Saudi Arabia Introduces Comprehensive Occupational Fitness and Non-Communicable Diseases Examinations Regulation
The Kingdom of Saudi Arabia (“KSA”) National Council for Occupational Safety and Health issued the Occupational Fitness and Non-Communicable Diseases Examinations Regulations (the “Regulations”) which established a comprehensive framework for assessing the physical, mental, and psychological fitness of employees across all sectors in KSA.
The Regulations were published in the Official Gazette on 8 September 2025 and became effective date on or around 7 March 2026, although no formal implementation date was confirmed by the competent authorities.
Scope of the Regulations
The Regulations apply to all employees in KSA, including those working in government agencies, private sector establishments, and non-profit organizations, regardless of the type of contractual relationship or nature of work.
Types of Medical Examinations
The Regulation establishes three categories of medical examinations:
- Pre-Employment Medical Examination: This examination is mandatory for all job candidates and must be passed before completing the hiring process.
- Periodic Medical Examination: Conducted at regular intervals based on the profession and the level of potential health risks. These are legally mandatory for certain professions.
- Exceptional Medical Examination: Conducted when needed in specific circumstances, such as after an accident or noticeable change in performance.
Pre-Employment Requirements
All candidates must pass a medical examination of occupational fitness before commencing employment. Results are classified as “fit to work,” “fit with restrictions,” or “unfit to work.”
Examinations must be conducted by a specialised team under the supervision of a doctor specialising in occupational medicine who is accredited by the Saudi Commission for Health Specialties.
Employees who fail periodic examinations must be reassigned or have their position modified and employees may object to results within 30 days of notification.
Employers are responsible for arranging these examinations and covering the associated costs.
Requirements During Employment
Employees must undergo occupational fitness examinations as required by the employer in accordance with the Regulations and approved forms. Periodic medical examinations must be conducted at regular intervals according to the requirements of each profession or job and the type and level of potential health risks.
Under the Regulations, if an employee is unable to fully perform alternative work tasks due to medical restrictions, the employer must provide necessary adjustments to working conditions, such as flexible working hours or part-time arrangements.
Requirements Following Long Medical Leave
The Regulations require that an occupational fitness examination must be conducted upon return from a period of long medical leave. If the requirements of occupational fitness are not met following the return-to-work examination, the employee must be prevented from continuing in their profession, and necessary measures must be implemented to modify or change the employee’s profession.
High-Risk Professions
Occupational fitness examinations for employees in high-risk professions conducted in accordance with the procedural manual for the organisation of work in high-risk professions cover two categories:
- Hazardous Occupations: These are occupations that increase the risk of injury or death due to working conditions.
- Restricted Occupations: These are occupations with legally mandated restrictions and periodic examinations.
Examination Categories for Periodic Assessments
The periodic medical examination consists of four integrated programs, differentiated by color-coding:
- Mandatory Initial Examinations (Orange): Basic periodic examinations required for all workers in specific professions, including for example vital signs assessment and clinical examination.
- Mandatory Advanced Examinations (Green): Additional examinations based on risk assessment or working environment conditions.
- Occupational Fitness Examinations by Exposure (Blue): Examinations added based on exposure to specific workplace hazards such as chemical, physical, or biological agents.
- Optional Advanced Examinations: Discretionary assessments, such as for example age-related preventive examinations or gender-specific screenings.
Confidentiality and Data Protection
The Regulation require records to be retained for a minimum of 10 years from the last examination or five years after termination of employment, whichever is longer. For employees exposed to substances with long latency periods, such as asbestos or ionizing radiation, records must be kept for at least 30 years after cessation of work or until the employee reaches 75 years of age.
Action Points for Employers
- Review current medical examination policies and procedures to identify gaps with the new requirements under the Regulations.
- Assess which employees fall within high-risk or restricted occupation categories requiring enhanced examinations.
- Establish relationships with accredited occupational medicine specialists.
- Develop or update health record management systems to comply with retention and confidentiality requirements.
- Update internal policies to incorporate alternative work arrangements for employees who cannot meet fitness requirements.
- Train HR and management personnel on the new compliance obligations.
Saudisation Developments
The Saudi Ministry of Human Resources and Social Development (“MHRSD”) is continuing its drive to increase employment opportunities and to improve the conditions of the labour market for Saudi nationals.
To further achieve this objective, the MHRSD has issued the Procedural Guide for the 2026 Evolved Nitaqat Programme (the “Evolved Nitaqat Programme”), marking a further development in the Kingdom of Saudi Arabia’s (“KSA”) Saudisation framework.
