In many organizations, the DUERP is very much in place. It exists, it is identified, and is sometimes even updated regularly. Yet, from an HR perspective, one question often remains unanswered: Does this document truly reflect the reality of the workplace—the tensions within teams, the ongoing changes, and the risks emerging on the ground?
This issue has taken on a whole new dimension today. The tightening of penalties related to the DUERP does not merely increase the level of regulatory constraints. It also raises the bar for what is expected of companies. It is no longer enough simply to have a document. Companies must be able to demonstrate that occupational risks—including psychosocial risks—have been identified, updated, prioritized, and linked to preventive measures that are consistently implemented over time.
Since the law of June 25, 2026, failure to implement or update the DUERP may expose the employer to an administrative fine of up to €4,000 per affected worker, which may be doubled in the event of a repeat offense (Service-Public Entreprendre - June 26, 2026 - DUERP violations are now subject to penalties).
For a decision-maker, the challenge is therefore twofold: to review the DUERP more carefully, to better distinguish between compliance and management, and to better identify when an update becomes strategically important.
Frequently Asked Questions About the DUERP and Psychosocial Risks
Must psychosocial risks be included in the DUERP?
Yes. The DUERP identifies and analyzes risks in all aspects related to work, including work organization. Psychosocial risks must therefore be included in the DUERP as soon as they are identified in actual work activities (Service-Public Entreprendre - 08/07/2024 - What is the Single Occupational Risk Assessment Document (DUERP)?).
How often should the RPS section of the DUERP be updated?
At least once a year in companies with 11 or more employees, but also whenever a decision changes working conditions or new information about a risk becomes available (Service-Public Entreprendre - August 7, 2024 - What is the Single Occupational Risk Assessment Document (DUERP)?).
Can a helpline help manage psychosocial risks?
Yes, provided it is used as a supplementary source. It can enhance understanding of situations, but it does not replace either risk assessment or analysis by work unit (Service-Public Entreprendre - August 7, 2024 - What Is the Single Document for the Assessment of Occupational Risks (DUERP)?).
What the Tighter DUERP Regulations Actually Mean for Businesses
The change introduced in 2026 is simple to describe but important to understand: the DUERP is now subject to more direct oversight. The labor inspectorate can now issue a warning or an administrative fine, rather than relying solely on criminal proceedings. For HR directors, HR managers, and senior management, this shifts the focus. The DUERP is no longer just a compliance document to be produced or filed away. It becomes an element whose quality can be scrutinized much more concretely (Service-Public Entreprendre - June 26, 2026 - DUERP violations are now subject to penalties).
It is also important to note that the DUERP is mandatory as soon as a company hires its first employee. This is not a trivial matter. It means that psychosocial risks are not a secondary issue reserved for large organizations or times of crisis. Whenever work organization, emotional demands, interpersonal tensions, or internal changes put employees at risk, these factors fall within the standard scope of risk assessment (Service-Public Entreprendre - 08/07/2024 - What is the Single Occupational Risk Assessment Document (DUERP)?).
Another point that is often underestimated: an annual update is not always sufficient. For companies with 11 or more employees, it is a minimum requirement. However, the DUERP must also be reviewed whenever a decision changes working conditions or when new information about a risk comes to light. A reorganization, an alert from the Social and Economic Committee (CSE), a sustained workload, an accident, a labor dispute, or the emergence of new managerial challenges may therefore justify an update without waiting for the usual deadline (Service-Public Entreprendre - August 7, 2024 - What is the Single Document for the Assessment of Occupational Risks (DUERP)?).
In reality, the subject is no longer merely a matter of documentation. It has become demonstrable and traceable. The DUERP must meet requirements for consistency, convenience, and traceability.
This means being able to show what was observed, how it was analyzed, who contributed to the evaluation, and what was decided.
It is therefore not just a matter of proving that a document exists, but that a consistent, objectively verifiable, and sustained prevention strategy has actually been implemented. This is also what distinguishes a purely formal DUERP from one that is administratively correct and one that is genuinely implemented (Service-Public Entreprendre - August 7, 2024 - What is the Single Document for the Assessment of Occupational Risks (DUERP)?)
Find out why preventing psychosocial risks is essential to promoting quality of life at work.
Why Psychosocial Risks Are Often the Weak Point of the DUERP
Psychosocial risks (PSRs) pose a particular challenge: they are harder to objectively assess than physical risks. Whereas certain technical or material hazards are immediately apparent, PSRs manifest themselves in the intensity of work, emotional demands, autonomy, social relationships, conflicts of values, or the insecurity of the work situation. This analytical framework, based on the six risk factors now firmly established in public guidelines, helps avoid an overly vague approach to “stress” and focuses instead on the actual organization of work (Civil Service Portal - 2024 - Prevention of Psychosocial Risks).
