In brief
The legislation does not distinguish work accidents by severity; a work accident in which the employee is physically harmed is reported to the SGK within 3 working days, even if no medical note is issued and the employee returns to work. Incidents that cause no injury are not reported to the SGK, but under Art. 14/1 of Law 6331 they are recorded and investigated at the workplace. Delaying notification creates the risk of benefit recovery and an administrative fine if a medical note is issued later.
Reporting minor work accidents: the short answer
An employee cut their hand, it was dressed in the sickbay, and half an hour later they were back at their machine. No medical note, no trip to hospital. The frequently asked question is: is this incident reported to the SGK? On reporting minor work accidents, the legislation's answer is yes. The law does not distinguish accidents by severity, by whether a medical note was issued, or by whether incapacity for work resulted. If the employee was physically harmed because of the work, the incident is a work accident and is reported.
The reporting deadline is the same for every accident: the employer reports the accident to the Social Security Institution (SGK) within 3 working days of the accident (Law No. 6331 Art. 14/2; Law No. 5510 Art. 13). This article explains why minor accidents fall under this rule, how they differ from incidents without injury, and the records to keep at the workplace. We explain the notification screens step by step in our article on SGK work accident e-notification.
Does the law distinguish "minor accidents"?
The definitions in the two laws are as follows:
- Law 6331 Art. 3/1-g: A work accident is an event occurring at the workplace or because of the conduct of the work that causes death or renders the body mentally or physically impaired.
- Law 5510 Art. 13: A work accident is an event occurring in one of the circumstances listed in the law that renders the insured person physically or mentally impaired immediately or later.
Neither definition contains a threshold: no condition such as "at least one day of incapacity", "a medical note being issued" or "referral to hospital" is required. The word "later" in Law 5510 is also important; a sprain or a particle in the eye that seems trivial at first may turn into a condition requiring a medical note the next day.
The SGK's notification form reflects this approach too. The e-notification screens ask in separate fields whether the injured person continued working after the accident and about incapacity for work. The form anticipates from the outset an injured person who continues working and has no incapacity.
The difference between first aid case reporting and internal records
The confusion usually arises from treating two separate obligations as one. Art. 14 of Law 6331 has two paragraphs:
- Art. 14/1 (recording and investigation): The employer keeps a record of all work accidents and occupational diseases and prepares reports after carrying out the necessary investigations. It also investigates incidents that did not cause injury or death but damaged, or had the potential to damage, the workplace or work equipment.
- Art. 14/2 (notification): It reports work accidents to the SGK within 3 working days of the accident.
On this basis, you can classify incidents as follows:
| Incident | Notification to the SGK | Recording and investigation at the workplace | Example |
|---|---|---|---|
| No injury, but a hazard | No | Yes (Art. 14/1-b) | A box fell from a shelf without hitting anyone |
| No injury, equipment damaged | No | Yes (Art. 14/1-b) | A forklift hit a column |
| Injury with return to work after first aid only | Yes, within 3 working days | Yes | Cut, return to work after dressing |
| Examined, no medical note | Yes | Yes | Dust in the eye, flushed in A&E |
| Medical note and incapacity | Yes | Yes | Crush injury, 5 days' sick leave |
For recording incidents without injury, our article on the near miss reporting system suggests a practical form and flow. If there is doubt about which incidents count as work accidents (company shuttle, rest breaks, business travel), see our article on situations that count as work accidents.
Why should reporting a small accident not be put off?
The decision not to report a minor accident is usually made in the belief that "nothing really happened". But the consequences emerge later:
- The hospital reports too. Under Art. 14/4 of Law 6331, healthcare providers report work accidents that come to them to the SGK within 10 days at the latest. If the employee goes to hospital in the evening and says it happened at work, the SGK learns of the accident that way.
