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Failure to organize regular health check-ups: businesses face fines of up to 150 million VND.

Key points

📌 Regulations regarding the organization of periodic health check-ups for employees of enterprises:

From January 10, 09, Decree 283/2026/ND-CP Regarding administrative penalties for violations in the labor and social insurance sectors, these measures have begun to be implemented. Failure to organize periodic health check-ups or occupational disease screenings for employees will result in a fine calculated per employee affected – and the company will still be required to organize the check-ups or reimburse the costs after paying the fine.

khám sức khỏe thông tư 26
What are the regulations regarding periodic health check-ups for employees according to Circular 26/2026/TT-BYT?

How often are businesses required to conduct periodic health check-ups?

According to Clause 1, Article 21 of the 2015 Law on Occupational Safety and Health No. 84/2015/QH13, employers must organize periodic health check-ups for employees at least once a year. The minimum frequency is doubled (every 6 months) for the following specific groups of employees:

  • Workers engaged in strenuous, hazardous, or particularly strenuous or hazardous occupations or jobs;
  • The worker is a person with a disability;
  • Child workers;
  • Elderly workers.

In addition, Clause 2 of Article 21 of the Law also stipulates that when organizing medical examinations, female employees must undergo gynecological examinations, and those working in environments exposed to factors that pose a risk of occupational disease must undergo occupational disease screening.

⚠️ The costs are borne by the business.

The employer is responsible for the costs of pediodic health check-ups and occupational disease screenings. If the employee has already undergone examinations on their own, the employer must reimburse the employee.

What should be included in a periodic health check-up? Guidance according to Circular 32/2023/TT-BYT.

In addition to organizing periodic health check-ups, businesses must also ensure that they register for check-ups correctly and completely according to regulations. According to Clause 3, Article 36 of Circular 32/2023/TT-BYT (amended and supplemented by Circular 25/2026/TT-BYT, effective August 15th, 2026), periodic health check-ups are conducted according to the contents specified in the Periodic health examination certificate — Form No. 03, Appendix XXIV issued with this Circular. The list includes four groups of contents:

Category Examination content
Physical examination Measure height, weight, BMI; count pulse; measure blood pressure.
Clinical examination Internal medicine (circulatory, respiratory, digestive, renal-urinary, endocrine, musculoskeletal, neurology, psychiatry); surgery; dermatology; obstetrics and gynecology; ophthalmology; otolaryngology; dentistry.
Clinical examination Hematological and biochemical tests, X-rays, and other paraclinical examinations will be performed as directed by the doctor.
Obstetrics and gynecology specialist examination
(for female workers)
According to the regulations in Appendix XXV of the Circular: Gynecology, cervical cancer screening, breast cancer screening, uterine ultrasound (when indicated by a doctor).

According to regulations, periodic health check-ups as stipulated in Circular 32 must be conducted at medical facilities that meet standards, are licensed by the Ministry of Health, and are qualified to provide periodic health check-up services.

The penalty is calculated per employee affected.

According to Clause 2, Article 33 Decree 283/2026/ND-CPEmployers who fail to organize periodic health check-ups or occupational disease screenings for their employees will be fined. for each employee whose rights were violatedThe penalty for cases where the offending party is an organization. equal to 2 times Penalties for individuals:

Subject Fines Maximum
Personal 1 to 3 million VND 75 million VND
Organization 2 to 6 million VND 150 million VND

Even after paying the fine, the obligations are not yet over.

Unlike previous regulations, a notable new point is... Decree 283/2026/ND-CP That is: In addition to fines, violating businesses are also required to implement corrective measures:

  • Mandatory conduction of the overdue health examination and occupational disease screenings for employees in accordance with regulations.
  • Reimbursement of expenses for the medical examinations and occupational disease screenings in cases where employees have already paid for the examinations themselves.

💡Strict compliance saves costs.

Delaying mandatory health checkups does not save businesses expenses. When caught, businesses face fines that can reach up to 150 million VND, and must also pay the full cost of the examination that should have been carried out in the first place — the total actual cost is always higher than the cost of complying on time.

What should businesses do?

Expertis, your trusted partner
Labor and wage compliance review with Expertis
The Expertis team assists businesses in verifying compliance with employee obligations—from contracts and insurance to routine health checkups—and establishing operational procedures to minimize the risk of penalties.
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