This is where many DUERPs reveal their weaknesses. Psychosocial risks are sometimes mentioned, but without being truly analyzed. The documents contain general, often overly broad statements, with no identified work units, no prioritization, and no connection to specific situations. However, the INRS points out that psychosocial factors can offset or reinforce one another, and that they become more harmful when they are prolonged, endured, numerous, or incompatible with one another. A DUERP that merely lists a risk without describing its mechanisms does not allow for an understanding of exposure or for effective prevention management (INRS - November 9, 2021 - Preventing Psychosocial Risks. Risk Factors).
Psychosocial risks (PSRs) are also rapidly evolving risks. They are sensitive to changes in business operations, workforce fluctuations, managerial practices, workplace tensions, and critical events. They evolve more quickly than a static document. At the same time, the broader context of mental health calls for increased vigilance: Santé publique France estimates the prevalence of generalized anxiety disorder among adults aged 18 to 79 at 6.3% in 2024. While this data does not allow us to directly attribute anxiety to work, it serves as a reminder that organizations are operating in an environment where psychological vulnerability is more visible, underscoring the importance of a rigorous assessment (Santé publique France - 2024 - Santé publique France Barometer).
The main blind spot, ultimately, is often the same: confusing stated prevention with demonstrable prevention. Companies may have initiatives, training programs, employee feedback mechanisms, or a QVCT policy in place. This, in and of itself, is not enough to demonstrate prevention of psychosocial risks. The QVCT can support prevention, enrich it, and provide it with tools for action. However, it does not replace the obligation to assess risks, nor does it replace the DUERP itself. The IGAS report on the reform of the DUERP specifically emphasizes the collective traceability of exposures and the retention of successive versions. The challenge, therefore, is not simply to say that action is being taken, but to show how risks are assessed, prioritized, and monitored over time (IGAS – May 2023 – Reform of the Single Occupational Risk Assessment Document: Current Status and Proposals).
What a Comprehensive DUERP Must Be Able to Demonstrate Regarding Psychosocial Risks
A robust DUERP first and foremost links psychosocial risks to specific work situations. It does not discuss risks in abstract terms. It links them to specific jobs, groups of workers, work sequences, sensitive periods, or clearly identified changes. This is, in fact, the intent of the Labor Code, which designates the DUERP as a tool for collectively tracking exposure. The key question, therefore, is not merely whether psychosocial risks exist, but where they occur, for which groups of workers, and under what work conditions (Légifrance – June 25, 2026 – Article L4121-3-1 of the Labor Code).
It must also characterize risk factors, not just list them. Assessing a risk means specifying its frequency, intensity, organizational mechanisms, aggravating factors, and the populations affected. This is what allows us to move beyond an overly moralistic or individualistic interpretation of the difficulties and return to the concrete conditions under which work is performed (Civil Service Portal - 2024 - Prevention of Psychosocial Risks).
A robust DUERP also cross-checks its sources of information. It is not developed solely by the HR department. The Social and Economic Committee (CSE), the employee responsible for occupational safety, and the occupational health and safety department all contribute to the assessment.
This diversity is essential, as psychosocial risks rarely appear in a single source. They can be identified through HR data, feedback from managers, alerts from employee representatives, on-the-ground discussions, and analysis of work situations. HR professionals have a key role to play in implementing effective prevention policies. Learn more about their role in preventing psychosocial risks.
The role of managers deserves to be clarified here: they are neither solely responsible for psychosocial risks nor merely a channel for reporting concerns. They play a role in regulating work, reporting difficulties, and observing situations that sometimes put them at risk as well.
Finally, a robust DUERP links preventive actions to identified risks. This is where the difference between compliance and proactive management lies. In companies with 50 or more employees, the assessment must result in an annual prevention program detailing the selected measures, performance indicators, cost estimates, available resources, and a timeline. This requirement necessitates a shift from a purely declarative approach to one focused on decision-making and monitoring. It is also one of the key factors that distinguishes this process from a simple update of documentation (Ministry of Labor – DUERP).
Monitoring, in fact, becomes central. Successive versions of the DUERP must be retained for 40 years. This figure—often cited but rarely considered—nevertheless changes the nature of the document. It is no longer a one-time record, but a chronicle of exposures, decisions, and changes observed within the organization. This is also what gives substance to a sustainable prevention approach, going beyond merely reacting to an inspection or a one-time event (Service-Public Entreprendre - 08/07/2024 - What Is the Single Document for the Assessment of Occupational Risks?).
When HR Needs to Re-examine the Psychosocial Risks Section of the DUERP
Certain situations make this reassessment particularly necessary. This is the case during a reorganization, a workforce reduction plan, or a significant change in work. A transformation rarely affects only organizational charts. It also alters points of reference, roles, decision-making processes, collective support, and psychological safety. The INRS also includes restructuring, uncertainty about the future of the profession, and uncontrolled changes among the factors contributing to workplace insecurity (INRS - 11/09/2021 - Preventing Psychosocial Risks (PSR). Risk Factors).
We must also be alert to more subtle signs of deterioration. A work environment that is becoming increasingly tense without open conflict, teams that are withdrawing into themselves, a general sense of irritability, a loss of mutual support, or prolonged managerial burnout are not merely a matter of perception. These are often early warning signs of disorganization or overload, which may warrant a more structured assessment. On their own, they do not constitute a diagnosis of psychosocial risks; rather, they indicate that an analysis needs to be conducted.
