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E-AIA: occupational health precaution for work abroad (formerly G35)

Who has to arrange occupational health precaution for work abroad, and what happens if it is skipped?

Written by WorkFlex Support Team

E-AIA (formerly known as G35) is a mandatory occupational health precaution under the German Ordinance on Occupational Health Care (ArbMedVV) for certain work-related stays abroad. This article explains when it applies, who is responsible for what, how long an existing precaution counts, what happens if it is skipped, and where WorkFlex supports you.

What E-AIA is

E-AIA can be required in particular for:

  • work in tropical or subtropical regions; or

  • other business trips abroad with particular climatic stress and infection risks.

There is no official country list stating "E-AIA required" or "E-AIA not required". What matters is the specific work location, the activity and the actual risks. In large countries, one region may require E-AIA while another may not.

Who is responsible

E-AIA is an employer-managed requirement, not something the traveller is expected to sort out alone.

What WorkFlex does

WorkFlex helps you identify and document a possible E-AIA requirement early in the travel process. Where the travel data indicates that E-AIA may be required, the risk assessment flags it, so you know before the trip starts that a health precaution may need to be arranged.

You can then check:

  • whether a Vorsorgebescheinigung already exists;

  • whether the next precaution is due;

  • whether the risk profile has changed; and

  • whether a new precaution is needed.

An existing Vorsorgebescheinigung can be stored in WorkFlex as evidence for the individual case, in the employee's document center.

WorkFlex supports the process. It does not replace your risk assessment or the occupational physician's assessment, does not book appointments, does not act as your occupational physician, and does not receive medical information about your employees.

What you as the employer must do

Where mandatory precaution applies, organising it is the employer's responsibility. You must:

  • assess whether E-AIA is required for the specific business trip;

  • check whether a relevant precaution already exists;

  • arrange a new precaution if one is needed;

  • make sure the employee has attended the mandatory precaution before the relevant work starts; and

  • prevent the employee from performing the relevant work without having attended it.

Two further employer obligations in this context have their own legal basis. You carry the cost of the occupational health precaution, because the cost of occupational safety measures may not be passed on to employees (ArbSchG). And you must keep a precaution register, the Vorsorgekartei.

The employee should not have to judge for themselves whether E-AIA is legally required. Legal responsibility for organising the mandatory precaution and complying with it stays with the employer.

If a mandatory precaution has not been completed, the employee must not perform the relevant work.

What the employee must do

Where mandatory precaution applies, the employee must attend the precaution appointment before performing the relevant work. Attending is what is mandatory — individual medical procedures are not automatically mandatory. The employee does not automatically have to accept:

  • every physical examination;

  • every blood test; or

  • every vaccination.

When the first precaution has to take place

The first precaution has to be arranged within the last three months before the relevant activity starts (AMR 2.1). For mandatory precaution, the employee must also have actually attended before the work starts.

In practice it is therefore worth starting the process several weeks before the planned business trip. That leaves enough time to arrange an appointment and, where relevant, any recommended vaccinations or other preventive measures.

The Vorsorgebescheinigung

A Vorsorgebescheinigung is the occupational health precaution certificate issued by the doctor after the appointment. It confirms:

  • that the precaution took place;

  • when it took place;

  • for what reason; and

  • when a further precaution is medically indicated.

It is not a general "fit for travel" or "fit to work abroad" certificate. As the employer, you generally do not receive diagnoses, lab values or other confidential medical results.

Note: for postings to France, a comparable occupational health certificate already covers the French medical certificate requirement. See Medical certificate for postings to France.

The Vorsorgekartei

As the employer you must keep a Vorsorgekartei, a precaution register. It records that occupational health precaution took place, when it took place, and for what reason.

The Vorsorgekartei is a statutory documentation duty in its own right. If it is not kept, or is kept incorrectly or incompletely, that can be a separate regulatory offence under the ArbMedVV.

Medical findings, diagnoses and test results do not belong in the Vorsorgekartei.

How long an existing precaution counts

There is no fixed legal validity period such as "valid for 24 months" or "valid for 3 years". Instead, the rules set maximum intervals for the next precaution:

  • First precaution: arrange within the last three months before the relevant activity starts.

  • Second precaution: no later than 24 months after the relevant activity starts.

  • Further precautions: no later than 36 months after the previous precaution.

These are maximum intervals, not automatic validity periods. The doctor may set an earlier next-precaution date on the Vorsorgebescheinigung, and that earlier date is the one to follow.

When an existing precaution still counts for a new business trip

You can generally still rely on an existing precaution if:

  1. a relevant Vorsorgebescheinigung exists;

  2. the next precaution date has not yet been reached;

  3. the applicable 24- or 36-month maximum interval has not been exceeded; and

  4. the destination, the activity and the risk profile have not materially changed.

Where the risk has materially changed, the risk assessment has to be reviewed and, if necessary, the company or occupational physician involved.

Note: a certificate with a future date does not automatically cover every further trip until that date.

When a new check is required

A new check is required in particular if:

  • the next precaution is already due;

  • the maximum interval has been exceeded;

  • the destination or region has materially changed;

  • there are new or different infection risks;

  • the climate, the working conditions or the activity have materially changed; or

  • it is unclear whether the existing precaution covers the new business trip.

Can the employee travel without E-AIA?

Technically, yes — the employee can travel. What matters is performing the work on site: where mandatory precaution applies, the employer may only let the employee perform the relevant work after they have attended it.

A doctor, clinic or medical emergency service at the destination does not replace the mandatory precaution before the work starts.

Where the precaution genuinely cannot be arranged in time, the minimum practical step is to make sure the traveller has access to local medical specialists throughout the trip. This is a mitigation only. It does not replace the mandatory precaution and does not remove the employer's exposure described below.

What happens if the employer allows the work anyway

If the employer does not arrange a required mandatory precaution, or does not arrange it in time, or lets the employee perform the relevant work without having attended it, this can be a regulatory offence under the ArbMedVV. That applies to intentional as well as negligent conduct.

Failing to keep the required Vorsorgekartei, or keeping it incorrectly or incompletely, can be a separate regulatory offence.

A fine of up to EUR 5,000 can in principle be imposed for such breaches. Where these obligations are breached intentionally and an employee's life or health is endangered as a result, criminal consequences can follow in addition.

After the business trip

Where this mandatory precaution was required for the trip, the employer must offer a follow-up precaution (Angebotsvorsorge) once the activity ends. The employee is not obliged to accept that offer.

Recommended alongside E-AIA

In addition to the statutory mandatory precaution, it is advisable to:

  • start the process several weeks before the trip;

  • involve the company or occupational physician where the destination or the risk is unclear;

  • have recommended vaccinations and, where relevant, prophylaxis checked;

  • arrange medical support at the destination; and

  • ensure appropriate travel insurance and emergency support.

These measures are good practice, but they do not replace a legally required mandatory precaution.

In short

  • The employer is responsible: check whether E-AIA is required, review any existing precaution, arrange a new one in time where needed, and keep the statutory Vorsorgekartei.

  • The employee must attend a required mandatory precaution.

  • An existing E-AIA only continues to count if it is still current in time and still matches the risk profile of the new business trip.

  • Without a required mandatory precaution the employee can technically travel, but the relevant work must not begin.

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