TL;DR
Sixteen hours for every employer, two modules, by 24 May 2027. Six-hour refresher every five years. The supervisor course goes from eight to twelve hours and must be taken in person.
Why this is a new row, not an update
Until now the employer appeared in training under two conditions: if they personally took on the duties of the prevention service — the Art. 34 course, which concerns a minority of undertakings — or as a worker, where they effectively were one. An employer who had appointed an external prevention head had no path of their own. The Agreement of 17 April 2025, published in Official Gazette no. 119 of 24 May 2025, introduces one for all: sixteen hours, two modules, one legal and one on organising and managing safety.
A date, not a periodicity
This is the distinction that breaks the maths. Every other row in a tracker starts from the certificate date and counts months: five years from job-specific training, two from the supervisor course. Not this one: it is a single deadline, 24 May 2027, the same for everyone and independent of when you start. Setting the expiry by counting back from the last certificate produces a date that means nothing. After the first course, however, the refresher becomes a periodicity again: six hours every five years.
- Sixteen hours, deliverable in person, by videoconference or e-learning.
- Six-hour refresher on a five-year cycle.
- The supervisor course rises from eight to twelve hours and must be in person, with a two-year refresher.
- The 24 May 2027 deadline runs from publication in the Official Gazette, not from taking office.
Where the mistake hides
In many systems the role «employer» is wired to the Art. 34 course. It was an understandable shortcut — those were the only employers with a training duty — and it has become a false negative: the employer who is not the prevention head shows as compliant because nothing is asked of them. They appear in no gap, in no expiry, and the dashboard reads green exactly where the most urgent item sits.
Worth checking across every client now rather than in 2027: sixteen hours for one person can be arranged in a week, sixteen hours for twenty employers all in March 2027 cannot. It is the kind of deadline that produces no symptom until it is too late.
Looking for a workspace for your DPO work?
DPO Workspace is built by a certified DPO. 30-day free trial.
Start free