A report of harassment, an alert from the Social and Economic Committee (CSE), a series of conflicts, or a work overload reported by several employees should also be viewed as possible indicators of a collective risk. The fact that 30% of the French workforce reports having experienced at least one instance of hostile behavior at work over a 12-month period serves as a reminder that these situations are not isolated and that they may reveal broader systemic issues (Info.gouv - 2024 - Preventing Risks, Promoting Well-Being at Work).
Similarly, a serious or potentially traumatic event—such as a death, an assault, a serious accident, or a suicide—often requires us to reevaluate not only the immediate response but also the exposure of affected groups, preexisting vulnerabilities, and the organizational factors involved.
Finally, it is important to keep in mind that visible HR indicators often appear late. By the time a recognized incident rate emerges, the exposure has generally already taken hold. The 6.7% increase in occupational illnesses in 2024—a rise driven in particular by mental health conditions—serves as a reminder that the most visible signs frequently appear only after a prolonged deterioration (Health Insurance - 2024 - 2024 Annual Report on Occupational Risks).
Identifying both visible and invisible risk factors helps prevent psychosocial risks.
How to Turn the DUERP into a Tool for Managing Psychosocial Risks, Rather Than a Static Document
Transforming the DUERP into a management tool first requires clarifying governance. Who monitors? Who raises alerts? Who analyzes? Who makes decisions? Who formalizes? Without this division of responsibilities, the document risks either remaining confined to an HR framework or staying purely technical, without any real decision-making impact. The quality of the social dialogue is an integral part of this robustness: the CSE is not merely a consulted party or an alarm trigger. It must also contribute to the flow of information and the credibility of the process.
It also requires regularly monitoring HR and on-the-ground indicators. Such monitoring ensures that the update process does not become a mere routine. At the European level, 39% of workplaces with 20 or more employees report having an action plan to address stress. This shows that structured approaches exist, but they are not yet widespread (EU-OSHA - 2024 - ESENER 2024 First findings).
Another key point is to clearly distinguish between a weak signal, a risk factor, and a corrective action. A work stoppage, a complaint, or a conflict are not, in and of themselves, risk factors. They are signals. The assessment process involves identifying the underlying exposure mechanisms and then developing appropriate responses.
Traceability of decision-making is just as important. It is not just a matter of keeping a record of what was done, but also of what was discussed, postponed, prioritized, or set aside. This is often what demonstrates that prevention is based on explicit reasoning, rather than on a collection of disconnected initiatives.
Finally, the DUERP must be linked to the psychosocial risk action plan or the QVCT. When such measures already exist, the goal is not to add new ones, but to coordinate them. Here again, the QVCT can serve as a useful framework for action or regulation, without being confused with the obligation to assess risks. In companies with 50 or more employees, the requirement for an annual program—including indicators, costs, resources, and a timeline—provides precisely the framework needed to ensure this coherence. It is also at this level that certain internal decisions are made: who leads the review, when the Social and Economic Committee (CSE) needs to be more actively involved, and at what point existing tools are no longer sufficient (Service-Public Entreprendre - 08/07/2024 - What is the Single Document for the Assessment of Occupational Risks (DUERP)?).
In what situations is an RPS audit useful for ensuring the DUERP is compliant?
A psychosocial risk audit becomes useful when a company is no longer able to assess its psychosocial risks objectively enough. This is often the case when data is abundant but scattered, when internal assessments contradict one another, or when tensions persist without a definitive assessment to help resolve the issue.
It also becomes relevant when a sensitive situation puts the organization at risk: an alert from the CSE, a conflict, a reorganization, unusual absenteeism, managerial tensions, or repeated reports of concerns. Similarly, when actions already taken do not produce visible results, the issue is no longer merely one of the resources deployed, but rather whether those resources are appropriate for the risk factors that are actually present.
The need for a prioritized action plan is often another catalyst. Between trying to address everything and failing to make any decisions, it is essential to be able to prioritize the risks, the affected groups, and the courses of action.
An RPS audit is not intended to replace the DUERP. However, it can help provide an objective view of situations, identify organizational factors, prioritize risks, and support a more robust update. It is a relevant option in certain contexts, particularly when warning signs are increasing, internal interpretations differ, or the governance of preventive measures lacks clarity. It represents less a one-size-fits-all solution than a shift in perspective among several structuring options. Other organizations can, however, strengthen their internal approach, provided they have the necessary expertise, resources, and social dialogue.
In 2024, workplace accidents identified as related to psychosocial risks numbered nearly 29,000—more than 5% of all workplace accidents—a reminder that this issue is no longer a minor one (Assurance Maladie - April 21, 2026 - Psychosocial Risks: A Major Issue for Occupational Health).
The issue is no longer simply about having a DUERP, but about being able to demonstrate how risks are actually assessed, monitored, and managed over time.
This capability is based on the interplay between assessment, indicators, work organization, and prevention measures, which are now at the heart of approaches to preventing psychosocial risks.
