Removal from the list of workers subject to reinforced individual health monitoring

Since October 1, 2025, the SIR has been abolished for driving licenses and electrical certifications, replaced by a medical certificate valid for five years issued by the occupational physician.

Léa Soler
EHS Consultant
Update : 
12.12.2025
Publication: 
16.05.2025
Contents
Example H2
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Cases of driving and electrical authorization

In line with the reform introduced by law no. 2021-1018, known as the "occupational health law" of August 2, 2021, decree no. 2025-355 of April 18, 2025 has been published in order to optimize medical resources, with the aim of redeploying them on :

  • monitoring employees assigned to workplaces presenting a particular risk; and
  • on the primary prevention actions to which the missions of occupational health and prevention services have been directed by the 2021 reform of these services.

Thus, since October 1, 2025, this text excludes from the list of employees entitled to Enhanced Individual Monitoring (SIR) those workers who may be assigned to a position requiring a driving license (Article R. 4323-56 of the Labor Code) or electrical certification (Article R. 4544-10 of the Labor Code). Instead of SIR, it makes the issuance of driving authorization and electrical certification for live work or operations in the vicinity of exposed live parts contingent upon the possession of a certificate valid for five years proving the absence of medical contraindications.

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The decree of September 26, 2025 establishes the template for these certificates.

Stemming from the reform of Law no. 2016-1088 of August 8, 2016, known as the "Labor Law", Article L. 4624-2 of the Labor Code states that any worker assigned to a position presenting particular risks to their health or safety or to that of their colleagues or third parties evolving in the immediate work environment benefits from a CRS of their state of health. Positions presenting particular risks are listed in article R. 4624-23 of the French Labor Code, and are as follows:

  1. those exposing employees to asbestos, lead, carcinogens, mutagens or agents toxic to reproduction, group 3 and 4 biological agents, ionizing radiation, hyperbaric risk, risk of falls from height during scaffolding assembly and dismantling operations;
  2. those whose assignment is conditional on a specific professional aptitude test, as is the case for workers who hold a driver's license and those authorized to perform operations on or near electrical installations;
  3. Lastly, if he deems it necessary, the employer may supplement the list of jobs in the categories mentioned in I. with jobs presenting particular risks, after consulting the doctor(s) concerned and the social and economic committee, if any, in line with the risk assessment.

To qualify for a CRS, employees must undergo a medical examination prior to being assigned to the position (replacing the information and prevention visit), and this examination must be renewed at intervals of no more than 4 years, plus interim visits. The aim of this follow-up is :

  • Ensure that the worker is fit for the job to which the employer intends to assign him/her, in particular by verifying that the job is compatible with the worker's state of health, in order to prevent any serious risk of harm to his/her health or safety or that of his/her colleagues or third parties in the immediate work environment;
  • Investigate whether the worker is suffering from a condition that poses a danger to other workers;
  • Suggest adaptations to the position or assignment to other positions;
  • Inform the worker about the risks of exposure to the workplace and the medical follow-up required;
  • Make workers aware of the preventive measures to be taken.

Driving licence

Article R. 4323-56 of the French Labor Code stipulates that the operation of certain equipment presenting particular risks, due to its characteristics or purpose, is subject to a driving license* issued by the employer. This is the case, for example, for an employee using a self-propelled handling truck or a mobile elevating work platform.

Since October 1, 2025, the provision requiring workers with a driver's license to have an SIR has been abolished. However, the validity of this driving permit is now subject to the worker holding a certificate proving that they have no medical contraindications to driving the equipment for which they are authorized to drive. This certificate, valid for five years, is issued by the occupational physician following a medical examination. It is presented by the worker to the employer, who keeps a copy for the entire period of its validity. A copy is added by the occupational physician to the occupational health file.

Appendix 1 of the decree of September 26, 2025 defines the model certificate applicable to driving permits. *The driving authorization is issued following an assessment organized by the head of the establishment, which aims to certify that the worker has the aptitude and ability to drive the equipment for which the authorization is being considered. This assessment takes into account the following three elements:

  1. An aptitude test carried out by the occupational physician;
  2. A test of the operator's knowledge and skills in the safe operation of work equipment;
  3. Knowledge of the area and the instructions to be followed at the site(s) of use.

Electrical certification

In accordance with article R. 4544-9 of the French Labor Code, operations on electrical installations or in their vicinity may only be carried out by authorized workers. This authorization is issued by the employer after theoretical and practical training, in accordance with the conditions laid down in the relevant standards.

Thus, for these workers too, the SIR has been abolished since October1, 2025. From now on, in order to carry out operations in the vicinity of live parts or live work, employees must hold a certificate issued by the occupational physician certifying that they have no medical contraindications to the nature of the operations concerned. This certificate, which is also valid for five years, is kept by the employer and included in the employee's occupational health file.

The decree of September 26, 2025 specifies the exact scope of electrical operations for which possession of a medical certificate becomes mandatory.
The following are concerned:

  1. Electrical work in the immediate vicinity or close proximity to exposed live parts;
  2. Short-term work in the vicinity of exposed live parts within the meaning of the decree of April 7, 2021;
  3. Live work, explicitly including live cleaning work.

Conversely, the decree excludes the following transactions from this mechanism:

  • deposits;
  • tests, measurements, checks, and maneuvers;
  • operations on photovoltaic installations.

It also sets out in Appendix 2 the model medical certificate used in the context of electrical accreditation.

In order to clarify these new provisions, the Ministry of Labor and Solidarity has published an FAQ (Individual monitoring of workers' health, operation of machinery, electrical hazards: the decree of April 18, 2025 - Questions and answers) the authorizations for which the validity of the authorization is subject to the holder having a certificate of no medical contraindications:

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Other electrical certifications are not subject to possession of the aforementioned certificate.

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Transitional provisions

Notices of suitability issued under the CRS prior to the present decree replace the new certificate for a period of five years from the date of issue.

As a reminder, in the case of a CRS, the medical examination for fitness to work follows the medical examination for fitness to work on hiring, as well as any renewals. It is issued by the occupational physician. This opinion is sent to the employee and employer, and added to the employee's occupational health medical file.

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Lastly, in both cases, the decree stipulates that the employee or employer can lodge a dispute with the Conseil de prud'hommes under the accelerated procedure for the merits of a dispute concerning a refusal by the occupational physician to issue a certificate.