NR-1 Changes 2026

The Ministry of Labor and Employment (MTE) released, on May 6, 2026, the first round of Questions and Answers regarding Chapter 1.5 of NR-1, dated April 30, with 22 clarifications aimed at companies, workers, and Occupational Safety and Health (OSH) professionals. The material was prepared by the General Coordination of Standardization and Registration (CGNOR), of the Department of Occupational Safety and Health (DSST), and previously submitted for consultation with the representative groups of employers, workers, and the government in the National Tripartite Thematic Commission (CNTT) of NR-1.

This guide is expressly for guidance purposes and does not replace the normative text, but it focuses on topics that have been generating recurring questions since the publication of the GRO/PGR Manual (2026) and the Information Guide on Psychosocial Risk Factors Related to Work (2025). The focus is on psychosocial risk factors, which are now subject to mandatory identification and management within the context of the Risk Management Program (PGR) and the Preliminary Ergonomic Assessment (AEP) foreseen in NR-17.

In its announcement, the Ministry of Labor and Employment (MTE) indicated that there will be no extension of the effective date, set for May 26, 2026, maintaining its validity despite requests from the business sector for a delay. As a transition mechanism, the Ministry confirmed the application of the double-visit criterion by the Labor Inspection during the subsequent 90 days, a period in which the inspection activity will be primarily advisory in relation to the new requirements.

The requirement applies to all companies.

According to the document, all organizations are required to carry out actions to prevent psychosocial risks through AEP (Assessment of Psychosocial Risks), within the context of Occupational Risk Management (GRO) of NR-1. This includes identifying hazards, assessing risks, adopting preventive measures, and monitoring the entire process.

The Ministry of Labor and Employment (MTE) also clarified that the obligation covers remote, hybrid, and telework arrangements, and that, in the construction industry, the contracting party must incorporate into the construction site's Risk Management Plan (PGR) information about the risks of the contracted companies' activities, including psychosocial factors, as per item 18.4.4 of NR-18.

Micro and small businesses classified in risk levels 1 and 2, which are exempt from PGR (Risk Management Program), must maintain the AEP (Ergonomic Risk Assessment) as a mandatory document to demonstrate the process of managing ergonomic and psychosocial risks.

There is no official professional, tool, or model.

One of the central points of the publication is the confirmation that NR-1 does not establish a professional reserve for the identification and evaluation of psychosocial risks. It is up to the organization to designate a person or team with technical knowledge appropriate to the nature and complexity of the activities, which may involve a multidisciplinary team. This position reaffirms the understanding of Technical Guidance SIT/No. 9/2023, expressly cited in the document.

Similarly, there is no single official tool, methodology, or instrument defined by the Ministry of Labor and Employment (MTE) for this purpose, nor is there a standardized document template. The GRO Manual presents examples of spreadsheets and document structures on pages 94, 95, and 97, but these are merely for guidance.

Questionnaires: an option, not a solution.

The guide makes a relevant distinction for the labor compliance market: the use of standardized questionnaires is an option for the company, but it is not sufficient, in isolation, to characterize the management of psychosocial risks. When used, their results must be technically analyzed and integrated into the Psychosocial Risk Assessment and/or the risk inventory, with the documentation of the results attached to these documents.

The Brazilian Ministry of Labor and Employment (MTE) also ruled out the possibility of mapping psychosocial risks through periodic medical evaluations under medical confidentiality: the hazard identification process refers to the analysis of working conditions and organization, and should not be confused with the individual clinical assessment of workers' mental health.

Oversight will be principled and contextual.

The third part of the document details the inspection regime. During the 90 days following its entry into force—a period of double visits confirmed by the Ministry of Labor and Employment (MTE)—the Labor Inspection will prioritize actions of guidance, instruction, and notification to organizations regarding the need for adjustments, without prejudice to the adoption of administrative measures in applicable cases. After this period, any non-compliance may result in fines, based, among other provisions, on article 201 of the CLT (Consolidation of Labor Laws). The MTE emphasized that the initial period should not be interpreted as a waiver of adjustments, but as a phase of fiscal guidance for the implementation and correction of processes.

The guide clarifies that it is not up to the Labor Inspector to impose a specific methodology. The inspection analysis will focus on the technical consistency of the adopted process, the methodological coherence, the ability to identify hazards, the integration with the Occupational Risk Management System (GRO), and the effectiveness of the implemented measures. There will also be no single operational protocol, national checklist, or standardized inspection instrument for psychosocial risks, at least for now.

In a situation that is particularly sensitive for many companies, the Brazilian Ministry of Labor and Employment (MTE) noted that the absence of psychosocial factors in the Risk Inventory does not, in itself, constitute an irregularity, provided that the organization demonstrates, in a technically sound manner, the process of identification, analysis, and the criteria that led to this result. The illustrative lists present in official guides and manuals are also merely referential and not exhaustive or normative.

What to expect from here on out

The publication reinforces that the focus of the inspection will be on the demonstrable process, and not simply the presentation of formal documents. In practical terms, companies will need to demonstrate consistency between the methodology adopted, the criteria defined, the reality of the activities, the hazards identified, the prevention measures implemented, and the effectiveness of the risk management process.

The document will be updated periodically and is available on the official NR-1 page on the Ministry of Labor and Employment website. The next round of questions and answers should address new topics arising from the practical application of the standard after it comes into effect.

The Labor Law team at Mazzucco & Mello is closely monitoring the implementation of the new provisions of NR-1 and is available to provide clarifications and support in structuring occupational risk management processes, including psychosocial factors related to work.

Article written by: Rafael Mello, Israel Cruz and Ana Vasconcelos.