issued to an employee who failed the exam.
No records were taken from the remote training platform, and the data was lost when the contract ended.

The 2026 base administrative fine for not providing training is 8,980 TL per employee and is multiplied by the number of employees; no hazard class increase is applied to this fine. Training without a record risks being treated as not given in an inspection. You can see the current amounts in the OHS administrative fines tool. We listed which documents the file as a whole should contain in our article on the contents of the OHS file.

At Bursa Sistemer, in our OHS training service we deliver the induction record, attendance records, exam results and Annex 2-compliant certificates in the same record structure, and enter refresher dates into the annual training plan.

Frequently Asked Questions

Does an OHS training certificate have a validity period?

No period is written for the certificate itself; the refresher training determines it. Refresher training is given every year in very hazardous workplaces, every two years in hazardous and every three years in less hazardous workplaces, and a new certificate is issued for each refresher.

Is it enough to keep only the certificate instead of the attendance list?

No. The Regulation requires attendance to be recorded with a training attendance record. The record is what shows that the date, duration and topics written on the certificate actually took place.

Can OHS training certificates be stored digitally?

Yes. Certificates can be signed with an electronic signature, and prepared and archived electronically. If you only scan and store a wet-signed certificate, keep the original as well.

Is a certificate issued to an employee who fails the exam?

No. The certificate is issued only to those who successfully complete the training. The employee has two retake opportunities; if they still fail, they retake basic training.