- A medical note may come later. A wound dealt with by a dressing on the first day may require sick leave because of infection. If the accident was not reported on time, under Art. 21 of Law 5510 the temporary incapacity benefit paid for the period up to the notification date is recovered from the employer.
- Administrative fine: The 2026 basic amount for not reporting a work accident on time is 44,443 TL, and the fine is imposed by the SGK. Failing to keep records and prepare reports is subject to a separate basic amount of 33,326 TL. You can see how the amounts increase by hazard class and number of employees in the OHS administrative fines tool.
- Loss of evidence: An unreported accident is not investigated. Repeated small cuts at the same bench may be the forerunner of a serious accident, and without records this repetition is invisible.
Art. 13 of Law 5510 also requires immediate notification to the law enforcement authorities alongside the SGK; this provision does not distinguish accidents by severity either.
Internal recording: from the first aid record to the accident file
Making sure minor accidents are not missed depends on setting up the first record on site properly. Put the following flow in writing:
- First aid record: The first aider who responded fills in a record on the same shift: date and time, person, department, what happened, type and location of the wound, treatment given, and whether the person returned to work. Have a printed form beside the sickbay or first aid cabinet.
- Informing the supervisor: The shift supervisor sees the record the same day and passes it on to the OHS unit. The "it's not serious" judgement is not the supervisor's to make.
- Assessment by the specialist and physician: The OHS specialist assesses whether the incident is a work accident and its cause; the workplace physician sees the injured person if necessary.
- SGK notification: An incident concluded to be a work accident is reported before the 3 working days are up; the outcome of a medical note is not awaited before reporting.
- Investigation and measures: A simple root cause analysis is carried out and the measure is written down with a responsible person and a date. Our article on the work accident report and witness statements guides you on gathering information after an accident.
- Additional training: Under Art. 19 of the 2026 training regulation, an employee who has had a work accident is given additional training on returning to work, before starting work, on the causes of the accident, ways of protecting against it and safe working methods. For a minor accident this training may be short, but it is documented in minutes.
- Risk assessment: A work accident is one of the situations requiring the risk assessment to be reviewed regardless of its period. For a minor accident the change may be small; but the review of the relevant line is recorded.
Common mistakes
- Waiting for the medical note: The "we'll report it if a note is issued" approach misses the deadline; the 3 working days run from the accident.
- Leaving the accident record in the first aid book: If the book is kept but never reaches the OHS unit, the recording obligation is not considered fulfilled.
- Forgetting the subcontractor's employee: If the injured person is insured by a subcontractor, the subcontractor makes the notification; but the incident should also go into your records.
- Trying to report incidents without injury: Near misses go into the workplace's own recording system, not to the SGK.
In businesses in Bursa and the surrounding provinces, as part of our OHS specialist service, we prepare first aid and accident record forms, and take on the investigation of minor accidents and the gathering of the information needed for notification. For everything to do in the first 72 hours, see our article on what to do after a work accident.
Frequently Asked Questions
Is the accident of an employee who did not get a medical note reported to the SGK?
Yes. The law requires no medical note or incapacity for notification. If the employee was physically harmed because of the work, the accident is reported within 3 working days even if they have returned to work; the e-notification form states that there is no incapacity.
Is an incident with no injury at all reported?
It is not reported to the SGK. Under Art. 14/1 of Law 6331, incidents that cause no injury but cause damage or have the potential to cause damage are investigated and reported at the workplace. These incidents are the subject of near miss records.
What happens if I report a minor accident late?
An administrative fine is imposed; the 2026 basic amount is 44,443 TL. If a medical note is issued later, the temporary incapacity benefit up to the notification date is recovered from the employer by the SGK.
What happens if an incident we reported is not considered a work accident?
The SGK may investigate the incident and decide that it is not a work accident. So write the description of the incident concretely and accurately, and keep it consistent with witness statements and the first aid record.
A certified specialist matched to your hazard class: site inspections, approved logbook, training plan, annual plan and report follow-up.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.