The updated Evolved Nitaqat Programme represents a continuous strategic step within MHRSD’s ongoing efforts to enhance the Saudi labour market, expand employment opportunities for Saudi nationals, and promote a safe and attractive work environment. The new framework will apply for over three years, effective from April 2026 until December 2028.
The updated Evolved Nitaqat Programme follows the implementation of the Evolved Nitaqat system in 2021 which introduced a comprehensive restructuring of the Saudisation system, imposing a gradual increase in Saudisation percentages across various economic activities, with increasing Saudisation quotas applicable over a three year period. Further, the required Saudisation percentage for each establishment was determined by reference to its economic activity and actual headcount.
2026 Evolved Nitaqat Programme Mechanism
Under the updated Evolved Nitaqat Programme, the Saudisation quotas will be increased across all economic activities for each of the three years under the Programme. Employers will therefore need to employ a higher number of Saudi nationals to comply with the increased Saudisation quotas, as well as employ an increasing number of Saudi nationals over the three-year period to maintain or improve their Saudisation rating.
The updated Evolved Nitaqat Programme continues to rely on incentivising establishments to invest in Saudi national employees. The existing five-category classification (Red, Low Green, Medium Green, High Green, and Platinum) will continue and remain in effect.
MHRSD Services
The scope of services available to establishments will continue to depend on their Saudisation compliance level.
Establishments classified as Platinum, High Green, and Medium Green will continue to benefit from a range of services, including the ability to (i) apply for new visas, (ii) change the professions of non-Saudi national employees, (iii) renew work permits, and (iv) transfer employee services. In addition, under the updated Evolved Nitaqat Programme, establishments classified as Platinum or High Green will benefit from the immediate reflection of hiring Saudi nationals in their Saudisation quotas, thereby enabling establishments to benefit from more MHRSD services.
In contrast, establishments classified as Low Green will continue to face service restrictions, including the suspension of (i) visa applications and (ii) profession changes. Employers classified as Red will also face the same service restrictions in addition to suspension of service transfers, and the prohibition on issuing or renewing work permits for new or existing non-Saudi national employees.
Recommendations for employers
All employers operating in the KSA are advised to review the updated Evolved Nitaqat Programme to ensure that their hiring and workforce planning strategies are aligned with the increased Saudisation requirements applicable to their respective economic activities. Early alignment will be key to maintaining compliance, enhancing the employment of Saudi nationals beyond previous levels, and avoiding operational disruptions or penalties.
KSA Issues Updated Table of Violations and Penalties Under Ministerial Decision No. 112377
The Kingdom of Saudi Arabia (“KSA”) Ministry of Human Resources and Social Development (“MHRSD”) has issued Ministerial Decision No. 112377 in February 2026 which sets forth an updated Table of Violations and Penalties (“Table of Penalties”) which became effective as of February 2026. The Table of Penalties forms part of the MHRSD’s ongoing efforts to strengthen the labour market, protect employees’ rights, and enhance the flexibility and attractiveness of the work environment in KSA.
These amendments follow the recent updates to the KSA Labour Law issued under Royal Decree No. (M/44) dated 8/2/1446 AH, together with subsequent revisions to the Implementing Regulations of the Labour Law under Ministerial Decision No. (115921) dated 19/8/1446 AH which came into effect in February 2025.
The Table of Penalties has reclassified violations into activity based and sector specific categories. This approach is intended to provide greater clarity for both employers and employees regarding compliance obligations. The new classification framework includes, but is not limited to, general violations applicable to all activities, violations related to recruitment and labor services, violations related to employment of minors, violations related to administrative and compliance obligations and violations related to breaches of female employee statutory rights.
Employers operating in KSA should review the Table of Penalties to ensure compliance with the updated regulatory framework.
How Al Tamimi can help?
Their Employment & Incentives team in KSA regularly advises on all aspects of employment law, including Saudisation compliance and workforce planning. If you would like to discuss the impact of these updates on your business or require assistance with compliance under Occupational Fitness Regulations or the Evolved Nitaqat Programme, please contact the Key Contacts.
Key Contacts
Mohsin Khan, Partner, mohsin.khan@tamimi.com
Hayat Rafique, Senior Associate, h.rafique@tamimi.com
Amane Mohammed, Associate, amane.mohammed@tamimi.com
Tamam Aldakheel, Associate, T.Aldakheel@tamimi.com